20191201Comments_(66).pdf

Diane Holt
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rjfehringer@g ma il.com
Sunday, December 1, 2019 5:39 AM
Oiane Holt
Case Comment Form: Richard Fehringer
Name: Richard Fehringer
Case Number: IPC-E-18-15
Email: [e-mail]
Telephone:
Address: 1352 SprinB Court
Jerome IDAHO, 83338
Name of Utility Company: ldaho Power
Comment: I received your information in the mail about the possibility of a rate change for your customers that have
installed solar power. I installed the panels solely on the premis of your current rates in hopes of getting my loan paid off
by using that money I was using for power. lf the rates are changed, I believe your customers that installed solar panels
prior to the rate change should be grandfathered in under the current net meter standards. Please consider this very
hard. Thank you, Richard (Rick) Fehringer.
Unique ldentifier: L64.165.206.42
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Sunday, December '1, 2019 8:00 AM
Diane Holt
Case Comment Form: Justin Welty
Name: .,ustin Welty
Case Number: IPC-E-18-15
Email: [e-mail]
Telephone: [phone]
Address: 2309 W. Malad St.
Boise lD, 83705
Name of Utility Company: ldaho Power
Comment: We purchased solar panels over three years ago with the express purpose of offsetting our carbon emissions
to help reduce our carbon footprint and to reduce our power bill in the long run. We were excited that we could afford
the panels and have extra power we generate during peak times credited to our account and that power would be
transferred to our neighbors providing local electricity. Being credited the normal rate was critical to our decision to
purchase the panels. We are by no means rich, and getting full credit for all the extra power we generated was a critical
factor in our decision to purchase the panels. Discovering the ldaho Power now wants to reduce our credit and
essentially steal some of our electricity is infuriating. Forcing us to receive a reduced credit will force us to pay for both
the solar panels and electricity. What made good financial and environmental sense in the long run suddenly seems like
it will be an unwise investment all because ldaho Power wants to turn more of a profit and steal our electricity. I've used
the term "steal" twice now because that is exactly what it is. we paid for the installation of the solar panels, we
generate the electricity, and now ldaho Power wants to pay us a reduce rate and steal some of that electricity for free all
so they can generate a profit.
Boise continues to Brow at one of the fastest rates in the country. Power consumption is and will always be a major issue
for any growing city. Rooftop solar is an excellent solution to this issue. Tens of thousands of roofs exist across Boise and
the surrounding area. All literally doing nothing. lnstead of creating huge solar farms that impact the surrounding
environment, rooftop solar takes advantage of open spaces that already exist. Reducing our credit will decrease the
likelihood that individuals will invest in rooftop solar. While this may help ldaho Power by allowing them to increase
rates of those with rooftop sola r, but it hurts everyone else in Boise. lt will hurt consumers like myself as we will have to
spend more money on electricity and less on eve$hing else. lt will hurt allthe solar companies as individuals will invest
less in rooftop solar. lt will hurt the local economy as there will be reduced solar jobs and less cash in the pockets of
those of us who do have solar. There are multiple reasons to allow those of us who generate our own electricity to be
charge a fair and equal credit. There is only one reason to reduce our credit and that is to allow a greedy utility company
to increase its profits.
I urge you to keep our credits at the going rate and do what is right for the citizens of Boise and not what generates the
most profit for one company.
While I doubt our collective outrage will have any impact on your decisions, I urge you to put people over profit and to
show that we value our environment and our local citizens who invest in solar.
Justin Welty
Unique ldentiff er: 764.\65.206.42
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Diane Holt
Diane Holt
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Sunday, December '1, 2019 8:27 AM
Diane Holt
Case Comment Form: Scott Runkel
Name: Scott Runkel
Case Number: IPC-E-18-15
Email: [e-mail]
Telephone: [phone]
Address: 1610 Northridge Dr
Hailey lD, 83333-8563
Name of Utility Company: ldaho Power
Comment: Dear Commissioners,
About five years ago I installed solar panels on the roof of my house in Hailey, making the decision in part due to the
net metering agreement made with ldaho Power. Changing the deal now seems grossly unfair as my decision was made
based on payback assuming full value for the energy I generate but can't use immediately.
ldaho should be incentivizing renewable energy as much as possible and this move certainly isn't going to do that. lf it
was a free market situation and my carrier changed the agreed-upon rules after a significant investment on my part, I
would switch immediately to a new company. I don't have that option and a m at the mercy of the PUC to recoBnize that
this is patently unfair. I am encouraged by ldaho Power's commitment to clean energy and incentivizing residents to
help achieve this goal makes sense. Let's have rules in place that do that.
Thank you,
Scott
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Diane Holt
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Sunday, December'1,2019 9:28 AM
Diane Holt
Case Comment Form: Sarah Hollopeter
Name; Sarah Hollopeter
Case Number: IPC-E-18-15
Email: [e-mail]
Telephone: [phone]
Address:
Boise lD, 83702
Name of Utility Company: ldaho Power
Comment: Dear ldaho Public Utilities Commission,
I am opposed to the proposed changes to net metering for solar customers brought forward by ldaho Power as part of
case IPC-E-18-15. My principal objections are outlined below. Most disturbing to me and the public is that this change is
based on a secret analysis performed behind closed doors that has not been made available to the public nor other
third-party scrutiny. This violates principals of transparency and severely limits accountability moving forward.
The proposed changes will most likely eliminate the solar panel industry for residential customers in ldaho.
Furthermore, it will drive current and future solar generating customers off of the power grid and ldaho power will lose
customers.
Please take these points into consideration during your deliberations:
1. No net metering changes, or settlement proposals should take effect until the comprehensive study of the cost and
benefits of on-site generation on ldaho Power's system, as was ordered by the PUC in Order No. 34045 Case No. IPC-E-
17-13, has been completed, analyzed, and those findings evaluated by the public, PUC, and all parties with net metering
interests, as stated in that docket.
. No study, nor any information related to a cost/benefit analysis study, was directly used to calculate the terms of
this settlement decision.
. lf a study was used to calculate these proposed changes, then that study should have been made available to the
public and PUC for an opportunity to review before reaching the terms of this settlement or determining any other
potential net metering changes.
. The proposed settlement is an arbitrary representation of parties who met behind closed doors without consultinB
the constituents who actually invested in on-site generation.
. All net metering interests were not taken into consideration during these settlement proceedings. ln fact, the vast
majority of net metering interests were not taken into consideration during these settlement proceedings. Order No.
34046 and Case No. IPC-E17-13 indicates that this case should include all net-metering interests in this study.
. Any chanBes to net meterinB should be evidenced based, and only then should we have a hearing about the
whether net metering changes are properly justified.
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. The current hearing is non-scientific, undemocratic, and should be postponed until a legitimate cost and benefit
study has been properly conducted rather than completely ignored.
2. Grandfathering in existing net metering clients should be an obligation, not a consideration.
. No settlement should have taken place behind closed doors without the direct input of existing net meterlng
custome rs.
. Systems were purchased and engineered based on existinB net metering policies that track production and usaBe
on a monthly basis.
. The adoption of hourly net metering as proposed by the settlement would completely alter how existing systems
would have otherwise been designed. This dramatically alters how these investments otherwise would have been made.
. ln order to protect these investments, systems should be grandfathered along with the meter number attached to
the residence and not only the account number of the client currently residing there. A calculated, expected increase in
home value was a major factor in many solar investments.
. Any implemented changes that may happen should become effective 30 days from the PUc's decision and should
not take place retroactively. This is a standard practice for most policy changes.
Sincerely,
Sarah Hollopeter
Unique ldentifier: 164.165.206.42
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. There were no other existing net metering models for the design of PV systems, or other types of on-site
generation, at the time of this investment.
. The current hearing is non-scientific, undemocratic, and should be postponed until a legitimate cost and benefit
study has been properly conducted rather than completely iSnored.
2. Grandfathering in existing net metering clients should be an obligation, not a consideration.
. No settlement should have taken place behind closed doors without the direct input of existing net metering
customers.
. Systems were purchased and engineered based on existing net metering policies that track production and usage
on a monthly basis.
. There were no other existing net metering models for the design of PV systems, or other types of on-site
generation, at the time of this investment.
. The adoption of hourly net metering as proposed by the settlement would completely alter how existing systems
would have otherwise been designed. This dramatically alters how these investments otherwise would have been made.
. ln order to protect these investments, systems should be grandfathered along with the meter number attached to
the residence and not only the account number of the client currently residing there. A calculated, expected increase in
home value was a major factor in many solar investments.
. Any implemented changes that may happen should become effective 30 days from the PUc's decision and should
not take place retroactively. This is a standard practice for most policl changes.
Sincerely,
Sarah Hollopeter
Unique ldentifier: 764.765.206.42
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Sunday. December 1,20'19 10:08 AtM
Diane Holt
Case Comment Form: Brian Roberts
Name: Brian Roberts
Case Number: IPC-E-18-15
Email: [e-mail]
Telephone: [phone]
Address: 240 E Mikyl Ridge Loop
Nampa ldaho, 83586
Name of Utility Company: ldaho Power
Comment: I added solar power to my home in August in a effort to save on my power bills as well as produce my own
power. The current net metering system is an equitable way for consumers to reduce our cost in an equal portion to
what we no longer require from the utility. We Are Not power producers. We did not set up our own solar system to sell
power. We don't have the economies of scale on our side to offset the cost of what it took to install our own power
production. As a consumer it's only fair to offset at an equal rate the power we produce. You can not allow ldaho Power
to Not equitably offset our electricity usage at the same rate we purchase it. Compensating is for less than what we
purchase our power is the utilities way of taking more power which they spent nothing for and to sell it at their profit.
The power we consumers produce is not for profit of the power utility. lt is for the benefit of us consumers to become
more self reliant on our own efforts.
ldaho Power has no claim to sell the power consumers produce at their profit. ldaho Power can not buy our power
during the day when we are not home to use at at half the cost, then turn around and sell us the power we produced at
full rate. This is robbery.
Unique ldentifier: t64.165.206.42
Diane Holt
I
Diane Holt
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Sunday, December 1, 2019 11:05 AM
Diane Holt
Case Comment Form: Daniel Appel
Name: Daniel Appel
Case Number: IPC-E-18-15
Email: [e-mail]
Telephone: [phone]
Address: 4190 N Waterford Pl
Boise lD, 83703
Name of Utility Company: ldaho Power
Comment: Nearly two years ago made a 550,000 investment in a rooftop solar installation at my personal residence.
This investment was made under the existing net meterinB system rules. I understood at that time that my investment
in a solar power generation system would require approximately 12 years to recoup my investment (after federal Tax
credit).
It is not fair for this proposed change to ldaho Power's reimbursement to solar power generators to be approved by the
PUC.
ln addition this reduced reimbursement rate will have a very negative effect on future solar installations in ldaho. I
would not be opposed to a greater monthly flat fee for being part of the grid system.
Residential solar excess power Beneration during the peak summer demand times helps to reduce ldaho Power's need
for purchasing additional power.
Thank you for your consideration
Unique ldentifier: L64.765.206.42
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Diane Holt
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Sunday, December 1, 2019 1 1:09 AM
Diane Holt
Case Comment Form: Sandra Petersen
Name: Sandra Petersen
Case Number: IPC-E-18-15
Email: [e-mail]
Telephone: 2O8788 9647
Address: 731 northstar drive
Hailey ld, 83333
Name of Utility company: ldaho Power
Comment: Please don't allow ldaho Power to change its net metering so that it penalizes those of us who have solar
panels on our roofs, and discourages potential investment in solar power. Their claim to be 100% renewable by 2045
rings hollow.
Unique ldentifi er: 164.L65.206.42
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Diane Holt
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Sunday, December 1,2019 1l:18 AM
Diane Holt
Case Comment Form: bruce skinner
Name: bruce skinner
Case Number:
Email: [e-mail]
Telephone: [phone]
Address: 16432 n midland blvd #36
nampa lD, 83687
Name of Utility Company: ldaho Power
Comment: Re: Change in rates for solar customers.
Havin gone solar a year and a half ago, we spent a lot of money under the existing rules and regulations. Now a
proposed rule change that had we have known we might not have done the solar project. lts hard to play the game
when the other team can change the rules at any given time.
Thanks for listening, be fair.
Sincerely,
Bruce Skinner
Unique ldentifier: 764.165.206.42
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Diane Holt
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Sunday, December 1, 2019 11:46 AM
Oiane Holt
Case Comment Form: Joe Corcoran
Name: Joe Corcoran
Case Number: IPC-E-18-15
Email: [e-mail]
Telephone: [phone]
Address: 4459 Danridge Ave
Kuna, lD ldaho, 83717
Name of Utility Company: 2 Thumbs Up Plumbing
Comment: We as a business aren't worried about the dollar for dollar issue. We as a business agreed to a solar
installation for selling a watt for a watt . lf for some reason ldaho Power is going to take our watt that we produced and
resell it for a profit that's ldaho Powers business. However that's not what they are doing. ldaho Power is in fact saying
that our watt we produce at our expense is not the same as the watt ldaho Power produces at our expense. That's not
business that is criminal.
Unique ldentifi er: t64.L65.206.42
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Diane Holt
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Sunday. December 1, 2019 12:04 PM
Diane Holt
Case Comment Form: Nolan Corcoran
Name: Nolan Corcoran
Case Number: IPC-E-18-15
Email: th u m bsplum bing@ hotm a il.com
Telephone: [phone]
Address: 4459 5. Danridge Ave
Boise ldaho, 83716
Name of Utility Company: ldaho Power
Comment: Money or not. We all should get a watt for a watt. IDAHO POWER shouldn't have the ability to dictate how
much our watts are worth after ldaho Power agreed that our watts being the same.
