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HomeMy WebLinkAbout20191203Comments_(64).pdfMCFARLANpORTTTER WL ARE IDAHo :!I( raBLANrrxrr ll rr.(otl VtA EMAI L: dia ne,h o n io n@t uc,idah o.gov Pubtic Utilities Commission I l33l w Chinden Blvd. Ste.20l-A Boise, ID 83714 Re: L'ase No. IPC-E- 18- l 5 Public Utilities Commission, I am an ldaho Power customer and I have had a residential, roof-top solar system since August 201 8. I write to requesl that the Public Utilities Commission (hereinaficr "PUC") allow me..rs an existing Schedule 6 customer, to continue to be conrpensated under the existing retail rate net metering struclure, and not be forced into the proposed new structure as sel forth in the proposed Settlement Agreement (Casc No. IPC-E-18-15), now pending before the P[JC. Facts, l. I entered into a contract to construct a rooftop solar system at my home located at I 675 E. Picabo Ct., Boise, ldaho 83716 in June 201 8. The solar system cost more than $36,000.00. 2. Based on the monthly net nretering structure in place at the time of the installation of my system (and still in place today). I expected to recoup the cost ofthat system by end ofyear 2028. 3. My solar production system was completed on or about August 23, 2018, and I received a "System is Ready" ernail from Idaho Porver on that day.'l-hat email states, "Tariffschedules (including rates and system requirenrents) are subject to change with approval from the Commissions." Reasons. l. Investment Premised on Existing Structurc. The ldaho Power disclosure provides me notice that I cannot rely on rates remaining the same; however. nothing in the Idaho Power disclosure suggests thal the fundamental structure ofthe net metering is subject to change. There is no disclosure ofthe fact that net metering may be changed from monthly to hourly. There is no disclosure that the credits I will receive will be in cash credits on my account rather than KWHs. I'lad I been on notice that the entire structure might be changed. I could have designed rny system to nrore effectively, i.e., to take better advantage ofeasterly and rvesterly sun during the hours I am home. rather than southerly when I am not home. I almost certainly would not have invested in such a robust system, had I been on notice that the structure ofthe program - not merely the rates - was subject to change. I r.o. t.r* r::s I urrruu.x, tulro l3cu I rt^rorr r^euliorrlrrx.rou I r.20ti.7{9.1s3 r.2m.895-1270 ) l 3 December 2019 My decision to install a solar electrical system in reliance on the nel metering structure - is part ofa comprehensive plan to use energy more fiscally responsibly and environmentally friendly. I purchased my first electric vehicle in August 2019. which is powered by my residential solar system, and I plan to buy a second electrical vehicle in 2020. These investments will also be compromised if I am not permitted to remain in the existing net nretering structure. ln short, my financial decision was made in reliance on the structure of monthly net metering, and this structural change (not merely a rate change) will prolong. and perhaps entirely undermine. rny investment. ldaho Power's net metering slructure was critical to a series offinancial decisions, and now ldaho Power's proposed settlement changing that structure threatens to eliminate the financial benefits ofmy investntent. 2. Takings. Should I be forced into the new hourly net metering structure. I believe I will be subject to a regulatory takings - to the benefit of ldaho Power. 3. Insuflicient Evidence, The preamble olthe proposed Settlement Agreemenl states thatldahoPower"requested,andthe.-.Commission...ordered.afollorv-ondocket to comprehensivell, study thc costs and benefits ofon-site generalion on the Company's system," and that the "Commission directed the Parties lo confer." Further, Section IV(C) states that "The methodology to determine Ithe environmental benefits of distributed on-site general.ion systemsl is not part of this settlement Agreement. . ." lt appears that the Panies did confer, but thar no study ofthe environmenlal or financial effects ofrooftop solar systems has ever been conducted - or. if it has. that study has not been published. lt seems patently unfair to upend the net metering system on which I have relied to the benefir ofldaho Power. at my expense. when the costs and benefits ofmy rooftop solar system to tlre Conrpany any other Idaho Power users has not been adequately studied. Studies outside ofldaho suggest that rooftop solar systems have a net pefiliyg efl'ect on all users: httos ://www. brooki ncs.edu/rcsearch/roo ft oo-solar-net-meterine-is-a-net-benefi V. Idaho law requires utility decisions to be'Just and reasonable," (t.C. 6l-303. 6l-315) and the ldaho Supreme Coun has said such decisions cannot bejust and reasonable unless based on ''competent, substantial evidence." Application of Pac. Tel. & Tel. Co., 7 I ldaho 476, 480, 233 P.2d 1024. 1026 ( I 95 I ). In the absence of the PUC- ordered study, or other evidence justifying the new net metering system, placing me (an existing customer) into it would nol bejusl or reasonable. Conclusion. The proposed settlement was drafted without a comprehensive study, without sufficient evidence to support it, and without my involvement. lll am not permitted to remain in the net monthly metering system that I invested in, I will be unjustly deprived of my property. I request that I, as an existing net melering customer. be permitted to continue to receive the benefits ofthe program I - literally - bought into. Sfpcerely. il ft.fdn r. na"rurtuna !