Unique ldentifier: 764.765.206.42
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Diane Holt
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Sunday, December 1,20'19 12:08 PM
Diane Holt
Case Comment Form: Nolan Corcoran
Name: Nolan Corcoran
Case Number: IPC-E-18-15
Emall: th u m bsplum bing@ hotm a il.com
Telephone: [phone]
Address: 4459 S. Danridge Ave
Boise ldaho, 83716
Name of Utility Company: ldaho Power
comment: Money or not. We all should get a watt for a watt. IDAHO POWER shouldn't have the ability to dictate how
much our watts are worth after ldaho Power agreed that our watts being the same. Please send us a check for 25,00O
dollars to the above address. lf we are talking dollars please. lf we are talking watts still. Please stick to the contract as
mentioned.
Unique ldentifier: 164.!65.206.42
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Diane Holt
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Sunday, December 1,20'19 12:38 PM
Diane Holt
Case Comment Form: Peter Adams
Name: Peter Adams
Case Number: IPC-E-18-15
Email: [e-mail]
Telephone:
Address: 2785 N. Lancaster Drive
Boise lD, 83702
Name of Utility Company: ldaho Power
Comment: As an owner of a rooftop solar system, I purchased and sized my system based on the net metering
agreement that was in place at the time. lt wasn't as good as an other states but good enough for us to go ahead and
build it. I did this because lwanted to do my part to combat global climate change, and waiting for short term profit
obsessed corporations to do the right thing wasn't going to get it done.
ldaho power moving to a rip-off rate structure for the surplus on my system during the day only to charge me full price
when I use it at night is outrageous, and puts ldaho squarely on the wrong side of history on the single most important
exastential challenge we face. Not only should we NOT punish the providers of rooftop solar for doing the right thing, we
should be working on legislation forcing the utility companies in ldaho to purchase all surplus wind or solar generated
electricity at the end of the year. This kind of head in the sand climate change denial needs to turn around NOW. lt's
only Boing to get more expensive to reverse the damage of excess carbon the longer we wait.
lf this change is allowed to happen, ldaho rooftop solar is going to wither and die, and those of us with existinB systems
are going to need to add expensive battery backup systems to avoid getting ripped off by ldaho power. Please don't let
this happen.
Unique ldentifier: L64.t65.206.42
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Sunday, December 1,20'19 1:44 PM
Diane Holt
Case Comment Form: Joseph Miczulski
Name: Joseph Miczulski
Case Number: IPC-E-18-15
Email: [e-mail]
Telephone: [phone]
Address: 1141 Riverview Drive
Bellevue lD, 83313
Name of Utility Company: ldaho Power
Comment: My solar PV system was installed and put in seNice during May, 2015. lfeel the ldaho PUC should uphold the
original program that was agreed upon by ldaho Power and solar customers. I and many other ldahoans invested in self-
installed clean energy expecting a fair deal.
ldaho families, including mine, and small businesses shouldn't have the rules changed on them after they have already
made their investment.
The ldaho Power proposal could cost existing solar customers thousands of dollars on their electricity bills on top of the
significant personal investment to purchase and install a solar system. ooing our part to protect my children's future on
this planet shouldn't cost our family twice.
Allowing existing solar customers llke my family to stay on the existing net metering program and applying the new
program only to new customers is a commonsense compromise that allows all parties to keep agreements made in good
fa ith.
When changing net metering, other utilities and commissions around the nation allow existing customers to keep the
original terms, because it's unethical and unfair not to. The ldaho PUC should do the same for ldaho families and small
businesses.
The ldaho PUC promised that discriminatory rates would not be the outcome of this proposed rate change. lf changes
are implemented that negatively impact my family's solar investment, it would be discriminatory. The PUC need to hold
true to their word.
ldaho families and businesses should not be penalized for investing their own money into a program that was created to
incentivize purchasing renewable generation. Approving a net metering policy that encouraged investment for long term
savings, only to have it invalidated in this manner, is unethical. We should expect more from our appointed officials on
the PUC and our public utility. lf ldaho Power had no intention of honoring the service agreement they set out initially,
they shouldn't have even made it an option. But ldaho Power did, and it should be honored.
I'm proud my family was willing to make the financial sacrifice to purchase and install a solar PV system and do our part
reducing carbon emissions. Please don't make our investment in our planet's and my son's future more expensive than it
already was by changing the rules in the middle of the game.
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Diane Holt
Maintaining existing utility rates and terms for existing customers is a very common practice for other utilities in the
region making similar changes - ldahoan should be able to to expect the same.
Sincerely,
Joseph B. M iczulski
Unique ldentifier: L64.765.206.42
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Diane Holt
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Sunday, December '1, 2019 1:58 PM
Diane Holt
Case Comment Form: JULIA MAHAFFEY
Name: JULIA MAHAFFEY
Case Number:
Email: jstenuf @gmail.com
Telephone: [phone]
Address: 414 brookdale dr
Boise lD, 83712
Name of Utility Company: ldaho Power
Comment: ANY increase in fees and rates for solar net metering customers is unfaar and short sighted. Solar is one of the
ways customers can help ldaho Power and I do not understand why rates should increase for people trying to do the
right thing for Boise energy needs. I do not have solar because of initial expense. Any move to make solar more
expensive will encourage customers like me who are interested in solar turn away. I do not think this is the right
direction for this public utility.
Sincerely,
Julia Mahaffey
Unique ldentifier: 164.L65.206.42
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Diane Holt
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Sunday, December 1,2019 2:1'l PM
Diane Holt
Case Comment Form: Tabitha Thach
Name: Tabitha Thach
Case Number: E-18-15
Email: [e-mail]
Telephone:[phone]
Address: 3893 S Suntree Way
Boise ldaho, 83706
Name of Utility Company: ldaho Power
Comment: We just got our solar panels and am really disappointed. ln the very least, allowing existing solar customers
to stay on the existing net metering program and applying the new program only to new customers is a good
compromise that allows all parties to keep agreements made in good faith.
Thank you!
Unique ldentifier: L64.765.206.42
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Sunday, December 1, 2019 2:38 PM
Diane Holt
Case Comment Form: Curt and Gwen Fransen
Name: Curt and Gwen Fransen
Case Number: IPC-E-18-15
Email: [e-mail]
Telephone: [phone]
Address: 3844 N. Willowbar Ln.
Garden City ldaho, 83815-7728
Name of Utility Company: ldaho Power
Comment:
We oppose the settlement proposed in this case.
First, we recall that the PUC determined that a "study" to assess both costs and benefits was necessary to assess and
determine a fair rate schedule for customers with on-site generation (See Order No. 34045 in Case No. IPC-E-17-13).
The settlement being proposed may be appropriate but without providing information (the'study') which explains costs
and benefits and how the settlement rate schedule was derived, there is no way for the public, to determine whether
the proposed rate schedule is appropriate or not. The publicshould have accessto,and it isthe responsibility of the
PUC and the involved parties to provide, adequate information as to the factors considered and utilized in determining
the proposed settlement rate schedules. There are likely many factors and methodologies that were or could or should
have been considered or utilized---but we have no way of knowing. lt appears, reading between the lines, that the
export credit rate was derived from and based only on "avoided cost" considerations. Some explanation is necessary as
to why environmental and other public interests were not factored in some manner or even considered.
Second, the new schedules should not apply to existing customers with onsite generation. We invested in our modest
roof-top solar system installed about 5 years ago after considering investment costs, tax credits and likely "pay-back" or
"break-even" periods based on then existing and reasonably foreseeable rates. Because our home was relatively new
and constructed to be extremely efficient, the "break-even" period was about 20 years. There is no way that we could
have known that a radically different rate structure, one that decreases the value of customer generated energy by
more than 50%, would ever be implemented. While we realized that rates could change, we reasonably believed, based
on past PUC actions regarding rates, that any change would be modest and gradual--which 50% is not. Had we known,
we likely would not have installed the system or we would have designed it differently-perhaps larger or incorporating
other design features. Likewise, imposing the new rate structure on our existing on-site generation is unfair in that at
the time the sytem was installed some design features that could have responded to or take into cosideration the
proposed rate structure, simply didn't exist 5 years ago. This concern specifically applies to the proposed change from
monthy net-metering to hourly net-metering. Existing customers which have invested in onsite generation such as
ourselves should be grandfathered for the realistic life-expectancy of our systems, which is around 25 years.
Third, we strongly believe and suggest that the PUC should examine and implement strategies to encourage and harness
the benefits of household solar systems for the public interest, including environmental factors. The public is willing, as
were we, to invest in these systems, partly for the public good, if they make some sort of personal economic common
sense. The current settlement proposal appears to remove most of that incentive. ln a future where global warming
threatens the availa bility of water for hydro power and the use of fossil fuels for turbines, solar and wind Eeneration,
including household systems will be important resource.
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Diane Holt
Thank you, Curt and Gwen Fransen
Unique ldentifier: L64.L55.2O6.42
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Sunday, December 1, 2019 2:57 PM
Diane Holt
Case Comment Form: Lance Fritze
Name: Lance Fritze
Case Number: IPC-E-18-15
Email: [e-mail]
Telephone: [phone]
Address:195 E San Pedro Street
Meridian ldaho, 83646
Name of Utility Company: ldaho Power
Comment: I am opposed to the proposed rate change for net metering on ldaho Powe/s system.
We made a substantial investment to off set our power usage and now ldaho Power wants to change the rules that were
agreed to. Those who already have systems installed should not be subjected to these proposed changes.
ldaho Power claims they need to make the proposed chanBes so that solar customers help pay for their infrastructure,
such as substations, primary lines and transformers. I do believe all ldaho Power customers should help cover these
charges, just not the way ldaho Power wants to do it. We currently do cover some of these charges with our Basic
Charge on our monthly bill. When you look at ldaho Power/s BillTerminology list online, Basic Charge is defined by how
it is arrived and then the last sentence explains, "The Basic Charge, billed on the basis of B[C, recovers a portion of the
capacity-related costs of the distribution facilities, which includes substations, primary lines and transformers."
Based on this definition all ldaho Power solar customers are currently paying for their infrastructure. lf solar customers
are not covering enough ldaho Power should be asking for a rate change regarding their Basic Charge, not their net
metering.
When you look at lda Corp's financial report you can see the parent company of ldaho Power is still in good financial
health, which makes justification for this request hard to understand.
ln summation those currently receiving 1:1 net metering should be grandfathered in, this is what we all based our
decision on.
Solar customers are already paying a basic charge to offset infrastructure, if this needs adjusted this is what ldaho Power
should be requesting, not takinB half of our power credits. Finally ldaho Power wants to derive half of their Power from
green power, this proposalwill make sure it is not going to do that with homeowners help. Please deny this proposal.
Thank you,
Lance Fritze
Unique ldentifier: 164.765.206.42
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Diane Holt
Diane Holt
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Sunday, December 1,2019 3:00 PM
Diane Holt
Case Comment Form: Hannah Sanger
Name: Hannah Sanger
Case Number: IPC-E-18-15
Email: [e-mail]
Telephone: [phone]
Address: 529 S 7th Ave
Pocatello lD, 83201
Name of Utility Company: ldaho Power
Comment: Dear Members of the IPUC,
Thousands of ldahoans have already invested in residential solar systems, purchasing their system using a financial
model that allowed them to invest their own funds and then slowly pay it off by generating solar energy for ldaho
Power. Solar PV net metering reduces ldaho Powe/s generation needs at peak times when electricity is expensive to
produce, as in the summer when air-conditioning requirements are high. The proposed rate structure change will
penalize the ability of existing residential solar system owners to recoup their investment and will discourage future
investments.
The solar PV industry in ldaho grew 43 percent from 2015 to 2015, and renewable energy and energy efficiency
industries are creating jobs at 12 to 20 times that of the general economy. ln Pocatello alone, over 90 residential rooftop
structures were installed this past year. lf the proposed rate structure Boes into effect, fewer homeowners will be able
to afford to install solar systems on their roofs, negatively impacting the solarjob market.
Finally, I am sure that you are aware that similar rate changes have been considered by other state utilities. ln every
case, the legislatures and Utility Commissions have rejected the rate changes and kept net metering (see recent cases
quoted below in Nevada, Montana, Wyoming). The ldaho PUC ought to do the same.
I urge you to keep the net metering rate as it is, and help spur the realization of residential sola/s tremendous energy
potential.
Sincerely,
Hannah Sanger
Residential ldaho Power customer
"ln a vote of 5-0, the Montana Public Service Commission supported clean energy jobs and the right of Montanans to
harness clean electricity from their own solar panels. The Commission reiected NorthWestern Energys proposal to end
net metering, implement a separate rate class, and impose punitive demand charge rates for rooftop solar customers."
(November 25, 2019, Solar Power World).
[Wyoming] "Lawmakers introduced multiple bills to repeal or amend the state's net metering statute. But after more
than four hours of impassioned public testimony Tuesday, two bills drafted to overhaul the state's net metering system
1
I urge you not to change the rate structure for residential users who generate solar power.
failed to advance to session. The Legislature's Joint Corporations, Elections and Political Subdivisions Committee voted
7-7, causinB the bills to fail." (November 19,2079, Casper Star Tribune).
"The Public Utilities Commission of Nevada (PUCN) unanimously approved a draft order on Friday that establishes new
rules and regulations for how net-metered solar customers will be compensated in the state, bringing an end to nearly
two years of policy debate.
"Sometimes the best way to move forward is to take a step back, adjust direction, and restart a8ain," the order states.
"That is what Nevada is doing with rooftop solar and net energy metering."
The decision comes after utility regulators voted to phase out net metering credits and hike fixed fees on all residential
solar customers in December 2015.
The rate change undercut the economics of investing in home solar and slowed Nevada's booming rooftop solar market
to a halt. Hundreds of solar workers were laid off and several installers pulled out of the state.
But with Friday's decision, Nevada's rooftop solar market is officially back In business, say rooftop solar advocates."
(September 5, 2017, GTM)
Unique ldentifier: 164.L65.206.42
2
Diane Holt
From:
Sent:
To:
Subject:
[e-mail]
Sunday, December 1, 2019 3:06 PM
Diane Holt
Case Comment Form: Ric Woolery
Name: Ric Woolery
Case Number: lpc-e-18-15
Email: [e-mail]
Telephone:
Address: 15731 farmway rd
Caldwell ldaho, 83607
Name of Utility Company: ldaho Power
Comment: lt amazes me that ld power is even attempting to under value those who have joined or want to join a
growing community of people that are trying to improve power consumption. I've invested a large amount of money to
aid in generation of power..Why would the PUC even think about letting this happen and push ldaho further into the
dark ages.
Green power should be a huge goal for everyone and a single company should not be allowed to let this happen.
Those that generate green power gain the benefit that ld Power established and now they want to change the rules for
their gain alone. I've always thought that I was also a supportive producer in order to help others that struggle with
income by helping to keep ldaho Powers need to buy power from other sources.
How much power to they sell to others. How much do they buy from others?
Now they want to penalize US?
It will be a sad day if this is allowed to happen
Unique ldentifier: L64.!65.206.42
1
Diane Holt
From:
Sent:
To:
Subject:
Name: Sandra Mansfield
Case Number:
Email: [e-mail]
Telephone: [phone]
Address: 3923 S Mt Vernon Way
Boise lD, 83706
Name of Utility Company: idaho power
Comment: I would like ldaho Power to honor their agreement with me concerning my solar system that I had put in.
ldaho Power has no right to change the terms of sald agreement. What ldaho Power does to future solar customers is up
to them, just, leave the existing solar customers alone.
Unique ldentifier: L64.165.206.42
1
[e-mail]
Sunday, December 1, 2019 3:05 PM
Diane Holt
Case Comment Form: Sandra Mansfield
Diane Holt
From:
Sent:
To:
Subject:
msanger'l [e-mail]
Sunday, December 1, 2019 3:07 PM
Diane Holt
Case Comment Form: Matthew Sanger
Name: Matthew Sanger
Case Number: IPC-E-18-15
Email: [e-mail]
Telephone:
Address: 529 S 7th Av
Pocatello lD, 83201
Name of Utility Company: ldaho Power
Comment: Oecember 1, 2019
RE: Case # IPC-E-18-15
Dear Members of the IPUC,
I am writing you to urge that you not change the net metering rate structure for residential users who generating solar
power.
Many of us have invested heavily in residential solar systems, based upon existing net metering rates (which aren't that
Benerous to begin with). Changing those rates is after a significant investment has been made is entirely unfair.
This will also be a setback for ldaho businesses who have invested in support small scale solar generation, because it
makes their basis of their businesses economical unfeasible. You are knowingly working against ldaho jobs and small
business success, and will have a chilling effect on future business investment, hurting our economy.
Next, like many others, my decision was based in part to help ldaho Power meet its OWN stated goals for renewable
energy production. You claim to support clean sources of power generation, including solar, but your proposal punishes
those of us workinB to support that stated Eoal (at our own expense). That is hypocritical.
A number of our neighboring states have faced similar situations, and made the right move to not punish their citlzens
for doing the right thing, and to support clean energy jobs and economic development in their states. I urge you to do
likewise.
Sincerely,
Matt Sanger
529 S 7th Av Pocatello, lD. 83204
1
Unique ldentifier: 154.165.206.42
Diane Holt
From:
Sent:
To:
Subiect:
[e-mail]
Sunday, December .1, 2019 3:10 PM
Diane Holt
Case Comment Form: Kirk Ebertz
Name: Kirk Ebertz
Case Number: IPE-E-18-15
Email: [e-mail]
Telephone: 2O8 720 2454
Address: PO Box 1901
Ketchum lD, 83340
Name of Utility Company: ldaho Power
Comment: When I signed my net metering agreement with lD Power nothing was mentioned about the possibility of a
rate change. We installed solar panels and agreed to the rules of the current net metering pro8ram. lt is unfair to change
them for existing customers that signed up for the current rates. The PUC has promised that discriminatory rates would
not be an option. Breaking an agreement and changing rates for solar producers is discriminatory.
lf lD Power wants to change the rates for solar producers they should make a new agreement with new customers and
grandfather in current customers to the rates they agreed to.
Home solar panels are important in many ways and you should be doing all you can to support their use.
Thank you, Kirk Ebertz
Unique ldentifier: L64.165.206.42
1
Diane Holt
From:
Sent:
To:
Subject:
[e-mail]
Sunday, December'1,2019 3:14 PM
Diane Holt
Case Comment Form: Gayle Eaton
Name: Gayle Eaton
Case Number: IPC-E-18-15
Email: [e-mail]
Telephone: [phone]
Address: POBox 752
Donnelly id, 83515
Name of Utility Company: ldaho Power
Comment: I bought solar panels 10 years ago. Due to the way that it is regulated, I have yet to see any positive results.
It is also very difficult to see how much lgenerate. I think that ldaho Power should make it easier and profitable for
those who do the responsible thing in this age of climate change. Do not approve this change. Thankyou, Gayle Eaton
Unique ldentifier: L64.L65.206.42
1
Diane Holt
From:
Sent:
To:
Subject:
[e-mail]
Sunday, December 1,2019 3:26 PM
Diane Holt
Case Comment Form: Todd Chavez
Name of Utility Company: ldaho Power
Comment: Dear PUC Commissioners,
Thank you,
Sincerely, Todd Chavez
Unique ldentifier: 764.765.2O5.42
1
Name: Todd Chavez
Case Number: IPC-E-18-15
Email: [e-mail]
Telephone: [phone]
Address: 17934 N Crea8 Way
Boise lD, 83714
I strongly urge you to reiect ldaho Power's proposed change in net metering. We invested in solar power for our home
as a solid action we could take to reduce our carbon footprint. We made the considerable investment based on the
current net metering rates and, even at that, it will not be paid off for many years. lt is not fair for ldaho Power to
change the rules in the middle of the game. Furthermore, their proposed change in net metering Boes against their
stated goal to reach 100% clean energy production by 2045. Our society does not have time to delay the adoption of
10070 clean energy production. ldaho Power should not be allowed to break their promises.
Diane Holt
From:
Sent:
To:
Subject:
[e-mail]
Sunday, December 1,2019 3:50 PM
Diane Holt
Case Comment Form: Charles & Denise Burnett
Name: Charles & Denise Burnett
Case Number: IPC-E-18-15
Email: [e-mail]
Telephone: [phone]
Address: 25498 Emmett Road
Caldwell lD, 83607
Name of Utility company: ldaho Power
Comment: We are against any changes to the current net metering. ldaho Power has not shared any cost/benefit study
information that would justify the changes they suggest. We don't have hourly information for reimbursement changes
suggested.
Grandfathering in these changes over 8 years is really just slowing down the changes. Grandfathering would mean no
changes to current net metering customers.
As a solar generator in the Treasure Valley, our system adds power in the summer during peak needs which should be
something that ldaho Power would want, yet these changes will discourage others from wanting to solarize their homes
Unique ldentifi er: L64.L65.206.42
1
Diane Holt
From:
Sent:
To:
Subject:
[e-mail]
Sunday, December 1, 2019 4:04 PM
Diane Holt
Case Comment Form: Jennifer Harrington
Name: Jennifer Harrington
Case Number: IPC-E-18-15
Email: jennha rr78 @gm a il.co m
Telephone: [phone]
Address: 6240 W. Butte Street
BOTSE tD, 83704
Name of Utility Company: ldaho Power
Comment: I am submitting this comment in protest to ldaho Power's attempt to change the rules regarding how existing
solar customers are paid for energy that they put into the energy grid. When I purchased my solar panels and signed up
with this program it was with the understanding that I would get paid enou8h for the power I produced to cancel out my
bill that I would normally pay to ldaho Power. ln this way, I am able to take the money that I would have paid for
electricity, and apply that to pay for my solar panels. I am low income and cannot afford to pay for both an electric bill
and for my solar panels. When I signed up, I was given the impression that if there were ever changes to the contract
with ldaho Power, that I would be grandfathered in at the ori8inal contract as an existing customer. lt would be unfair
and unethlcal for ldaho Power to go back on that now. Them paying me less of a credit than what I would be paying
them for electricity is not what I agreed to. Please allow existing customers to keep the original contracts that they
agreed to.
Unique ldentifier: !64.t65.206.42
1
From:
Sent:
to:
Subject:
[e-mail]
Sunday, December 1,2019 4:54 PM
Diane Holt
Case Comment Form: Casey Campbell
Name: Casey Campbell
Case Number: IPC-E-18-15
Email: [e-mail]
Telephone:
Address: 11504 W Peconic Ct, United States
Boise lD, 83709
Name of Utility company: ldaho Power
Comment: Dear Public Utilities Commission, ldaho Powers desire to change the existing net-meterinB program for
homeowners like myself is disappointing. ln visiting ldaho Power's website, it indicates they are awaiting approval by
IPUC to purchase 120MW power generation facility. This seems like a clear indication of the value that solar power
brings to the communities that ldaho Power serves. I purchased a 6.9KW system in August 2018 and paid over S30K to
ensure I can help ldaho Power serve its customers as well as offset my usage. By allowing the change to the net
metering program, it would allow ldaho Power to devalue my contribution to their Going Green by 2045 and making me
pay more for electricity since it's the only game in town. Devaluing the homeowner's investments in green energy is not
a long-term solution of their customers, just their investors.
Please reconsider any change to the existing net meterin8 rules so that homeowners who have made the investment in
green energy are not adversely affected. Allow existing customers to stay on the current net metering program and
apply a new commonsense approach to new customers. I look forward to attending the meeting on December 3rd.
Sincerely,
Casey
Unique ldentifier: L64.L65.?06.42
Diane Holt
1
Diane Holt
F om:
Sent:
To:
Subject:
[e-mail]
Sunday, December 1,2019 5:07 PM
Diane Holt
Case Comment Form: Kevin Brinegar
Name: Kevin Brinegar
Case Number: IPC-E-18-15
Email: [e-mail]
Telephone: [phone]
Address: 3414 W. Lassen St.
Boise lD, 83703
Name of Utility Company: ldaho Power
Comment: I would like to voice my concern over the proposed changes to solar and net metering policies by ldaho
Power. I believe it is imperative that ldaho Power recognizes the value of solar energy as a model for future
development in the state of ldaho and commits to working with communities that embrace it. lnstead of prioritizing
financial gains for the company, to compensate for the decreased customer dependence on the service, ldaho Power
should work to adjust the number of FTE needed to continue operation under a new energy consumption dynamic.
For customers that have already purchased solar because they were told that their monthly bill would be based on a
consistent value/kwat, it is an insult to change the rules to limit this value. Not only will this rule-change affect future
solar purchases, which speaks volumes to ldaho's lack of commitment to solar energy, but it will directly insult those
that were excited to take the lead in moving ldaho in the right direction. By doing so, current solar households will think
that ldaho Power is interested in only one thing...making money. Please do the ri8ht thing and respect customers that
currently have solar, by not changing the current rate structure, and commit to adapting ldaho Power's culture to
enhance and promote future households that recognize solar as an important part of ldaho's future and value.
Unique ldentifier: f64.765.206.42
1
Diane Holt
From:
Sent:
To:
Subject:
[e-mail]
Sunday, December 1, ?019 4:52 PM
Diane Holt
Case Comment Form: Clinton Hoops
Name: Clinton Hoops
Case Number: IPC-E-18-15
Email: hoops59 @ ca bleo ne. net
Telephone: 2Oa8707782
Address: 5914 W. View Dr.
Meridian ldaho, 83642
Name of Utility Company: ldaho Power
Comment: Thank you forthe opportunity to comment on case number IPC-E-18-15.
As noted in item 1 of the motion to approve the settlement aSreement, Case No. IPC-E-17-13, ldaho Power filed an
Application with the Commission requesting the Commission: .... "4) lnitiate a generic docket at the conclusion of IPC-E-
l7-13 to establish a compensation structure for customer-owned distributed energy resources ("DER") that reflects both
the benefits and costs that DER interconnection brings to the electric system." ltem 2 in the motion for approval of the
settlement agreement refers to Order No.34604. ln order 34504 the Commission approved "the Company's request for
a docket to study the costs, benefits, and related issues of net metering on the Company's system and to establish a
compensation structure for DERs. The Commission encouraged the Company and interested stakeholders to work
together to resolve the difficult issues inherent in desi8ning a fair,just, and reasonable net metering program. The
Settlement Agreement attached to this Motion as Attachment I results from the docket ordered by the Commission in
Case No. IPC-E-17-13, and represents the culmination of the thorough, data-driven evaluation undertaken by the
Company, Staff, and numerous stakeholders in a collaborative manner, as directed by the Commission."
As formulated, there are several major issues relating to the fairness of the program under the proposed settlement.
The first relates to the general nature of the proposed program as it relates to existing and future customer generation
facilities. This new proposed program drastically changes from the existing monthly net metering to an hourly net
metering. This means that even though a customer produces an excess of power during the day overall, how that power
is treated varies within the day. The proposed changes matter because my system and most other customer owned
systems are designed to produce power based on peak conditions for generation not based on when our peak
consumption occurs.
ln ldaho Power's motion, PUC order number 34604 is referenced approvinB a study of the costs, benefits, and related
issues of net metering on the Company's system and to establish a compensation structure for DERS. No study has
apparently been performed by ldaho Power as results of the study are not referenced nor are study results available for
review by the PUC, ldaho Power customers or other parties with an interest in net metering. Without the
comprehensive review proposed by ldaho Power a good cost/benefit analysis cannot be performed. This is reflected in
1
The second issue relates to the proposed rates under the settlement and ties back to the first issue. Under the proposed
rates in the settlement agreement a system designed under the existing program has a payback period of approximately
15 years dependent on the discount rate applied. Under the new program after 2028 the same system has a payback
period of over 30 years and may actually never pay back the initial investment when accounting for losses in system
production and maintenance and repairs.
Third, under the new rate structure ldaho Power is allowed to capitalize the customers' investment in generation. ln
paying customers half of what they sell the power for, a system such as mine would generate 10s of thousands of dollars
in income for ldaho Power without ldaho Power investing a cent.
the settlement agreement by a number of locations such as Avoided Capacity and Avoided Line Losses, where the
parties involved could not reach agreement and impacts are to be determined in future rate cases. l'll reference a study
by The Brookings lnstitute which actually states that DER, specifically roof top solar, is beneficial to the utility,
https://www.brookings.edu/research/rooftop-solar-net-metering-is-a-net-benefit/. Until a study has been performed
and reviewed by all parties, evaluating all the costs and benefits of DER, this settlement is premature.