-egal Counsel, f,rcratr-^NDn r l-l lx.corr I r.o.rortrrt I M$Rr ,r N, l r)^rro E36Eo I evru6rl(renr,rr,rorrnr,&(r) l r.208.7s9.r6{: | '. zm.a,'rzzo From: Sent: To: Subject: rob.w-conant@gmail.com Wednesday, December 4, 2019 1:44 AM Diane Holt Case Comment Form: Robert Conant Name: Robert Conant Case Number: IPC-E-18-15 Email: rob.w.conant@gmail.com Telephone: 208-559-5719 Address: 4950 N Farrow St Boise lD, 83713 Name of Utility Company: ldaho Power Comment: My testimony as delivered tonight, actually early this morninB at the meetirc 72/3-12/4119 Thank you, commissioners, for your patience to hear us. I am a professional electrical engineer. I have specialized in system design on this very campus for about a decade. We have a lot of onsite generation perspectives in this room. I am here to do my duty as a citizen, not mainly to represent the solar Beneration customers, who diligently could be here to speak for themselves. I have come with a perspective from the underrepresented 450,000 plus other ldaho power customers who were failed to be notifled of any of this. They are after all the suggested beneficiaries of this change. All my data and calculations are based on the companies fixed cost report. The company would like it to be apparent from their fixed cost report that they, are losing a large amount of money from on-site generation customers. At least when considering the factors that they wished to include. They would like it understood that this lost revenue is being born by the bulk of the non generatin8 residential customers. And have since justified this proposal in the name of rate fairness. There are a number of other factors they did not include which more thorough net-metering study would have, including numerous deferred costs and solar benefits they fail to assign value to. Such as mainly Benerating during the summer (their self-proclaimed "higher costing summer months", page 32). While multiple scenarios were considered in their report, the actual benefit to ldaho non-BeneratinB residents of net hourly billing was not discussed at all in the 91 page fixed cost study. So I have beencompelled to determine from their own data what this benefit might be. As an important aside, the company is using incorrect language in their public correspondence. The company's letter to the public addressed, and I quote, "more accurate measuring", as the issue being addressed in this case. accurate measuring, who could argue with that? they don't mention. That accurate hourly measuring is already occuring, and has for 5-10 years with the distribution of smart meters and any customer can login online and see accurate hourly measuring, their utilization and upload to the Brid. I urge the commission to require ldaho power to use the correct terminology with all the negative PR it may incur, This is about residential solar carryovers and billing methodology. The term measurement is misleading to the public and you will see that is not the terminology the company chose to use in their report. As a result of my personal analysis of their report there are two points I would like to make to the commission regarding logical and mathematical problems with the study and the proposed settlement agreement. Diane Holt 1 Point 1: The company is proposing this change in the name of rate fairness. They would, like those who incur the costs (at least as they would like to calculate them), to pay the costs. But strangely, from the companies own figure 1, page 15: (the residential generation customers are not the ones you should be targeting. There exists much more vast misalignment of distribution of fixed cost dollars within the schedule 1 residential (non-onsite) customer class itself. Because the company has failed to address the main fixed cost issues. Not discussed by the company is fixed cost report is the large discrepancy between who paying for those fixed costs and who is actually incurring those fixed costs. And l'm not talking about solar generation, l'm talking about the bulk of schedule 1 residential customers not billed appropriately amongst each other for fixed costs, per the companfs own report. The examples are not hard to consider, someone with a low scale constant (high accumulated) electric load is bearing the fixed costs, imposed by someone with little overall energy usage, but patterns which drives up the real costs of peak load and time of use generation and infrastructure costs. Also, there are also 430 times more of those regular customers than onsite generation customers. I would ask the company Why are we not proposing properly assigning the vast majority of fixed costs within schedule 1? lf we are truly pursuing fixed cost fairness amongst schedule 1 (by the way this is the proposed goal), wouldn't it make sense to address 99.8% of the group impacted by the problem, not only the 0.2% who are on-site residential customers? Why are you discriminating against on-site generation, saying they HAVE TO to pay their proper share of fixed costs, but no one else? No other schedules at all. This leads to the most blatant issue with the company's study Point 2: This regards the dollar amounts involved, you have-to follow the money. I examined the company's revenue surplus/deficiency numbers. They are clear. And with the company I must agree they are overcharging residential customers based on their data, by 19 million per year, (page 14), or on average 60 dollars per customer. But who is getting the benefit ofthis overcharging by 19 million? The company makes it sound like it is the residential solar producers, as this is the only party whom the company is targeting with this regulation. But only half a million (2.6%) is due to residential solar. Even according to their math. lf the company is overcharging residents by 19 million, who is the other 18.5 million subsidising? This is not going to residential solar. lt is the Large General, lndustrial and lrrigation customers who are not payin8 their fair share of costs, burdening the residents in schedule 1, and if you consider the service charge schedules 05 and 08 pay, perhaps them as well. Page 14, figure 6 in the report summarizes that this discussion should not merely be about a minor 0.5M. We should be addressing the 31 million, 60 times as much as ldaho power is considering addressing, though they have had this data for two years. lf we even achieved billing onsite generators perfectly fairly, based on the company's own numbers, the commission would save the average schedule 1 customer, over the course of an entire year, 1$. (The math is not hard - half a million $ recuperated to about as many customers) I ask the commission, why are we not discussing saving them the full S50 a year. Let's have candid discussion about the 20,0O0 irrigation, large general, and industrial customers who are causing 97.4%, almost the entire the schedule l over-charge totalling 31 million, and get that back to schedule l customers. ln WWll we dropped rubber dummies in enemy territory so they would spend their limited ammunition fighting a harmless target. 2 The company is wasting the commissions and the publics time tar8eting the wrong group. I would urge you, commission to focus your resources on the actual cost burden to ldaho residential overbilling. Why are we wastin8 years tar8eting residential generation, lndividual homeowners, who account for only 2.5% of the amount you are overcharging other residential customers? l'm not surprised that the public views this as predatory by the company, for squashing the schedules 06 and 08 because they encroached on their power generation monopoly. Here today we are discussing how to punish 0.2%, or two out of a thousand customers for faulty rate structures that fail to account for fixed costs properly for ANY of the half a million residential customers. Why tarBet initial change towards the two smallest schedule groups both in numbers and dollar impact on your rate fairness quest? Why is the company discriminatinB in this way? Something you have forbidden. One of the only conclusions the consumer can make is they are targeted because they don't have corporations behind them. As an analyst of the solar community I see: . Alignment with federal and state goals of advancing clean energy . personal investment in the technology of the future o personal investment in the clean future of our world . while not taking a single cent of a paycheck from our investment, only future deferred costs based on responsible calculations based on your prior policy. Should not they rather be the target of your support, having fully cooperated with every regulation and safety protocol you have issued, in fact bore additional cost to their solar systems in order to meet regulation? Are they some son of law violators? And yet, the company sent misleading statements like desiring the "accurate measuring". They should have been honest and said "lucrative billing for ldaho Power to the detriment of prior green energy competition in ldaho". ldaho Power's proposal has a clear goal to remove decades of previously agreed upon green energy incentives to a few, while promoting their "pro-green" face to the vast public, while they continue to overcharge that same public tens of millions, while subsidising the much more literally power hungry industry bottom lines. Should not hourly billing be marketed as it is, merely a way to tarSet and discourage residential solar customers in an unprecedented way? Why are they not including irrigation (schedule 24), Lar8e General Service (schedule 9)? This is discriminatory. ln the regulation proposal, the company would like to discourage future solar installations and for inappropriate reasons. This is based on data from their own report. Their own summary language focuses on classes 06 and 08 (a mere 2.4% their problem) as "especially'' a problem) pg 15. Why is 2.5% of the companies billing issue "especially a problem" while 97 .4% is not being mentioned at all here? I agree that reform is needed, but if approved, you are targeting the wrong group with this regulation. lf power providing parties like ldaho power are guaranteed a roughly 7% profit on their work, why are the truly green, proactive, smaller, more risk exposed, and personally invested homeowners in ldaho not worthy of similar consideration? Simply because they don't have millions of stakeholders holding stock certificates or sitting across the board room. The only personal comment that I would make is that My residential solar stakeholders are ages 4, 7, and 11, sit across the dinner table from me. And at some point l'm also here to represent them. They are currently excited about clean energy with open minds and future careers defined by pride in our households caring well for our limited community resources. They are smart and hear about and reference this moment, as thousands of children will. They are looking to us all to be examples ofjustice. I know you, like l, fall into one of these two categories, schedule 1 or 6. The company would suggest that solar generators are to be treated as a power wholesalers, and yet denied that their solar installation is able to pay for itself, or any profit. Reasonable would be guaranteeing the same 6.8% that the ldaho power is guaranteed and granted depreciation and other tax incentives that all businesses are provided by federal law. 3 This is of course, a ridiculous proposal. Every household will have low barriers to producing energy in a couple decades in some form, if they still own the sun that shines on their house. There is an overly complicated legal mess that would ensue, if we approve this, making every household a power business. This would be further distracting form the real source of fixed cost inequality in ldaho. Lets stay focussed, and do our jobs and force ldaho power to address the broader fairness issues. with years into the discussion and the company pressuring for quick regulation, it is time we start talking about a fair solution. Why would the so-called beneficiaries of this change not be invited? Because if they came and actually did the math, this is not the change they would want, it does not begin to address their needs. This begs the question of who is this change representing? Really, if not for schedule 1 benefit (a dollar?)? At the end of my analysis, Who is this for? this is about ldaho power controlling the future of household energy generation, nothing more, nothing less. The higher the percentage of energy they control, the more dollars of revenue they receive, the larger dollar amount profit they have at their guaranteed rate of return. To close, lf you are for clean energy? Why punish it? Punishing these 0.2% of the residents does not even begin to grant the other 450,000 fairness. This is a lie that we are being sold, and the math is clear. lf you are for rate fairness then lets actually pursue it, instead of straining out a 0.5M gnat and swallowing a 31M camel. Unique ldentifier: 164.765.206.42 4 Diane Holt Flom: Sent: To: Subject: tom-michaelson@ hotmail.com Tuesday, December 3,2019 3:40 PM Diane Holt Case Comment Form: Tom and Becky Michaelson Name: Tom and Becky Michaelson Case Number: IPC-E-18-15 Emall: tom_michaelson@hotmail.com Telephone: 8316767900 Address: Nampa ld, 83686 Name of Utility Company: ldaho Power Comment: The Commission should uphold the original program that was agreed upon by ldaho Power and solar customers. ldaho Power should not be allowed to make a profit on the backs of unfairly treated solar customers. 