This agreement would also have a significant negative effect on the solar industry in ldaho, potentially causing several
companies to abandon the ldaho market. This again reduces the value of the system as companies may not be available
to repair the system or, if available, may charge more due to the reduced competition.
As noted in the agreement, grandfathering is not addressed. The changes in this program have a significant negative
impact on existing net metering customers. The systems were designed and built based on the existing net metering
rules and customers did not have any reason to build based on other criteria. Systems should be grandfathered, along
with the meter number attached to the residence and not only the account number of the client currently residing
there. An expected increase in home value was a factor in many solar investments. This protects the investment made
by the customer, similar to how ldaho Power is treated.
The PUC has not held hearings regarding the existing net metering for these customers, nor have they been involved in
any of the discussions regarding what a future program should look like.
As written the settlement agreement would take effect January 1, 2020 or on approval of the PUC. This is not an
emergency rule and should only take effect after a reasonable time after approval. Should the agreement take effect,
ldaho Power should not be allowed to delay approval of any pending net metering applications.
This settlement aBreement also ignores many environmental and social impacts customer owned generation brings to
the table such as reliance on coal and natural gas generation (which may in the future have additional benefits for ldaho
Power), reduced reliance on hydro power and its impacts.
ln conclusion, I feel the settlement agreement does not meet the requirements for a fair, just, and reasonable net
metering program as the proposed program and associated rates paid for customer owned generation are unfair and a
study has not been performed to address all the costs and benefits of customer owned generation. The only fair part of
the settlement agreement is when customers owning Beneration are purchasing power, they are treated the same as all
other customers in the rate class.
Unique ldentifier: 764.765.206.42
2
the settlement agreement by a number of locations such as Avoided Capacity and Avoided Line Losses, where the
parties involved could not reach agreement and impacts are to be determined in future rate cases. l'll reference a study
by The Brookings lnstitute which actually states that DER, specifically roof top solar, is beneficial to the utility,
https://www.brookings.edu/research/rooftop-solar-net-metering-is-a-net-benefit/. Until a study has been performed
and reviewed by all parties, evaluating all the costs and benefits of DER, this settlement is premature.
This agreement would also have a significant negative effect on the solar industry in ldaho, potentially causing several
companies to abandon the ldaho market. This again reduces the value ofthe system as companies may not be available
to repair the system or, if available, may charge more due to the reduced competition.
As noted in the agreement, grandfathering is not addressed. The changes in this program have a significant negative
impact on existing net metering customers. The systems were designed and built based on the existin8 net meterin8
rules and customers did not have any reason to build based on other criteria. Systems should be grandfathered, along
with the meter number attached to the residence and not only the account number of the client currently residing
there. An expected increase in home value was a factor in many solar investments. This protects the investment made
by the customer, similar to how ldaho Power is treated.
The PUC has not held hearings regarding the existing net metering for these customers, nor have they been involved in
any of the discussions regardinB what a future program should look like.
As written the settlement agreement would take effect January 1, 2020 or on approval of the PUC. This is not an
emergency rule and should only take effect after a reasonable time after approval. Should the aBreement take effect,
ldaho Power should not be allowed to delay approval of any pending net metering applications.
This settlement agreement also ignores many environmental and social impacts customer owned generation brings to
the table such as reliance on coal and natural gas generation (which may in the future have additional benefits for ldaho
Power), reduced reliance on hydro power and its impacts.
ln conclusion, I feel the settlement agreement does not meet the requirements for a fair, just, and reasonable net
metering program as the proposed program and associated rates paid for customer owned generation are unfair and a
study has not been performed to address all the costs and benefits of customer owned generation. The only fair part of
the settlement agreement is when customers owning generation are purchasing power, they are treated the same as all
other customers in the rate class.
Unique ldentifier: 764.765.206.42
2
Diane Holt
From:
Sent:
To:
Subject:
[e-mail]
Sunday, December '1, 2019 5:15 PM
Diane Holt
Case Comment Form: Charles Blair
Name: Charles Blair
Case Number: IPC-E-18-15
Email: [e-mail]
Telephone: [phone]
Address:4782 5 Spotted Horse Ave
Boise lD, 83716
Name of Utility Company: ldaho Power
Comment: My wife and I have a rooftop solar system on our house. We are therefore quite interested in the proposed
changes to the current net-metering system for ldaho Power customers. Our comments are divided into several
sections for clarity. I begin with a summary of our main points and follow with details and extensive documentation
supporting those main points. Each main point alone is enough reason for the PUC to deny the requested changes.
Together, the arguments against these change cannot be ignored.
Summary of Key Points
Fairnpss
ldahoans have a strong belief that people should be treated fairly and not be penalized retroactively when the rules of
the game change. We respect private investment by individuals, especially when that investment benefits others as well
as benefitting ourselves, which is clearly the case with rooftop solar (as documented below). Existing residential solar
generators must be grandfathered into the current net metering system and not subjected to the proposed unfair
changes.
The Future of Residential Solar Under the Proposed Changes
Residential distributed solar installations in Nevada plummeted by 92% after that state's PUC implemented onerous
changes to their net metering system. The changes proposed here will essentially kill any future expansion of residential
and small commercial PV solar implementation in ldaho.
Proposed Changes Are Not Supported By Facts or Transparent Data
The cost/benefit study ordered by the PUC (Order No. 34046), which was to have provided information needed to
develop a fair and equitable rate and reimbursement structure, has not been conducted. Without real data the
proposed changes amount to nothing more than ldaho Power's assertions and "black box" calculations.
No net metering changes or settlement proposals should take effect until the comprehensive study of the cost and
benefits of on-site generation on ldaho Power's system and other customers, as was ordered by the PUC in Order No.
34046 Case No. IPC-E-17-13, has been completed, analyzed, and those findings evaluated by the public, PUC, and all
parties with net metering interests, as stated in that docket. Numerous studies have shown that the entire argument
that costs are being shifted from those with rooftop solar to other customers has no basis in fact and there is no proof
that it is happening in ldaho. Until we have the facts from the comprehensive study ordered by the PUC, any decision
made at this time would be arbitrary and based on nothing more than ldaho Powe/s unsupported claims.
1
Residential Solar Cost/Benefit Analyses by Other State's PUCs and a DOE National Laboratory
Several other state's PUCS as well as the Lawrence Berkeley National Lab have conducted rigorous cost/benefit analyses
of distributed solar. These studies concluded that the economic benefits of net metering actually outweigh the costs
and impose no significant cost increase for non-solar customers. Farfroma net cost, distributed solarsystemsand net
metering are, in most cases, a net benefit for both the utility and for non-solar rate-payers.
A review of 11 net metering studies found that distributed solar offers net benefits to the entire electric grid through
reduced capital investment costs, avoided energy costs, and reduced environmental compliance costs. Eight of the 11
studies found the value of solar energy to be higher than the average local residential retail electricity rate: The median
value of solar power across all 11 studies was nearly 17 cents per unit, compared to the nation's average retail electricity
rate of about 12 cents per unit.
Greenhouse Gas Emissions Are At Record Levels and Climate Change is Recognized as a Major Threat to National
Security by the U.S. Military
The 2019 annual Emissions Gap Report by the UN Environment Program reported that total green house gas (GHG)
emissions reached a record high of 55.3 Giga tons of CO2 in 2018.
Since January 2017, twenty-one senior officials at the U.S. Defense Department, including former defense secretary
James Mattis, have publicly raised concerns about, and recommended actions to address, the security implications of
climate change, both due to its effect on military infrastructure, readiness and operations, and its broader geostrategic
implications for the United States.
ln spite of these facts and the statements of grave concern about climate change by our top military leaders, IPC and the
PUC are poised to implement these onerous changes, which will put an end to the growth of residential solar in ldaho.
This would increase greenhouse gas emissions in ldaho rather than doing everythinB possible to reduce emissions.
Details and Documentation of Key Points
Fairness
ldahoans have a strong belief that people should be treated fairly and not be penalized retroactively when the rules of
the game change. We respect private investment by individuals, especially when that investment benefits others as well
as benefitting ourselves. Weexpectasystemthatisfairtoall parties involved and we care aboutthe kind of world we
will leave to our children and grand children.
ldaho has a tradition of fostering independent businesses and individual choice. Rooftop solar is a great example of this,
with local companies seeking to help individuals meet their own energy needs with competitive clean options.
My wife and I designed and built our system to primarily meet our own electrical needs as much as possible and we did
so with a reasonable expectation of return on our investment. That fair return will not be possible under the proposed
changes. Under the rules in place when we installed our system we expected a 10 or 11 year breakeven point. With this
proposal that breakeven point is expected to more than double to over 20 years, assuming that further adverse changes
are not implemented in the future.
Our system was sized and designed under the monthly accounting rules in place at the time. Our system would have
been substantially smaller and the design would also have been much different if the proposed net hourly billing
approach had been in place.
Again, changing the rules after the fact is hardly fair.
2
Residential Solar Cost/Benefit Analyses by Other State's PUcs and a DOE National Laboratory
Several other state's PUCs as well as the Lawrence Berkeley National Lab have conducted rigorous cost/benefit analyses
of distributed solar. These studies concluded that the economic benefits of net metering actually outweigh the costs
and impose no significant cost increase for non-solar customers. Far from a net cost, distributed solar systems and net
metering are, in most cases, a net benefit for both the utility and for non-solar rate-payers.
A review of 11 net metering studies found that distributed solar offers net benefits to the entire electric grid through
reduced capital investment costs, avoided energy costs, and reduced environmental compliance costs. Eight of the 11
studies found the value of solar energy to be higher than the average local residential retail electricity rate: The median
value of solar power across all 11 studies was nearly 17 cents per unit, compared to the nation's average retail electricity
rate of about 12 cents per unit.
Greenhouse Gas Emissions Are At Record Levels and Climate Change is Recognized as a Major Threat to National
Security by the U.5. Military
The 2019 annual Emissions Gap Report by the UN Environment Program reported that totalgreen house gas (GHG)
emissions reached a record high of 55.3 Giga tons of CO2 in 2018.
Since January 2017, twenty-one senior officials at the U.S. Defense Department, including former defense secretary
James Mattis, have publicly raised concerns about, and recommended actions to address, the security implications of
climate change, both due to its effect on military infrastructure, readiness and operations, and its broader geostrategic
implications for the United States.
ln spite of these facts and the statements of Brave concern about climate change by our top military leaders, IPC and the
PUC are poised to implement these onerous changes, which will put an end to the growth of residential solar in ldaho.
This would increase greenhouse gas emissions in ldaho rather than doing everything possible to reduce emissions.
Details and Documentation of Key Points
Fairness
ldahoans have a strong belief that people should be treated fairly and not be penalized retroactively when the rules of
the game change. We respect private investment by individuals, especially when that investment benefits others as well
as benefitting ourselves. We expect a system that is fair to all parties involved and we care about the kind of world we
will leave to our children and grand children.
ldaho has a tradition of fostering independent businesses and individual choice. Rooftop solar is a great example of this,
with local companies seeking to help individuals meet their own energy needs with competitive clean options.
My wife and ldesigned and built our system to primarily meet our own electrical needs as much as possible and we did
so with a reasonable expectation of return on our investment. That fair return will not be possible under the proposed
changes. Underthe rulesin place when we installed oursystem we expected a 10 or 11 year breakeven point. Withthis
proposal that breakeven point is expected to more than double to over 20 years, assuming that further adverse changes
are not implemented in the future.
Our system was sized and designed under the monthly accounting rules in place at the time. Our system would have
been substantially smaller and the design would also have been much different if the proposed net hourly billing
approach had been in place.
Again, changing the rules after the fact is hardly fair.
2
Changing to net hourly billing means that IPC would get very cheap wholesale rate power from me when the sun is
shining and will sell power back to me at the retail rate at other times ofthe day. How is this possibly fair?
ldaho Power has solar panels on lts headquarters building and at several other of its facilities. They recognize the many
positive aspects of solar and apparently believe that solar is good for them but not for individuals. That is unfair and we
deserve better treatment from the utility who we have no choice but to work with and from the PUC.
The proposed changes to the pricing structure will kill future residential solar installations in ldaho. Effectively ending
the expansion of residential small solar is totally inconsistent with ldaho Power's clean energy goals as stated on their
own web site, "ldaho Power has set a goalto provide loo-percent clean energy by 2045. ln addition to its hydropower
facilities, which typically meet almost half its customers' energy demands, ldaho Power plans additional investments in
wind, solar and other clean sources" (emphasis added).(https://www.idahopower.com/news/idaho-power-sets-goal-
for-100-percent-clean-energy-by-2045/). Once again ldaho Power recognizes that solar is good for them and will be a
part of their move away from fossil fuels but that distributed solar is not good for individuals. Please tell me how this is
fa ir?
This unfair and unjustified attempt by ldaho Power to eliminate competition from the local solar industry also undercuts
IPC's recent announcement to go 100% clean energy by 2045. To achieve this goal will require a wide variety of clean
energy developments, including distributed ener8y systems where customers spend their own money to meet their own
needs as well as contributing to the overall power grid.
Existing residential solar generators should be grandfathered in to the current net metering rate structure. ln order to
protect our investments, systems should be grandfathered along with the meter number attached to the residence and
not only the account number of the client currently residing there. A calculated, expected increase in home value was a
major factor in our solar investments and we should not be cheated out of the investment we made in our home's value.
We installed our system based on the reimbursement rate in place at the time of installation and changing the rules now
is completely unfair. The first word in Public Utility Commission is PUBLIC. We the public, with residential solar systems,
are trying to do our pa rt to generate clean power and reduce the rate of global warming. We should not be punished
for doing so.
Order No. 34(N6 and Case No. lPc-E17-13 stipulate that this case should include all net-metering interests in a detailed
and transparent cost/benefit study. All net metering interests were not included durang these settlement proceedings. ln
fact, the vast majority of net metering customers, including my wife and me, were not included or apprised of
developments, nor were we represented, during these settlement proceedings.