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 originalterms, because it's unethical and unfair not to. Maintaining existing utillty 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. Unique ldentifier: 764.165.206.42 1 Diane Holt From: Sent: to: Subject: dmmonsees@gmail.com Tuesday, December 3, 2019 3:55 PM Diane Holt Case Comment Form: David Monsees Name: David Monsees Case Number: IPC-E-18-1S Email: d m monsees@gma il.com Telephone: 202-669-6431 Address: 1347 W Parkhill Drive Boise ldaho, 83702-1350 Name of Utility Company: ldaho Power Comment: The proposed settlement as nothing more than a thinly disguised attempt by ldaho Power (lP) to continue their long battle against distributed electricity generation based on renewables, especially sun and wind. They first stood firm in favor of coal and now continue to promote gas, even when they know that these short-term gains will lead to long-term losses. Their approach to using fossil fuels is the driver behind the sixth great extinction, an extinction that may well include man. The planet we know today is the victim of companies like ldaho Power. The blizzards, wildfires, flooding and droughts are well known to be an large part a result of our failure to use sustainable power sources. The proposed settlement violates requirements of IPUC Order No. 34046 in Case No. IPC-E-17-13 that called for a publicized cost-benefit analysis of lP's on-site generation system. This analysis, if done, has not been released. The IPUC must carefully determine that the fiBures in that analysis are correct and fair, including, as required, all net metering customers or other constituent investors in on-site solar power generation. lP does not need the money they wish to obtain by raising net metering rates. lfthey do need money, they might instead forgo the obscene raises and bonuses not truly earned by their executives. They might also stop spending huge sums on donations to ldaho's politicians. While use of these monies is constrained and legal, it remains that this is a thinly disguised bribe giving politicians funds to defeat lP's opponents in elections and to pay their dues to their political party. This eases politicians' pain of spending half their day fundraising. ln one year, Governor Otter received not only his annual gift of 55000 from lP, but also received similarly large donations from Mr. Anderson and other lP executives. This largess is possible because of the conflicts of interest among well-paid members of the IDACORP board, and the fact that Breen or renewable energy is not considered when awarding raises and bonuses. This system is broken. ln today's world, an lP monopoly is no longer necessary. The environment has and is changing to the point that old practices cannot be allowed if this earth is to survive. Tha nk you, Dr. David Monsees 1347 Parkhill Drive Boise, lD 83702 1 Unique ldentifier: L64.f65.205.42 From: Sent: To: Subject: pricebr@tfsd.or9 Tuesday, December 3, 2019 3:57 PM Diane Holt Case Comment Form: Bruce Price Name: Bruce Price Case Number: IPC-E-18-15 Email: pricebr@tfsd.org Telephone: 2088632518 Address: 1016 Toxaway Circle Twin Falls lD, 83301 Name of Utility Company: ldaho Power Comment: Good morning, Thank you, thank you for being one of the few power companies in the United States that ls trying to create a power grid that does not include coal and methane gas as its primary source ofgenerating electricity. Thank you for being a leader in the idea for the average person considering using less energy by educating the population of ldaho in your clean/green energy solutions in our homes. Thank you for givin8 an incentive to ldaho farmers to reduce their energy usage by turning off their irrigation pumps at peak times during the summer days and also indirectly teaching farmers that watering during the peak electrical hours is also a poor method of irrigation as the summer heat evaporates a substantial amount of irrigation water. Thank you for bein8 one of the power companies that does not have a nuclear power plant built within your grid. Thank you for being reliable for me and my families heating in the winter, coolin8 in the summer, lights, a cold refrigerator with cold beer, and for the other first world problems we have here in ldaho because of the power you provide. Thanks you for leading in the technology advancements that electricity needs to make to keep everyone around save. Thank you for all of the linemen that risk their lives and spend numerous hours fixing power poles, such as the twenty plus power lines that went down near Jerome, ldaho in November. Your company is reliable and dependable when compared to the other power companies in ldaho. Thank you for providing an incentive for electricity and power consumers to change. The incentive that your company provided have allowed numerous electricity consumers change how they think about their energy consumption, has provided numerous new business opportunities, and most importantly improves your measurement of being a green company. Having solar installed on my house was not only a green/environmental, but an economic decision. But let us take a moment to discuss ldaho Power and its history of economic decisions. ldaho Power infrastructure, including dams and hydroelectric plants and wlnd turbines have been funded by other numerous other entities such as the federal government, including the Bureau of Reclamation, Army Corps of Engineers, state government, and private business and corporations like British Petroleum. The infrastructure that you now own and maintain has been built through numerous federal and state funding projects, which are and have been Breat for the economy in ldaho and will continue to fuel the economic groMh of our state. ldaho is in the middle of the next economic growth phase, which was spurred by ldaho Power, the solar movement. With numerous solar companies moving into our state and being started within our state by local entrepreneurs, the economic growth will fill the 25% void of ldaho Powe/s movement away from coal and natural gas fuel as a means to produce energy. The incentive to place solar on our roofs is the driving force to make a change in the future and to fill your void of electricity coal and natural gas produced in our state today. Thank you for becoming a carbon free company and let the consumers produce the next phase of infrastructure for ldaho Power. 1 Diane Holt ln ldaho Powe/s quest to become carbon free, I have seen numerous commercials and advertisements promoting green technology and Breen habits. ln these commercials, ldaho Power promotes ways to lower household electricity demands, such as changing lights to LED, adding a lid while cooking to retain heat, and turning down the thermostat during the winter to lower energy costs and bills. All of these are a start, and yet as soon as my family put solar panels on our roof, the power and energy savings created by your incentives, change my outlook and my family habits. All of us in our home now demand that we make sure we change the lights to LED, we are using less energy by turning off lights to areas we are not using, the thermostat is now controlled by a central system that knows when we are home and we use the heat/cooling systems only when we are at home. We have changed, we are actually practicing conservation and the cause is the incentive to maintain our incoming solar through energy conservatlon. Solar and the incentive to save on our 5100.00-200.00 ldaho Power bill has caused a change in our home, for the better. There was a story in the New York Times that discusses how ldaho Power has paid farmers since 2004 to turn off their irrigation pumps during electrical peak hours and of course the farmers agreed. They agreed because you give them a financial incentive. The same is true for those households using electricity during peak hours, ldaho Power give them an incentive to turn offtheir thermostats while they were not at home during those peak hours. ldaho Power has created a business model of spurring change and the solar panels installed on my home was ldaho Power new incentive, equal price for kwh coming in as going out. "With the right incentives, people can and will modify their behavior in ways that are beneficial," LaMont Keen, the C.E.O. of ldaho Power Thank you for keeping the incentive to go green and making this beneficial to those households and businesses that want to add to the grid. Please consider keeping the contract we signed together and agreed to in April the same. The power we generate should cost you the same as the power you generate..........l am going to keep up the infrastructure on my side of the electrical panel, while you can keep up the infrastructure on your side ofthe electrical panel. The people that are not generating power should pay more to offset the costs on your side of the infrastructure, as they are more reliant on it than those who have chosen solar. As discussed earlier, some of the cost of your original infrastructure was not paid for by ldaho Power. At minimum, I would want my children to uphold their end of contract or agreement, even if they didn't like the results later. I would hope the narrative changes for my children and they do not think of ldaho Power as the quote from the New York Times, "IDAHO POWER has been used to getting its way: it's an old joke around Boise that ldaho is the only state named for a power company." Use your influence for the benefit of all, let the new solar infrastructure help with the Brid a peak times, but let us have the incentive of generating power at an equal cost, let small business installing and maintaining solar grow the economy, let the coal and natural gas plants can be a source of energy from the past, and uphold your agreement on our contract together, be the business model of change and inspiration, change the narrative of energy production and profit, this is the new way. Remember, The Sears and Robbuck catalog was once the way to buy ltems, Amazon changed the business model of how to do thin8s. B. J. Price Twin Falls High School Biology Department 1016 Toxaway Circle Twin Falls, ldaho 83301 2 From: Sent: to: Subiect: johnlharry@msn.com Tuesday, December 3, 2019 3:58 PM Diane Holt Case Comment Form: John Harry Name: John Harry Case Number: IPC-E-18-15 Email: johnlharry@msn.com Telephone: Address: 1452 W. Powder Ct Eagle ldaho, 83615 Name of Utility Company: ldaho Power Comment: I understand ldaho Power is seeking to drastically change the amount it is paying for solar power customers with net metering. Neitherthe Commission nor ldaho Power set the initial net metering system up in a vacuum. We made the financial decision to add solar power to our house based on the rules set up by you both. We have a lot of money invested in this system. We only have a limited time to pay for the system. Our lives are not infinite like a Corporation that will go on forever. lf you must change the rules make it for future solar customers who can then decide based on the new rates, or cap net metering as a percentage of total customers. lunderstand ldaho Power says everyone needsto payforthegrid. lagree withthis. Possiblythe cost of thegrid should be a separate line item on the utility bill. But then shouldn't ldaho Power pay something for my grid, my infrastructure. we (solar net metering) arepartof thegrid now. Afterall I am producing the most electricity when lda ho Power needs it the most. we have invested in the Brid, because ofthis ldaho Power is spending less on infrastructure and maintenance. One of the main reasons for net metering, among many other things, was to eliminate the need for an additional coal fired plant or to eliminate one. We are helping to do this. Please