The PUC should allow existing residential solar customers to remain on the monthly net metering program until the
thorough, transparent cost/benefit analysis ordered by the PUC is completed and available for review by the public.
The Future of Residential Solar Under the Proposed Changes
Case No. IPC-E-17-13 Order No. 34046 stated that "While the number of on-site generation customers on the
Company's system is a relatively small percentage of the Company's total customers, based on the relatively high rate at
which customers are installing systems in ldaho and elsewhere, we believe current and prospective on-site generators
will be better positioned to analyze the costs and benefits of buying, installing, and maintaining an on-site generation
system as a result of this Order."
Net metering makes sure that solar customers like myselt receive fair credit on their utility bills for the valuable, clean
electricity we deliver to the grid. This individual investment in local solar power reduces the need for expensive utility
infrastructure, lowers energy bills and supports local solar installation jobs. As described and fully documented in detail
below, distributed rooftop solar has been shown in many states to provide a net financial benefit to regulated utilities
and all of their customers.
3
This statement fairly indicates that any implemented changes in the current system would provide a baseline against
which people could analyze the future costs and benefits of buying, installing, and maintaining an on-site generation
system as a result of this Order. But what about the people who installed their system under the current rules? The
approximate payback period under the current rules is 10 to 11 years. lf the proposed changes are implemented that
payback period would double to 20 to 22 years or more. lt is doubtfulthat many people who currently have rooftop
solar systems would have chosen to install those systems with a payback period of 20 to 22 or more years.
Case No. IPC-E-17-13 Order No. 34045 further states: "Though the number of net metering customers on ldaho Power's
system is relatively small today - fewer than 1,500 net metering customers in June 2017, out of approximately 535,000
customers - the utility asserted that the increasing affordability of on-site generation would lead to surges in
participation, exacerbating the shifting of costs from net metering customers to standard customers, and eventually
killing the net metering program unless it is overhauled."
"The Commission agreed, saying "this inequity will only increase as more customers choose on-site generation" and that
the outcome of this case will allow potential on-site generators access to reliable information on which to make a
decision about whether to install on-site generation."
Proposed Changes Are Not Supported By Facts or Transparent Data
The cost/benefit study ordered by the PUC (Order No. 34046), which was to have provided this information, has not
been conducted. Without real data or the "reliable information", as specified in the Order, the proposed changes
amount to nothing more than ldaho Power's statements and "black box" calculations.
Net metering changes, or settlement proposals should NOT take effect until the comprehensive study of the cost and
benefits of on-site distributed solar generation on ldaho Power's system, as was ordered by the PUC in Order No. 34045
Case No. IPC-E-I7 -L3, has been completed, analyzed, and those findings evaluated by the public, PUC, and all parties
with net metering interests, as stated in that docket. The basis of ldaho Powe/s proposed changes is that distributed
power generators are not paying their fair share and that costs are being unfairly shifted to other rate payers. As
thoroughly documented below, this premise has no basis in fact and there is no proof of it. The cost/benefit study
ordered by the PUC (Order No. 34046), which was to have provided information necessary to make truly fair changes to
the existing net metering system has not been conducted. Until we have all of the facts from the comprehensive
cost/benefit study ordered by the PUC, any decision made at this time would be arbitrary.
l've monitored the output from my system and have observed that the peak output occurs during the summer and that
the daily peak occurs between about 12 pm and 5 pm. ldaho Power's web site
(https://www.idahopower.com/news/idaho-power-sets-new-peak-demand-record/) indicates that IPC recorded a new
all-time peak demand on Friday, July7,2Ol7. On that day, total demand reached 3,422 megawatts (MW) between 4
4
There is neither "reliable information" nor any proof that an inequity exists between rooftop solar customers and other
IPC customers because the cosvbenefit study ordered by the Commission has not been conducted. Furthermore, it is
highly unlikely that there would be much additional rooftop solar capacity installed if the proposed changes are
implemented. Here's one example of why future rooftop solar will die in ldaho under the proposed changes.
ln a number of states utility interests have sought to persuade state regulators to roll back net-metering provisions,
arguing they are a net cost to the overall electricity system. The local utility in Nevada, NV Energy, successfully wielded
a cost-shift theory (not unlike ldaho Power's argument) during the the last quarter of 2015 to get the Nevada Public
Utilities Commission to drastically curtail the state's net-metering payments
(http://pucwebl.state.nv.us/PDF/Axlmages/DOCKETS_2015_THRU_PRESENT/2015-7/8305.pdf). The changes in Nevada
resulted in a 92 percent decline in new residential solar installation permits in the first quarter of 2016 compared to Q4
2015, falling from 33 MW to 3 MW (Brookings lnstitute 2015 (https://www.brookings.edu/research/rooftop-solar-net-
metering-is-a-net-benefit/)). As a result the state's three largest providers of rooftop panels (Solar Clty, Sunrun, and
Vivint Solar) have left the Nevada market entirely. This is what we can expect to happen in ldaho as well if the proposed
changes are implemented.
This statement fairly indicates that any implemented changes in the current system would provide a baseline against
which people could analyze the future costs and benefits of buyinB, installing, and maintaining an on-site generation
system as a result of this Order. But what about the people who installed their system under the current rules? The
approximate payback period under the current rules is 10 to 11 years. lf the proposed changes are implemented that
payback period would double to 20 to 22 years or more. lt is doubtful that many people who currently have rooftop
solar systems would have chosen to install those systems with a payback period of 20 to 22,or more years.
Case No. IPC-E-17-13 Order No. 34046 further states: 'Though the number of net metering customers on ldaho Power's
system is relatively small today - fewer than 1,500 net metering customers in June 2017, out of approximately 535,000
customers - the utility asserted that the increasing affordability of on-site generation would lead to surges in
participation, exacerbating the shifting of costs from net metering customers to standard customers, and eventually
killing the net metering program unless it is overhauled."
"The Commission agreed, saying "this inequity will only increase as more customers choose on-site generation" and that
the outcome of this case will allow potential on-site generators access to reliable information on which to make a
decision about whether to install on-site generation."
There is neither "reliable information" nor any proof that an inequity exists between rooftop solar customers and other
lPc customers because the cost/benefit study ordered by the Commission has not been conducted. Furthermore, it is
highly unlikely that there would be much additional rooftop solar capacity installed if the proposed changes are
implemented. Here's one example of why future rooftop solar will die in ldaho under the proposed changes.
ln a number of states utility interests have sought to persuade state regulators to roll back net-metering provisions,
arguing they are a net cost to the overall electricity system. The local utility in Nevada, NV Energy, successfully wielded
a cost-shift theory (not unlike ldaho Powe/s argument) during the the last quarter of 2015 to get the Nevada Public
Utilities Commission to drastically curtail the state's net-metering payments
(http://pucwebl.state.nv.us/PDF/Axlmages/DocKETS_2015_THRU_PRESENT/2015-7/8305.pdf). The changes in Nevada
resulted in a 92 percent decline in new residential solar installation permits in the first quarter of 2015 compared to Q4
2015, falling from 33 MW to 3 MW (Brookings lnstitute 2015 (https://www.brookings.edu/research/rooftop-solar-net-
metering-is-a-net-benefit/)). As a result the state's three lar8est providers of rooftop panels (Solar City, Sunrun, and
Vivint Solar) have left the Nevada market entirely. This is what we can expect to happen in ldaho as well if the proposed
chanSes are implemented.
Proposed Changes Are Not Supported By Facts or Transparent Data
The cost/benefit study ordered by the PUC (Order No. 34045), which was to have provided this information, has not
been conducted. Without real data or the "reliable information", as specified in the Order, the proposed changes
amount to nothing more than ldaho Power's statements and "black box" calculations.
Net metering changes, or settlement proposals should NOT take effect until the comprehensive study of the cost and
benefits of on-site distributed solar generation on ldaho Power's system, as was ordered by the PUC in Order No. 34046
Case No. IPC-E-u-13, has been completed, analyzed, and those findings evaluated by the public, PUC, and all parties
with net metering interests, as stated in that docket. The basis of ldaho Powe/s proposed changes is that distributed
power generators are not paying their fair share and that costs are being unfairly shifted to other rate payers. As
thoroughly documented below, this premise has no basis in fact and there is no proofof it. The cost/benefit study
ordered by the PUC (Order No. 34045), which was to have provided information necessary to make truly fair changes to
the existing net metering system has not been conducted. Until we have all of the facts from the comprehensive
cost/benefit study ordered by the PUC, any decision made at this time would be arbitrary.
l've monitored the output from my system and have observed that the peak output occurs during the summer and that
the daily peak occurs between about 12 pm and 5 pm. ldaho Power's web site
(https://www.idahopower.com/news/idaho-power-sets-new-peak-demand-record/) indicates that IPC recorded a new
all-time peak demand on Friday, .luly 7,2077. On that day, total demand reached 3,422 megawatts (MW) between 4
4
p.m. and 5 p.m. lt appears that my peak generation, both seasonally and daily, roughly corresponds to peak demand
periods on lPC. While I recognize that residential solar is a very minor contributor to IPC'5 total generation, small
generators like myself help to meet peak demand, thereby reducing the need to purchase power on the open market or
build more expensive generating capacity, both of which save money for all IPC customers. These factors must be fully
considered and evaluated in an open and transparent process, as outlined in Order No. 34045, before the PUC makes
any changes to the current net metering system.
The study specified in Order No. 34046 has not been undertaken. How can the PUC possibly set new terms and rates
without the results ofthis study? l, andthe rest ofthe interested public, expected to see these study results so that any
structural or rate changes would be based on facts, and not just on IPC's preferences. The PUC is not doing it's job when
it allows a utility to dictate it's own terms without any real data.
Residential Solar Cost/Benefit Analyses by Other State's PUCs
Detailed cost/benefit studies such as the one ordered by the PUC, have been conducted by the Public Utilities
Commissions in several other states.
The Brookings lnstitute*, a highly respected, non-partisan research group founded in 1916, conducts research many
areas related to economics and economic development. ln 2015 and 2016 they undertook a study to answer the
following questions that are at the center ofthis issue in ldaho. Those questions included: Does net metering really
represent a net cost shift from solar-ownlng households to others? Or does it in fact contribute net benefits to the grid,
utilities, and other ratepayer groups when all costs and benefits are factored in?
So what does the accumulating national literature on costs and benefits of net metering say? lncreasingly it concludes-
whether conducted by PUCs, national labs, or academics - that the economic benefits of net metering actually
outweigh the costs and impose no significant cost increase for non-solar customers. Far from a net cost, net metering is
in most cases a net benefit-for the utility and for non-solar rate-payers.
The following paragraphs in quotes, describinB the results of these PUC-conducted studies, are taken directly from the
Brookings lnstitute (2015) study (https://www.brookings.edu/research/rooftop-solar-net-metering-is-a-net-benefit/).
"...by the end of 2015, regulators in at least 10 states had conducted studies to develop methodologies to value
distributed generation and net metering, while other states conducted less formal inquiries, ranging from direct rate
design or net-metering policy changes to general education of decisionmakers and the public
(https://nccleantech.ncsu.edu/wp-content/uploads/50sosQ4-FlNAL.pdf). And there is a degree of consensus. What do
the commission-sponsored analyses show? A growing number show that net metering benefits all utility
customers...""ln 2013 Vermont's Public Service Department conducted a study that concluded that "net-metered
systems do not impose a significant net cost to ratepayers who are not net-metering participants." "The legislatively
mandated analysis deemed the policy a successful component of the state's overall energy strategy that is cost
effectively advancing Vermont's renewable energy goals."
(http://www.leg.state.vt.us/reports/20l3ExternalReports/285580.pdf)
"A 2014 study commissioned by the Mississippi Public Services Commission concluded that the benefits of
implementing net metering for solar PV in Mississippi outweigh the costs in all but one scenario. The study found that
distributed solar can help avoid significant infrastructure investments, take pressure off the state's oil and gas
generation at peak demand times, and lower rates. " (https://www.synapse-
energy.com/sites/defaulVfi les/Net%20Metering%20in%20Mississippi.pdf)
"ln 2014 Minnesota's Public Utility Commission approved a first-ever statewide "value of solar'' methodology which
affirmed that distributed solar generation is worth more than its retail price and concluded that net metering
undervalues rooftop solar. The "value of solar" methodology is designed to capture the societal value of PV-generated
electricity. The PUC found that the value of solar was at 14.5 cents per kilowatt hour (kwh)-which was 3 to 3.5 cents
more per kilowatt than Xcel's retail rates-when other metrics such as the social cost of carbon, the avoided
5
construction of new power stations, and the displacement of more expensive power sources were factored in."
(https://ilsr.orglwp-content/upload s/2014/U/MN-Value-of-Solar-from-lLSR.pdf)
"Another study commissioned by the Maine Public Utility Commission in 2015 put a value of $0.33 per kWh on energy
generated by distributed solar, compared to the average retail price of 50.13 per kWh - the rate at which electricity is
sold to residentaal customers as well as the rate at which distributed solar is compensated. The study concludes that
solar power provides a substantial public benefit because it reduces electricity prices due to the displacement of more
expensive power sources, reduces air and climate pollution, reduces costs for the electric grid system, reduces the need
to build more power plants to meet peak demand, stabilizes prices, and promotes energy security. These avoided costs
represent a net benefit for non-solar ratepayers. (https://www.nrcm.orglwp-
content/uploads/2015/03/M PUCValueofsolarReport.pdf)
These positive PUC conclusions about the benefits of net metering have been supported by research conducted by a
national lab and several think tanks. lmportant lab research has examined how substantially higher adoption of
distributed resources might look.
The Lawrence Berkeley National Lab, funded by the U.S. Department of Energy, is a world center for basic and applied
research. Their stated mission is to "bring science solutions to the world. We are leaders in energy conservation. We
find ways to save energy though design: better materials, greener buildings, and smarter power distribution."