don't punish us for stepping up with a very substantial financial investment that, with current rates, will still take about 12 years to pay off. lf the PUC decides to reduce the rate ldaho power pays for the electricity I produce I will be taking a loss with no possible way to recoup. The PUC guarantees ldaho Power make a profit. Maybe this should change too. Thank you for your consideration. John Harry Unique ldentifier: 164.L65.2O5.42 Diane Holt 1 Diane Holt Flom: Sent: To: Subject: tmccauley@gmail.com Tuesday, December 3, 2019 4:01 PM Diane Holt Case Comment Form: Todd Mccauley Name: Todd Mccauley Case Number: ipc-e-18-15 Email: tmccauley@gmail.com Telephone: Address: 3155 W State Eagle lD, 83616 Name of Utility Company: ldaho Power Comment: I would like to express my disapproval of the proposed solar policy. lt amounts to a decrease in credit for power we generate. we spent over s100,000 for our system with the expectation that this would have a pre- determined payback period. We feel it is unfair to change the rates on pre-existing solar installations. We feel that if changes must be made to the existing credit rates, at the very least, systems installed prior to the rate change should be grandfathered in and keep their old rates. ldeally, the solar power credits should be applied at the same rate they are charged. This seems the fairest way because with the proposed rate change, we are generating electricity on our investment that is profiting ldaho Power while only partially compensating us. Thank you! Unique ldentifier: 764.165.206.42 1 Diane Holt From: Sent: To: Subject: greg.lonnon@gmail.com Tuesday, December 3, 2019 4:07 PM Diane Holt Case Comment Form: GREGORY LONNON Name: GREGORY LONNON Case Number: IPC-E-18-15 Email: greg.lonnon@gmail.com Telephone: 20828/,674L Address:747 E, Hlghland View Dr Boise lD, 83702 Name of Utility Company: ldaho Power Comment: I believe we need to keep reasonable incentives in place to help grow green power production. Please do not increase fees for residential solar usage. Uniq ue ldentifi er: L64.165.206.42 1 From: Philip J. Neville To: ldaho Public Utilities Commission RE: Case Number IPC-E-18-15 On Site Electric Power generation settlement agreement on net metering. Dear Sirs: I am an ldaho Power residential customer with a state of the art rooftop solar power installation for on site generation. This system was installed about a year ago. ldaho Power inspected and approved the system. Like many other residents of ldaho, I had been concerned about the air pollution involved in production of energy from fossil fuels and decided to do my part to reduce dependency on such polluting fuels. I studied the history, costs and benefits of residential solar power and reviewed the installation costs with Auric Solar of Meridian, lD. I analyzed the projected energy savings from the specific residential installation at my home and understood that the installation would likely not pay off during the life expectancy of the solar panel installation. Nevertheless I went forward hoping to do my part to reduce the amount of fossil fuel generated power I would consume and reduce my electric power bills. As I review the proposed changes being considered by the lD PUC, I see that the changes would reduce the price ldaho Power pays io solar customers for solar generated power. Changing the rules that existed for net metering when current customers signed up would be harmful to those of us that previously invested in solar equipment. lt makes no sense to lower the price ldaho Power pays for power going forward when the price charged by ldaho Power tends to increase over time. Oddly, such customer generated power can be viewed as a windfallto ldaho Power, which need rely only on already existing infrastructure, and did not require major new investment, to receive the power. Such existing infrastructure is used not only to to sell and distribute their power to current residential customers. ldaho Power uses those same lines to purchase clean power from small customer / providers. Additionally I paid a $100 fee to ldaho Power as part of their application process in order to have this arrangement. lt is disappointing if not unethical for ldaho Power to change the rules and reduce the compensation to families and businesses who made the investment in good faith. Sincerely 1d(L(/ Philip Neville 33 oo W, /nrtv, -*t borse TD. 83toS 9r ( Flom: Sent: To: Subject: jpage422@gmail.com Tuesday, December 3,20.19 4:17 PM Diane Holt Case Comment Form: Julia Page Name: Julia Page Case Number: ICP-E-18-15 Email: jpage422@gmail.com Telephone: Add ress: Boise lD, 83702 Name of Utility company: ldaho Power Company Comment: We are existing net metering customers. Our system was designed on the basis of our needs and the net metering policies available at the time and installed on our house in the spring of 2017. We anticipate that the system will pay back our investment over the next 15 years or so. Beyond that, we are pleased to be able to generate power for ourselves and provide any extra to the grid. We do not think it is appropriate to apply the conditions of the settlement agreement to existing solar customers, especially the part about cutting in half (approximately, over time) the amount credited to us for power we provide to the grid. Our calculations for system design and payback would be turned upside down if these new rates apply. Aside from my strong feeling that existing rooftop solar systems should not be subject to this new order, I don't believe ldaho Power should be recommending new rates without having completed the study of the costs and benefits of distributed generation they were asked to do in a prior order. I find it hard to believe that rooftop solar costs ldaho Power money. lf that's the case, I want to see and understand how that occurs. How can rates be set without such a study? I am glad ldaho Power has committed to supplying 100% clean energy by 2045. I believe it ls in the public interest to do everything we can to lessen our use of fossil fuels. This new order makes it harder to achieve that goal by making an investment in rooftop solar much more difficult to ever