"ln a forward-looking analysis of the financial impacts of net-metered energy on utilities and ratepayers, the Lawrence
Berkeley National Lab found that while high use of net-metered solar generation may decrease utility shareholders'
earnings, it will have a "relatively modest" impact on ratepayers. The report examined solar penetration levels that are
"substantially higher than [those thatl exist today" - 10 percent compared to today's 0.2 percent - and concluded that
"even at penetration levels significantly higher than today, the impacts of customer-sited PV on average retail rates may
be relatively modest." The report further said that utilities and regulators "may have sufficient time to address concerns
about the rate impacts of PV in a measured and deliberate manne/'
(hnps://emp.lbl.gov/sites/all/files/LBNL%20PV%20Business%20Models7o20Report_no%20report%20number%2O%285e
pt%ol0Z5%o2Orevision%29.pdfhttps:/emp.lbl.govlsites/all/files/LBNL%20PV%20Business%20Models%20Report_no%20re
port%20number%20%28Sept%2025%20revision%29.pdf ).
"Similarly, a growing number of academic and think tank studies have found that solar energy is being undervalued and
that it delivers benefits far beyond what solar customers are receivinB in net-meterinB credits:"
"For instance, a review of 11 net metering studies by Environment America Research and Policy Center found that
distributed solar offers net benefits to the entire electric grid through reduced capital investment costs, avoided energy
costs, and reduced environmental compliance costs. Eight of the 11 studies found the value of solar energy to be higher
than the average local residential retail electricity rate: The median value of solar power across all 11 studies was nearly
17 cents per unit, compared to the nation's average retail electricity rate of about 12 cents per unit."
(https://environmentamerica.org/sites/environment/files/reports/EA_shiningrewards_print.pdf).
"Likewise, a study by the Acadia Center found the value of solar to exceed 22 cents per kwh of value for Massachusetts
ratepayers through reduced energy and infrastructure costs, lower fuel prices, and lowering the cost of compliance with
the Commonwealth's greenhouse gas requirements. This value was estimated to exceed the retail rate provided through
net metering." (https://acadiacenter.org/document/value-of-solar-massachusetts/)
ln short, while the specific conclusions vary, a significant body of cost-benefit research conducted by PUCS, a DOE
National Lab, consultants, and research organizations provides substantial evidence that net metering is more often
than not a net benefit to the utility and to all ratepayers.
Under case No. IPC-E-17-13 Order No. 34045 the ldaho PUC, on May 9, 2018, "directed ldaho Power to initiate a
comprehensive study of the costs and benefits of net metering on ldaho Power's system. The Commission encouraged
6
"Another study commissioned by the Maine Public Utility Commission in 2015 put a value of 50.33 per kwh on energy
generated by distributed solar, compared to the average retail price of 50.13 per kwh - the rate at which electricity is
sold to residential customers as well as the rate at which distributed solar is compensated.,The study concludes that
solar power provides a substantial public benefit because it reduces electricity prices due to the displacement of more
expensive power sources, reduces air and climate pollution, reduces costs for the electric grid system, reduces the need
to build more power plants to meet peak demand, stabilizes prices, and promotes energy security. These avoided costs
represent a net benefit for non-solar ratepayers. (https://www.nrcm.orglwp-
content/u ploads/2015 / 03 / MP UOI alueofsolarReport.pdf)
These positive PUC conclusions about the benefits of net metering have been supported by research conducted by a
national lab and several think tanks. lmportant lab research has examined how substantially higher adoption of
distributed resources might look.
The Lawrence Berkeley National Lab, funded by the U.S. Department of Energy, is a world center for basic and applied
research. Their stated mission is to "bring science solutions to the world. We are leaders in energy conservation. We
find ways to save energy though design: better materials, greener buildings, and smarter power distribution."
"ln a forward-looking analysis of the financial impacts of net-metered energy on utilities and ratepayers, the Lawrence
Berkeley National Lab found that while hi8h use of net-metered solar generation may decrease utility shareholders'
earningt it will have a "relatively modest" impact on ratepayers. The report examined solar penetration levels that are
"substantially higher than [those that] exist today' - 10 percent compared to today's 0.2 percent - and concluded that
"even at penetration levels significantly higher than today, the impacts of customer-sited PV on avera8e retail rates may
be relatively modest." The report further said that utilities and regulators "may have sufficient time to address concerns
about the rate lmpacts of PV in a measured and deliberate manne/'
(https://emp.lbl.govlsites/all/files/LBNL%20PV%20Business%20Models/o?OReport_noYo20report%20number%21yo28se
pt%2025%20revision%29.pdfhttps:/emp.lbl.gov/sites/all/files/LBNL%20PV%20Business%20Models%20Reporl_noyoaore
po rt%20number% 2}yo2Ssepl%2025%20revision%29.pdf ).
"Similarly, a growing number of academic and think tank studies have found that solar enerBy is being undervalued and
that it delivers benefits far beyond what solar customers are receiving in net-metering credits;"
"For instance, a review of 11 net metering studies by Environment America Research and Policy Center found that
distributed solar offers net benefits to the entire electric Brid through reduced capital investment costs, avoided energy
costs, and reduced environmental compliance costs. Eight of the 11 studies found the value of solar energy to be higher
than the average local residential retail electricity rate: The median value of solar power across all 11 studies was nearly
17 cents per unit, compared to the natlon's average retail electricity rate of about 12 cents per unit."
(https://environmentamerica.org,/sites/environment/files/reports/EA_shiningrewards_print.pdf).
"Likewise, a study by the Acadia Center found the value of solar to exceed 22 cents per kwh of value for Massachusetts
ratepayers through reduced energy and infrastructure costs, lower fuel prices, and lowering the cost of compliance with
the Commonwealth's greenhouse gas requirements. This value was estimated to exceed the retail rate provided through
net metering." (https://acadiacenter.org/document/value-of-solar-massachusetts/)
ln short, while the specific conclusions vary, a significant body of cost-benefit research conducted by PUCS, a DOE
National Lab, consultants, and research organizations provides substantial evidence that net metering is more often
than not a net benefit to the utility and to all ratepayers.
Under Case No. IPC-E-17-13 Order No. 34045 the ldaho PUC, on May 9, 2018, "directed ldaho Power to initiate a
comprehensive study of the costs and benefits of net metering on ldaho Powe/s system. The Commission encouraged
6
construction of new power stations, and the displacement of more expensive power sources were factored in."
(https://ilsr.orglwp-content/upload sl2074/0/.IMN-value-of-Solar-from-lLSR.pdf)
the utility to collaborate with Commission staff and other stakeholders in conducting the study and determining proper
rates, rate design, and compensation for excess generation for its net-metering customers. The Commission's order
does not limit the scope of the study, intending to encourage creativity among the stakeholders and company in
developing a successful net metering program.
That study has not been undertaken. How can the PUC possibly set new net-metering terms and rates without the
resu lts of this study? l, and the restofthe interested public, expected to seethese study results so that any structural or
rate changes would be based on facts, and notjust on IPC'S preferences and unsupported statements. The PUC is not
doing it's job when it allows a utility to dictate it's own terms without any real data.
Greenhouse Gas Emissions Are At Record Levels and Climate Change is Recognized as a Threat to National Security by
the U.S. Military
The 2019 annual Emissions Gap Report by the UN Environment ProSram reported that total green house gas (GHG)
emissions reached a record high of Giga tons of CO2 in 2018. The report further stated "There is no sign of GHG
emissions peaking in the next few years; every year of postponed peaking means that deeper and faster cuts will be
required to limiting global warming to below 2'C" (https://www.unenvironment.orglresources/emissions-gap-report-
201s).
Since January 2017, twenty-one very senior officials at the U.5. Defense Department, including former Secretary of
Defense James Mattis, have publicly raised concerns about, and recommended actions to address, the security
implications of climate change, both due to its effect on military infrastructure, readiness and operations, and its
broader geostrategic implications for the United States (https://climateandsecurity. ore/a0Lg/O2/t6/ update-chronology-
of-u-s-military-statements-and-actions-on-climate-change-and-security -?Ol7 -2Ot9ll.
ln spite of these facts and the statements of Brave concern about climate change by our top military leaders, IPC and the
PUC appear poised to implement these onerous changes, which will put an end to the growth of residential solar in
ldaho. This would likely increase greenhouse gas emissions in ldaho rather than doinB everythinS possible to reduce
emissions.
Footnotes
*The Brookings lnstitute's stated mission is to "provide innovative and practical recommendations that advance three
broad goals: strengthen American democracy; foster the economic and social welfare, security and opportunity of all
Americans; and secure a more open, safe, prosperous, and cooperative international system."
Brookings states that its staff "represent diverse points of view" and describes itself as non-partisan. Various media
outlets have alternately described Brookings as conservative (Glaberson 2008), centrist (DeParle 2005), or liberal
(Kurtzleben 2011). An academic analysis of Congressional records from 1993 to 2002 found that Brookings was referred
to by conservative politicians almost as frequently as liberal politicians, earning a score of 53 on a 1-100 scale with 100
representing the most liberal score (Groseclose and Milyo 2005). The same study found Brookings to be the most
frequently cited think tank by the U.S. media and politicians.
Additional References
Glaberson, William (November 16, 2008). "Closing Guantdnamo may not be easy". The New York Times.
DeParle, Jason (June 14, 2005). "Next Generation of Conservatives (By the Dormful)1". The New York Times.
Kurtzleben, Danielle (March 3, 2011). "Think Tank Employees Tend to Support Democrats". U.S. News & World Report
Retrieved February 14, 2016.
Groseclose, Tim and Jeffery Milyo (2005). "AMeasureof Media Bias". Pages l79L - L237 in: The Quarterly Journal of
Economics, Vol 4, 2005.
7
Diane Holt
From:
Sent:
To:
Subjea:
jody.brostrom@gmail,com
Sunday, December 1,2019 6:29 PM
Diane Holt
Case Comment Form: Jody Brostrom
Name: Jody Brostrom
Case Number: IPC-E-18-15
Email: [e-mail]
Telephone:
Address:
Salmon ldaho, 83467
Name of Utility Company: ldaho Power Company
Comment: I am opposed to ldaho Power's proposed change in net metering. I installed rooftop solar on my home in
Salmon, ldaho in 2014. At that time I entered into an agreement with ldaho Power that any energy I produced in excess
of what I used would be credited to my account to be used at another time of the year. ldaho Power, and the ldaho
Public Utilities Commission, should honor and uphold the original program that was agreed upon by ldaho Power and
existing solar customers. I and others shouldn't have the rules changed after our investment in clean energy has been
made, nor be subject to increases in their power bills. lf ldaho Power feels that changes need to be made, then it should
only be applicable to new customers, although this also penalized people interested in investing in clean power. Utilities
and states around the country recognize that maintaining existing utility rates and terms for existing customers is ethical
and reasonable. The same should be true for ldahoans. The PUC promised that discriminatory rates would not be the
outcome. lf changes are implemented that negatively impact customers' solar investments, it would be discriminatory. I
expect the PUC to stand behind this promise. Support ldahoans who are investing in clean, renewable ener8y for the
long term. Do not approve the changes in net metering for existing ldaho Power solar producing customers.
Unique ldentifi er: 164.L65.206.42
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Diane Holt
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Sunday, December 1,2019 6:49 PM
Diane Holt
Case Comment Form: Rick Pearson
Name: Rick Pearson
Case Number: lpc-e-18-15
Email: [e-mail]
Telephone:
Address: U05e 4000n
Buhl ld, 83316
Name of Utility Company: ldaho Power
Comment: I think ldaho Power's decision to cut rates after we have invested in a small solar system is completely unfair.
They encourage green power we listened and helped, now they want to change the rules. They spend millions of dollars
telling us how great they are, as if we have a choice since they are our only choice. lf they want happy customers they
must treat us fair. Please don't allow ldaho Power to kill the green energy movement. Thank you.
Unique ldentifi er: 164.765.206.42
L
Diane Holt
From:
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Sunday, December 1, 2019 7:11 PM
Diane Holt
Case Comment Form: David Tiffany
Name: David Tiffany
Case Number: IPC-E-18-15
Email: [e-mail]
Telephone: [phone]
Address: 9500 Cherry Lane
Nampa lD, 83687
Name of Utility Company: iDAHO POWER
Comment: I do not agree with ldaho Power's suggested rate decrease for solar power generators.
l.Generators provide power during the summer when ldaho power charges a higher rate to customers.
During the winter months when we need power back we are actually using power that is at a cheaper rate. They are
ahead right there.
2. ldaho Power vigorously advertases it is trying to help ldahoans to be more energy efficient and protect the
environment. Yet lt is essentially going to kill solar production. Just the opposite of what it claims it wants for ldaho. lf
ldaho Power talks the talk, then they should walk the walkl
3, lf ldaho Power has to purchase power from another power company it does not dictate what the cost will be. lt is
what it is.
4. As solar energy producers we are not tryin8 to make money, we are trying to reduce our costs and help the
environment and help ease the dependence of ldaho from having to purchase power produced by outside the state and
possibly from a source that is not as environmentally friendly.
5. I personally put in a solar system this year.l am 65 years old. At the current rate it will be 15 years before I save
enough in power costs savings to pay for the system. I will probably never live to see it paid for if ldaho power has its
way. Why would anyone commit the money for solar? I could of kept my 29k in a fund and made 5% a year. But I am
hoping for a clean ldaho for my children/grandchildren and generations in the future.
The system I put in will at most provide 85% of my annual power consumption. Guess what I still have to purchase 15%
more power to meet what I annually use.
I am sure other solar power generators to not produce 100% of what they use. So they also still will have to purchase
ldaho Power electricity.
ldaho Power is making money off us.
I personally would rather see a slight increase in rates for all consumers if they feel they need more money.
I understand solar producers provide 3.52% of the states Power. Why should we be expected to lose our money and
investment when all we are doing is trying to help the state and at best break even?
Yours Truly
David Tiffany
Solar Power producer
Nampa, ldaho
Unique ldentifier: 164.L65.206.42
I
Diane Holt
From:
S€nt:
To:
Subject:
[e-mail]
Sunday, December 1,2019 7:47 PM
Diane Holt
Case Comment Form: Paul Schlobohm
Name: Paul Schlobohm
Case Number: IPC-E-18-15
Email: [e-mail]
Telephone:
Address: 2357 E Parkside Drive
Boise ldaho,83712
Name of Utility Company: ldaho Power
Comment: As a homeowner with a recently installed solar system on my roof, I have grave concerns about the proposed
changes to net metering.
No settlement should have taken place behind closed doors without the direct input of existing net metering customers.
. Systems were purchased and engineered based on existing net metering policies that track production and usage
on a monthly basis.
. There were no other existing net metering models for the design of PV systems, or other types of on-site
generation, at the time of this investment.
. The adoption of hourly net metering as proposed by the settlement would completely alter how existing systems
would have otherwise been designed. This dramatically alters how these investments othemrise would have been made.
. ln order to protect these investments, systems should be grandfathered along with the meter number attached to
the residence and not only the account number of the client currently residing there. A calculated, expected increase in
home value was a maror factor in many solar investments.
. Any implemented changes that may happen should become effective 30 days from the PUC'S decision and should
not take place retroactively. This is a standard practice for most policy changes.
Unique ldentifier: L64.165.206.42
1
Diane Holt
jaredscowS0@ gmail.com
Sunday, December 1, 2019 8:07 PM
Diane Holt
Case Comment Form: Jared Scow
Name: Jared Scow
Case Number: IPC-E-18-15
Email: [e-mail]
Telephone: [phone]t
Address: 11706 N Nelson Lane
Pocatello ldaho, 83202
Name of Utility Company: ldaho Power
Comment: lam writing this to express my concern with the actions that may potentially be taken by ldaho Power. As an
ldaho Power customer, who has invested in producing clean power, feel that it is improper for ldaho Power to change
their agreement with those who have invested in solar power. ldaho Power should not be allowed to raise solar
customer rates. ldaho Power should at minimum allow the net metering customers to be grandfathered in with the
existing agreement. We installed our system under the current agreement, basinB our return on that agreement.
Changing the agreement would cause us a major financial burden. The commission promised that there would not be
discriminatory rates that negatively impact the customers, yet this change that ldaho Power is proposing would do just
that. This change would crush the solar industry in ldaho, making it difficult, if not impossible,for customers to go green
or even desire to go green. I spent a considerable amount of money and time investing in a solar power system, and I
would hope that the commission will take into account my concern and others like mine.
Sincerely,
Jared Scow
Unique ldentifier: 764.765.206.42
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Diane Holt
From:
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Subjea:
[e-mail]
Sunday, December 1,2019 8:15 PM
Diane Holt
Case Comment Form: Gayle Buhrer-Poorman
Name: Gayle Buhrer-Poorman
Case Number: IPC-E-18-15
Email: [e-mail]
Telephone:
Address: 5230 N Black Cat Rd
Meridian lO, 83545
Name of Utility Company: ldaho Power
Comment: Dear Commissioners:
I would like to ask that you deny ldaho Power Company's request to change the residential solar reimbursement rate
from 1:1 to V2:1 over the next five years. This change would, in my view, discourage development of solar installations
that make use of one of ldaho's most abundant and free natural resources: sunshine! ldaho Power has pledged to move
to 100% renewable resources to generate electricity by the year 2045. To meet this goal, it would seem to me that the
use of rooftop solar would be of great benefit to the company. Rooftop solar does not require additional land, more
miles of expensive transmission lines, and does not wipe out migratory wild fish runs like the hydro power dams do.
With the rapid building of new homes in the ever expanding new subdivisions across the Treasure Valley, the time is ripe
for such rooftop solar adaptations. But the proposed rate change would only provide disincentives to homeowners to
install solar panels on their rooftops.
Climate change is upon us, and many companies across our country, and all over the world, are realizinB the advantages
of the inexpensive and ever-evolving efficiencies of photovoltaic solar power. lt seems like an opportunity ldaho Power
should embrace and encourage of its customers, rather than discourage through rate changes that disincentivize rooftop
solar.
Thank you for listening to my concerns,
Gayle B. Poorman
Unique ldentifi er: 764.165.206.42
1
Diane Holt
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Sunday, December 1,2019 8:15 PM
Diane Holt
Case Comment Form: Greg Grotsky
Name: Greg Grotsky
Case Number: IPC-E-18-15
Email: [e-mail]
Telephone: [phone]
Address: 7582 W. Thunder Mountain Dr.
Boise ldaho, 83709
Name of Utility Company: ldaho Power
Comment: Hello PUC,
I recently received a letter from ldaho Power regarding changes to the net metering cost structure
(https://puc.idaho.Bovlfileroom/cases/summary/lPCE1815.html : IPC-E-18-15). lam shocked and dismayed by these
measures. We purchased our solar array in June of 2019. Of course, a large factor in our purchase analysis was the
ability to spread the upfront cost over the next 15-20 years with reasonable power rates over that period of time. This
restructurin8 measure is well beyond an acceptable "adjustment" and forces my family to essentially eat the cost of the
installation and equipment which was not something I had planned to do. lf I had known this change was coming I would
not have opted into the program. At this point, I have no choice-the array is purchased and installed. To anyone in my
position, this feels very much like bait and switch, with no one supporting or representing those customers who made
the solar switch in good faith. The PUC should uphold the original program that was agreed upon by ldaho Power and
solar customers.
Rather than this hyper-active price gouge, it seems much more fair to offer a grandfather clause for early adopters, who
should be allowed to keep their existing rates, while new adopters are introduced to the new plan. Allowing existing
solar customers to stay on the existing net metering program and applying the new program to new customers is a
common sense compromise that allows all parties to keep agreements that were made in good faith. Early adopters
should not be penalized for investing in a program that was created to incentivize purchasing renewable energy
generation. This bait and switch tactic is a terrible game to play with customers in the valley.
To approve a net metering policy which encourages investment for long term savings and to then completely invalidate
it in this manner is unethical.
Thank you for your time,
-Greg
Unique ldentifier: L64.765.206.42
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Diane Holt
From:
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To:
Subject:
nu llgee@g mail.com
Sunday, December 1,2019 8:20 PM
Diane Holt
Case Comment Form: Rachael Grotsky
Name: Rachael Grotsky
Case Number: Case Number IPC-E-18-15
Email: [e-mail]
Telephone: 2O89L77999
Address: 7682 W. THUNOER MOUNTAIN DRIVE
BOrSE tD, 83709
Name of Utility Company: ldaho Power
Comment: Hello PUC,
We recently received a letter from ldaho Power regarding changes to the net metering cost structure
(https://puc.idaho.govlfileroom/cases/summary/lPCE1815.html : IPC-E-18-15). We are shocked and dismayed by these
measures. We purchased our solar array in June of 2019. Of course, a large factor in our purchase analysis was the
abllity to spread the upfront cost over the next 15-20 years with reasonable power rates over that period of time. This
restructuring measure is well beyond an acceptable "adjustment" and forces our family to essentially eat the cost of the
installation and equipment which was not something we had planned to do. lf we had known this change was coming
we would not have opted into the program. At this point, we have no choice-the array is purchased and installed. To
anyone in our position, this feels very much like bait and switch, with no one supporting or representing those
customers who made the solar commitment in good faith. The PUC should uphold the original program that was agreed
upon by ldaho Power and solar customers.
Rather than this hyper-active price gouge, it seems much more fair to offer a grandfather clause for early adopters, who
should be allowed to keep their existing rates, while new adopters are introduced to the new plan. Allowing existing
solar customers to stay on the existing net meterin8 program and applying the new proBram to new customers is a
common sense compromise that allows all parties to keep agreements that were made in good faith. Early adopters
should not be penalized for investing in a pro8ram that was created to incentivize purchasing renewable energy. This
bait and switch tactic is a terrible game to play with customers in the valley.
To approve a net metering policy which encourages investment for long term savings and to then completely invalidate
it in this manner is unethical.
Please let us know if there is anything more we can do as customers of ldaho Power to keep our existing (and agreed
upon) net metering structure in place.
Unique ldentifier: 764.765.206.42
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Subject:
[e-mail]
Sunday, December 1,2019 8:41 PM
Diane Holt
Case Comment Form: Linda Engle
Name: Linda Engle
Case Number: IPC-E-18-15
Email: [e-mail]
Telephone: [phone]
Address: 340 S. 11th Ave
Pocatello lD, 83201
Name of Utility Company: ldaho Power
Comment:1) ldahoPower(lPC) wassupposed to do a studyon thevalue of net-metering before changing rates. Where
is that study?
2) How does lowering the price IPC pays for home generated electricity help IPC move toward 100% renewable?
3) This rate change suppresses a potentialjobs increase and economic boom that other states have experienced with
residential solar power.
4) lt's clear IDP does not want solar, but the public wants it. Last summer, with Solarize Pocatello, we saw over 375
people in 5E ldaho were interested. Close to 90 homeowners put solar panels on their property through that program.
We are talking multi-millions of dollars.
5) How can IPC possibly know the value of solar in eight years? They don't even know what their own prices will be in
eight years. What is the process they are usang to value solar energy? (see question #1)
5) Keep in mind what is happening in neighboring states: On November 19 the Wyoming Tribune Eagle reported that
two Wyoming net-metering bills were rejected. The bills would have effectively killed the solar industry in Wyomin8.
https://www.wyomi ngnews.com/.../article_7f4cc8a4-de90.
On November 25, the Montana Public Service Commission voted 5-to-0 against a proposal to add a charge onto new
rooft op solar. https://tinyurl.com/s2epazl
Thank-you for your time.
Please do not approve this rate change.
U niq ue ldentifi er: 164.765.206.42
1
Diane Holt
Diane Holt
From:
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Sunday, December 1,2019 8:53 PM
Diane Holt
Case Comment Form: .James Van Dinter
Name: James Van Dinter
Case Number: IPC-E-18-15
Email: [e-mail]
Telephone: ?082978288
Address: 12088 W Tidewater Dr
Boise lD, 83713
Name of Utility company: ldaho Power Company
Comment: The PUC should uphold the original program that was agreed upon by ldaho Power and solar customers.
ldahoans have invested in local clean energy expecting a fair deal. The over 5,000 solar customers have invested over 75
million dollars (S15,000 per customer). ldaho families and small businesses shouldn't have the rules changed on them
after they have already made their investment. The new proposal could cost existing solar customers thousands of
dollars on their electricity bills. Thus allowing existing solar customers to stay on the existing net metering program and
applying the new program only to new customers is a commonsense compromise that allows all parties to keep
agreements made in good faith. When changing net metering, utilities and commissions around the nation allow
existing customers to keep the original terms, because it's unethical and unfair not to. Maintaining existing utility rates
and terms for existing customers is a very common practice for other utilities in the region making similar changes - it's
reasonable to expect the same for ldahoans.
The PUc promised that discriminatory rates would not be the outcome. lf changes are implemented that negatively
impact customers' solar investments, it would be discriminatory. They need to hold true to their word. ldaho families
and businesses should not be penalized for investing their own money into a program that was created to incentivise
purchasing renewable generation. Approving a net metering policy that encouraged investment for long term savinBs,
only to have it invalidated in this manner, is unethical. We should expect more from our appointed officials on the PUC
and our public utility. lf they had no intention of honoring the service agreement they set out initially, they shouldn't
have even made it an option. But they did, and it should be honored.
At the last public hearing there was general agreement that a complete study of the impact of private solar systems on
ldaho was needed. The BrookinBs lnstitute report "Rooftop Solar: Net metering is a net benefit" (May 23, 2016) cites a
number of studies by other states that conclude that the present system of net metering is a benefit to the local power
company. ls this what ldaho Power is afraid of? Does the company want to avoid a conclusion they do not profit by.
We are not asking for a rate increase to pay us for the 75 million dollars plus that we have invested in expanding the
power generating resources for ldaho Power. We are asking to be treated fairly and according to the contract many of
us signed with ldaho Power. We are also asking that new families be treated the same as us. Please do not act before
the solar utilization study is completed. And do not allow ldaho Power to use the PUC as a means to modify the contract
we have with the company.
James A Van Dinter
12088 W Tidewater Dr
Boise, lD 83713
208 297-8288
[e-mail]
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Sunday, December '1, 2019 8:59 PM
Diane Holt
Case Comment Form: Edith Bregitzer
Name: Edith Bregitzer
Case Number: IPC-E-18-15
Email: [e-mail]
Telephone: [phone]
Address: 408 Polk Street
American Falls ldaho, 83211
Name of Utility Company: ldaho Power
Comment: Members of the ldaho Public Utilities Commission,
As a native ldahoan, lvalue the clean air and beautiful landscapes we enjoy in this state. Going solar was one way for
my husband and I to help protect the environment with a renewable energy source. Now, ldaho Power wants to
decrease the value of credit that solar customers receive on their bills for excess electricity to a rate that is
approximately 50% less than it is today. I feel strongly that the proposed rate decrease will precipitously slow down the
adoption of clean energy in ldaho and have lasting negative impact on the environment and the economy.
ldaho Power wants to achieve a goal as a 100% renewable energy provider by 2045. Solar power customers are helping
ldaho Power to achieve this goal. Changing the rules at this time will negatively impact the drive for other customers to
want to go with solar energy as a renewable energy source. As an ldaho Power customer and a rooftop solar panel
customer, I strongly urge the Commission NOT to approve the proposed decrease value of credit solar panel customers
receive on their bill for the electricity returned to the grid.
Respectfully,
Edith Bregitzer
408 Polk Street
American Falls, ldaho
Unique ldentifier: 164.165.206.42
1
Diane Holt
Diane Holt
From:
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Subject:
[e-mail]
Sunday, December '1, 20'19 10:00 PM
Diane Holt
Case Comment Form: Ray and Beth Corbin
Name: Ray and Beth Corbin
Case Number: IPC-E-18-15
Email: [e-mail]
Telephone: [phone]
Address: 6578 Cross View Lane
Marsing lD, 83639
Name of Utility Company: ldaho Power
Comment: As residential solar power providers for 5 years, we are concerned by the new proposed rate structure the
commission is studying. Our concerns focus on several areas.