pay off. This is backward in terms of achieving a clean energy goal. lt will hurt installers and diminish the economic impact of their work in ldaho. Also, I know there are a number of people who have already committed to installing solar on their homes but whose systems haven't been finished yet. These folks also made their calculations based on the existing price structure. lt would be unfair to penalize them by changing the rules in the middle of the game. lf they've signed their contract, they should be grandfathered in. As I understand it, even including these new people whose systems are not online yet, there are still only a relatively small number of rooftop solar systems throughout the whole ldaho Power system. Hurting new dispersed generation customers is not necessary. ldaho Power will not give much up by leaving them out of the new rate structure. Thanks for the opportunity to comment Unique ldentifier: 164.165.206.42 1 Diane Holt From: Sent: To: Subject: chadnworth@gmail.com Tuesday, December 3, 2019 4:19 PM Diane Holt Case Comment Form: Chad Worth Name: Chad Worth Case Number: IPC-E-18-15 Emaal: chadnworth@gmail.com Telephone: 208-557-9578 Address: 1621 W Hays St Boise lD, 83702 Name of Utility Company: ldaho Power Comment: My name is Chad Worth. I work as an engineer for a national clean energy consulting firm and also serve on the board of the Snake River Alliance, ldaho's nuclear watchdog and clean energy advocate. I helped launch the Solarize the Valley program in 2OL6,2OL7 and 2018, helping over 125 families across southwest ldaho go solar. These comments represent my own personal comments. While l'm not pleased with the outcome of the current NEM proposal, I appreciate the extensive work completed by ldaho Power, the PUC and the many energy advocates over the last year. I strongly encourage the ldaho PUC to require ldaho Power to "grandfathe/'the existing -4,000 NEM customers (and all those who invest in solar prior to this decision becoming final) for a period of 20 years under the current retail NEM structure. These ldaho families and businesses have collectively invested millions of dollars into ldaho's clean energy economy, helping provide cleaner air for ldahoans and a more resilient electric system for ldaho Power. While it's true that rates for NEM customers were never guaranteed to not chanBe, it is impossible to expect homeowners and businesses to make a multi-decade investment decision on anything but the existing NEM structure. Maintaining the "retail" structure for existing solar customers for a period of 20 years is fair, easy to administer for ldaho Power and has negligible impacts on non-NEM ratepayers. Excess generation compensation and grandfathering issues are not unique to ldaho as many state PUCS and utilities have dealt with these various NEM issues across the country in recent years. ln late 2015, Nevada state regulators switched existing NEM customers to a low, wholesale-type rate for excess power consumption. There were both significant layoffs of solar workers statewide and significant political backlash in the following years' election. ln short, our neighbors to the south have shown us what can happen decisions are made by regulators and utilities that needlessly upend existing solar investments. Nevada eventually reversed course, and ldaho should learn from their experience. ln summary, I strongly encourage the ldaho PUC to require ldaho Power to grandfather all existing NEM customers at the time of the final decision under the current NEM retail rate structure for a period of 20 years. Thank you. U nique ldentifier: 764.165.206.42 1 Diane Holt Diane Holt From: Sent: To: Subject: juliedagostino@gmail.com Tuesday, December 3, 2019 4:19 PM Diane Holt Case Comment Form: Julie DAgostino Name: Julie DAgostino Case Number: IPC-E-18-15 Email: juliedagostino@gmail.com Telephone: Address: PO gox2l44 Boise lD, 83701 Name of Utility Company: ldaho Power Co. Comment: I oppose the effort to cut by 50%, the price paid for power generated by the 4000+ solar owners in ldaho. Unique ldentifier: !64.765.206.42 1 Diane Holt From: Sent: To: Subject: Mdhaza@gmail.com Tuesday, December 3, 2019 4:30 PM Diane Holt Case Comment Form: Barbara Forderhase Name: Barbara Forderhase Case Number: IPC-E-18-15 Email: b4dhaza@gmail.com Telephone: 208-433-9548 Address: 2157 E Walling Drive Boise 1D,83712 Name of Utility Company: ldaho Power comment: Changes in ldaho Power's Net Metering - IPC-E-18-15 Dec 3,2019 I am currently in the process ofgetting solar panels for my home. lsigned a contract with Auric Energy on October 18, 2019 and got financing shortly thereafter. Usin8 the Federal tax credit, l'm also replacing a 20+ year-old roof. My system will probably go "live" by the end of December. I had heard rumors of ldaho Power seeking approval of a new net metering program from the ldaho PUC but was not aware of the details or timeline. Had I known how close the decision was to being decided, I wouldn't have moved forward with going solar. The issue was brouBht to my attention at the end of October, after I signed the contract. As a single person household, my energy needs are not large. I have line dried my clothes for years. This was not just to save money but to reduce my energy consumption and to do my small part to fight climate change. My investment in solar was to be a responsible citizen in creating clean energy, not just for myselt but for others. ldaho Powe/s jump into large solar farms is a new development. The solar system being installed on my house is the smallest allowed. Based on my historic energy use, Auric estimated that my system would create 115% of my energy needs. At first that bothered me, but then I thought - others can't afford solar systems and I would be creating clean ener8y that would be used by others. I liked the idea that I would get credit for my solar power at the same rate as ldaho Power charges customers- even though l'd probably never use the credits. l've even thought I should increase my energy use to try to break even. Then with the new net metering system I would eventually Bet only 50% of the value of the energy I create. On top of that, with