1) Unfa irness, a s it fu nda menta lly and radica lly cha nges the rate structu re that was in pla ce when we sta rted. This
change is unfair, unsupported, and unethical for a utility monopoly such as ldaho Power to propose. This also negatively
affects estimated payback times by a substantial period.
2l At a time when ldaho Power is touting its environmental commitment to clean and sustainable energy
production, this proposal is a disincentive to customers who willlngly invest in a system that helps with their stated
goals. This is further demonstrated by ldaho Power's own Residential and Business Solar Program which puts their
program in competition with existing residential producers.
3) We produce power during peak periods of electric need at no increased cost to ldaho Power. By having peak
power available, ldaho Power saves investments in alternative sources of power needed during peak periods without
investing ldaho Powe/s (publics fundslfor these sources.
We believe the rate structure should remain as it is. lf anything, ldaho Power should recognize and promote residential
solar production by increasing the residential net metering rate, not lower it. lf the commission insists on a higher rate
for net metering customers, it should only affect new customers and grandfather existing residential net metering
customers.
Unique ldentifier: 764.765.?06.42
1
Diane Holt
From:
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[e-mail]
Sunday, December'1, 20'19'10:05 PM
Diane Holt
Case Comment Form: Patrick Frederickson
Name: Patrick Frederickson
Case Number: IPC-E-18-15
Email: [e-mail]
Telephone: [phone]
Address: 3004 E Rosso Place
Caldwell ldaho, 83605
Name of Utility Company: ldaho Power Company
Comment: ln opposition to Changing Compensation of Net excess energy supplied by customer on-site generation.
I have si8ned 290 individual on a petition that have agreed with my vlew for the opposition of the change.
Reasons for opposition:
1) Customers current structure is fair with excess of energy being a credit for power being used at equal prices.
2) Customers have incurred all of the cost of the panels without compensation from the energy company
This change will severely negate the cost benefits to those with solar.
3) Currently customers pay the 55.00 fee and have additional power bills during sub optimal solar days such as much of
the winter.
4) The Solar companies are providing the necessary upgrades to the neighborhood power systems to allow solar panels,
the consumers are paying for upgraded monitoring systems. ldaho Power has not provided any physical upgrades or
cost for consumers wanting to go solar. What has changed recently for them to determine that solar is such a threat to
a booming area where power usage will be a hot topic for years to come.
Thank you for you consideration of several concerned users that will be directly impacted neBatively for your decision
The petition mentioned can be emailed upon request of found at http://chng.it/zRc6BVvM
Thank you,
Patrick Frederickson
Unique ldentifier: !64.t65.206.42
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Diane Holt
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mjw.pra4snow@ gmail.com
Sunday, December 1, 2019 10:05 PM
Diane Holt
Case Comment Form: Michael Wissenbach
Name: Michael Wissenbach
Case Number: IPC-E-18-15
Email: [e-mail]
Telephone: [phone]
Address: 280 May Road
Mccall lD, 83638
Name of Utlllty Company: ldaho Power
Comment: Proposed ldaho Power Changes to On-Site Generators
We are writing to oppose ldaho Powe/s proposed changes to the way it compensates customers who export enerBy to
ldaho Powe/s electrical system usinB their own on-site generation. We applaud ldaho Power for setting a goal to
provide 100% renewable energy to all customers by 2045. Customers like us, with on-site generation can play an
important role in helping achieve that goal. However, reducing by 50% the rate at which we are compensated for
producing energy for the system undermines that very commitment.
When we made the substantial investment in our photovoltaic solar system, we analyzed how long it would take to
recoup our initial investment based on the monthly net-meterinB of how much our system would generate versus how
much energy we would consume. To have the compensation rate slashed in half puts us underwater for many years to
come.
Customer-generated solar systems, such as ours, produce more excess energy when ldaho Power needs it the most -
during hot summer days when energy demands on the system are at their peak. This customer-generated energy
supplied to the grid can be efficiently used in the local area without incurring transmission energy loss and expense, a
win-win situation for ldaho Power and customers, alike. ldaho Powe/s proposed hourly net-metering discounts this
energy supplied when it benefits ldaho Power more than it does the producing customers. This is not right.
We believe that the ldaho PUC should uphold the existing monthly net-metering program that was agreed upon by
ldaho Power and on-site generator customers. This program served as an incentive to develop and utilize locally
Benerated renewable energy and to encourage investment for long-term savings. We urge the ldaho PUC to deny ldaho
Powe/s proposed changes to on-site generators.
Michael & Pam Wissenbach
280 May Road
McCall, ldaho 83638
Unique ldentifier: L64.165.206.42
ldaho Public Utilitaes Commission:
1
Diane Holt
From:
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Subjea:
[e-mail]
Sunday, December 1, 2019 6:33 PM
Diane Holt
Case Comment Form: Roger Turner
Name: Roger Turner
Case Number: IPC-E-18-15, IPC-E-18-15, IPC-E-19-15
Email: [e-mail]
Telephone: [phone]
Address: 307 N. Buchanan Ave.
Pocatello ldaho, 83204
Name of Utility Company: ldaho Power Company
Comment: November 29, 2019
ldaho Public Utility Commission (IPUC)
Commission Secretary
P.O. Box 83720
Boise, ldaho 83720
Re: Commentson Solar Net-Metering Rate Change proposed by ldaho Power; IPC-E-18-15, IPC-E-18-15, IPC-E-19-15
Dear Commissioners:
Thank-you for this opportunity to comment on ldaho Power Company's (lPC) proposed compensation rate increase to
Net-Metering customers
I urge the IPUC commission to deny the rate change for the following reasons:
(1) Lower Compensation Rates Would Effectively Stop Roof-Top-Solar in the state. The IPUC should deny the
reduced compensation rate because it will make residential Net-Metering unreasonable financially, due to the additional
years needed to pay off the cost of the investment. That is: the proposed decreased compensation will almost
completely suppress interest in residential solar power Beneration in ldaho Power Company's service area. lt would
significantly reduce the power added to the grid that would otherwise benefit IPC's customers.
ldaho Power reports in the media that they support solar programs. For example their newsletter "Connections" states
that Solar "strengthens the electrical grid." Thus ldaho Power, on the one hand advertises support for solar initiatives,
but with this proposal they would significantly reduce compensation rates in a manner that would almost completely
stop future homeowner Net-Metering. The IPUC should consider this contradiction when making their decision because
it is unjust and unreasonable, per IPUC's guidance outlined by the state.
(2) Homeowners Bear the Cost of Solar. Since the homeowner pays for the design, equipment and installation of
Net-Metering there is little or no costs to ldaho Power for Net-Metering. (ltried to find the cost analysis presented by
ldaho Power for this case and could not find one on IPUC's website.) Solar Net-Metering is nothing but a gain added to
the power grid.
ldaho Power already has a fail-safe profit system: lf the solar power delivered to the company does not equal the
customers usaBe, the solar customers are charged the retail rate for the difference; but if that Net Metering system
1
adds more power to the grid than they use every year it is just captured by ldaho Power for absorption into the Brid
without providing any compensation to the home-owner. Also, ldaho Power charges all Net Metering customers
enough to pay the administrative costs (S62.28/year). lt's already a win-win scenario for ldaho Power, without any
change to the rates. ln all fairness and prudence the compensation rate should stay the same as the retail rate.
(3) ldaho Powe/s Proposed Compensation Rate isContraryto the lPUCGuidelines. Reducing Net Metering
incentives, as proposed by ldaho Power surely isn't in the interest of ldaho citizens, nor does it adhere to IPUCS guidance
in such matters: That is, under state law the IPUC shall regulate utilities "assuring adequate service and affixingjust,
reasonable and sufficient costs". The proposed cutting of the compensation rate by nearly half is an extreme one that is
not "Just", not "Reasonable" and does not demonstrate "Sufficient Costs".
(4) Existing Net Metering Customers Should be Exempt lf The Compensation Rate is Reduced. What about those
homeowners that installed a system under the existing compensation rate? The IPUC should not penalize those that
have installed Net-Metering, in good faith, if there is any compensation rate reduction.
ln our case, we researched the cost, calculated the panel number in order to add enough power to the grid equal to our
usage, and decided to invest in a system-based on the existing compensation rate. We also installed a "smart lnverte/'
recommended by ldaho Power to assist them in a smooth absorption of our energy into their system. We have paid our
power bills of$5.lg/month that goes to IPC'S costs ofadapting our imported power and administrative costs. Had we
known that the compensation rate would have been reduced we would have never installed the system. This situation
is true for most existing Net Metering customers. lt's not right to change the rates now. Hence, I urge IPUC to exempt
existing Net Metering customers from any rate change approved for the future. This would be the fair thin8 to do.
Unique ldentifier: 164.L65.206.42
2
Roger & Kaye Turner
307 N. Buchanan Ave.
Pocatello, lD 83204
adds more power to the grid than they use every year it is just captured by ldaho Power for absorption into the grid
without providing any compensation to the home-owner. Also, ldaho Power char8es all Net Metering customers
enough to pay the administrative costs (562.28/year). lt's already a win-win scenario for ldaho Power, without any
change to the rates. ln all fairness and prudence the compensation rate should stay the same as the retail rate.
(3) ldaho Power's Proposed Compensation Rate is Contrary to the IPUC Guidelines. RPducing Net Metering
incentives, as proposed by ldaho Power surely isn't in the interest of ldaho citizens, nor does it adhere to IPUC5 guidance
in such matters: That is, understate lawthe |PUCshall regulate utilities "assuring adequate service and affixing just,
reasonable and sufficient costs". The proposed cutting of the compensation rate by nearly half is an extreme one that is
not "Just", not "Reasonable" and does not demonstrate "Sufficient Costs".
(4) Existing Net Metering Customers Should be Exempt lf The Compensation Rate is Reduced. What about those
homeowners that installed a system under the existing compensation rate? The IPUC should not penalize those that
have installed Net-Metering, in good faith, if there is any compensation rate reduction.
ln our case, we researched the cost, calculated the panel number in order to add enough power to the grid equal to our
usage, and decided to invest in a system-based on the existing compensation rate. We also installed a "smart lnverte/'
recommended by ldaho Power to assist them in a smooth absorption of our energy into their system. We have paid our
power bills of $5.19/month that goes to IPC'S costs of adapting our imported power and administrative costs. Had we
known that the compensation rate would have been reduced we would have never installed the system. This situation
is true for most existing Net Metering customers. lt's not right to change the rates now. Hence, I urge IPUC to exempt
existing Net Metering customers from any rate change approved for the future. This would be the fair thing to do.
Roger & Kaye Turner
307 N. Buchanan Ave.
Pocatello, lD 83204
Unique ldentifier: 164.765.206.42
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From:
Sent:
To:
Subject:
[e-mail]
Sunday, December 1,2019 10:42 PM
Diane Holt
Case Comment Form: Brian Brooks
Name: Brian Brooks
Case Number: IPC-E-18-15
Email: [e-mail]
Telephone:
Address: 419 Elk Creek Road
ldaho City ldaho, 83631
Name of Utility Company: ldaho Power
Comment: To: PUC December 1,2019
From: Brian and Becky Brooks
RE: Solar Power through Auric Solar with Net metering through ldaho Power Company
We made a very conscious decision to put solar power on our house to get our winter power bill lessened and to
contribute to clean energy for the ldaho City area in which we live. A major part of our decision to invest in solar was
due to the amount of solar credits that ldaho Power agreed to allow Auric Solar to give us when they talked through
putting our solar on our property. We were told that the Net Metering Agreement with Auric and ldaho Power was
written in an Agreement that we believed would be a way for us to bank solar credits from the summer to use during
the winter. This Agreement was a major part of our decision to invest.
We totally recognized that our investment in the solar panels and installment will not be paid off for many years but we
still made the conscious decision to invest in Solar due to the amount the ldaho Power agreed to allow for the credits.
We also thought that solar power could potentially be a good selling point in the future if we were to sell our house.
We made this investment knowing that we would be supported by ldaho Power through Auric. Unfortunately, we
recently received a letter from ldaho Power saying that they will be reducing the amount that each credit would be by as
much as 50 percent. We are VERY disappointed that ldaho Power is not upholding their original Agreement with Auric
on the amount that they agreed to give us for our solar net meter credits!! We should not have the agreement changed
because ldaho Power thinks that they may be losing money from this agreement or perhaps their investors would like
more for their bottom line. We made our agreement with Auric and ldaho Power in good faith and ldaho Power should
stick to their original agreement with us! ldaho Power should allow us to continue to stay on the net metering program
as they agreed to when we signed up. lf we had known that our credits could be reduced to the point that our
investment would not be worth anything, we would NOT have invested in solar power because it would not pencil out
for us - especially in ldaho Cityl!
The reduction of how much ldaho Power allows us for our net metering will make our power bill MORE than when we
originally had power without solar and we still have over 539,000 to pay off on our solar panels. We would NEVER have
invested in solar power if we knew ldaho Power had the ability to change up how much they would pay for our net-
meterin8 power. What a sham that is!!
We should be grandfathered in on the net-metering amount that we were promised through Auric that was promised by
ldaho Power. And, if ldaho Power wants to change their process of how much they will allow for the net-metering from
this point forward, then the new customers should be put in the new program and the people who were promised a
certain amount for the net-metering credits in the past should be given the amount that was promised originally, in
good faith! lt certainly seems unethical for the power company to change this agreement mid-stream especially with
the large investment that we had put into our solar panels! We signed up in good faith and ldaho Power should follow
through with their agreement with Auric in the same good faith arrangement! Please consider grandfathering us in on
the original net-metering price. We went into this investment agreement in good faith and we believed that the power
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Diane Holt
company was going to do the same. We hope that you support us by making ldaho Power hold true to their original
agreement as negotiated by Auric Solar for net metering with ldaho Power.
Thanks for your consideration of this matter
Unique ldentifier: L64.765.206.4?
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company was going to do the same. We hope that you support us by making ldaho Power hold true to their original
agreement as negotiated by Auric Solar for net meterinB with ldaho Power.
Thanks for your consideration of this matter
Unique ldentifier: t64.765.206.42
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