the Net Hourly Metering I would see an even lower return on my investment. So... financially my investment would be at a huge loss for me and ldaho Power would reap a hu8e gain. When the ldaho PUC granted permission to ldaho Power to separate residential and small business net meteran8 customers into different classes, the IPUC also directed ldaho Power to conduct a comprehensive study of the costs and benefits of net metering on ldaho Power's system to determine a proper rate structure of excess energy generation. My understanding is that this comprehensive study has not been completed. lt is only fair to existing and potentially new solar customers that this study be completed before new net metering rates Bo into effect. The Brookings lnstitution supports that concept - "Net metering - contra the Nevada decision - frequently benefits all ratepayers when all costs and benefits are accounted for, which is a finding state public utility commissions, or PUCS, need to take seriously as the fight over net metering rages in states..." 1 "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." "From the state PUCS' perspective, until broad changes are made to the increasingly outdated and ineffective standard utility business model, which is built largely around selling increasing amounts of electricity, net-metering policies should be viewed as an important tool for encouraging the integration of renewable energy into states' energy portfolios as part of the transition beyond fossil fuels. To that end, progressive regulators should explore and implement reforms that arrive at more beneficial and equitable rate designs that do not prevent solar expansion in their states." The article continues with suggested reforms. https://www.brookings.edu/research/rooftop-sola r-net-metering-is-a-net-benefit/ I sincerely hope that if the ldaho PUC does approve ldaho Power's new net metering program that individuals and businesses that have already invested in solar panels will be exempt from the change. Each of us invested in our systems based on the current net metering program. ln my case where my system isn't "live" yet... there was no approval for the new net metering when I decided to go solar. Protect the private investments of individuals. Protection of our investment also includes protecting the existing systems as part of the house. When a house is sold, the existing new metering program should transfer to the new homeowners. One selling point a solar company made to me was the increased value of my home when I sell it in the future, based on the solar system. Protection of the warranty on our solar systems is another issue. A new net metering program may very well reduce the demand for home solar systems putting existing solar companies out of business. Who would repair it if my solar company goes out of business? Sincerely, Barbara Forderhase Unique ldentifier: 164.L65.206.42 2 Diane Holt From: Sent: To: Subject: diaalt@hotmail.com Tuesday, December 3, 20'19 4:41 PM Diane Holt Case Comment Form: Dia Crevier Name: Dia Crevier Case Number: IPC-E-18-15 Email: diaalt@hotmail.com Telephone: 2089008093 Address: 2545 East Hampshire Court Eagle lD, 83616 Name of Utility Company: ldaho Power Comment: ldaho power needs to honorthe agreements made when we invested our money into solar. This proposed pay change seems like ldaho Power wants to penalize us for going Green. Which baffles me, because they are still making a profit from our connection fees and they make a profit from our surplus. Unf que ldentifier: L64.765.206.42 1 Diane Holt From: Sent: To: Subject: amyssecondmail@gmail.com Tuesday, December 3, 2019 4:50 PM Diane Holt Case Comment Form: Amy Taivalkoki Name: Amy Taivalkoki Case Number: Email: amyssecondmail@gmail.com Telephone: Address: 1133 E Washington St Boise lD, 83712 Name of Utility Company: idaho Power Comment: Regarding the proposed net metering change to be netted on an hourly basis instead of monthly. I have experience with solar and we all know that ideally it should be netted up annually except for maybe on the equator. The idea of truing up every hour is such a convoluted way of trying to get more money out of solar system owners. lf the rational is that solar owners do not pay their fair share of the grid because they are using so little power when netted monthly, I would ask how does that compare to someone who is super efficient and careful with their electricity usage? Are they paying their fair share? Just because a customer has a solar system does not mean that they are using less power than a careful neighbor. The solar owner could have an electric hot tub, or space heater, that even with the boost from the solar system makes their electrical usage high. Where do you draw the line on how much everyone should pay for grid access? lf the argument is that the utility is "payinB" too much for the excess Beneration from residential solar systems when truing up on a monthly basis, I disagree. The solar systems are generating electricity at peak hours for the utility - during the day when air conditioners are running, or furnaces are blowlng. Having the residential solar systems provide power back to the grid means that electricity is essentially going right next door to the neighbors and ldaho power is Betting the retail rate from that neighbor. The solar owner then needs that power back at night and retrieves it from the grid. By going to hourly netting, tdaho Power is always charging the solar owner retail and so is really getting paid twice. ldaho Power should not be concerned about residential solar cuttin8 into their profits. Solar PV is still very expensive to install and the majority of people will not do it. Since ldaho Power has plans to go to renewables in the long term anyway, why not be the good guys? Why not be the champion of clean energy and out in front on climate change? What a great legacy it would be to look back on as opposed to penny pinching every nickel from the tiny percentage of residents who choose to spend their money on a PV system out of a moral choice for less pollution. They could have bought a gas guzzling SUv with that same money. Please reconsider. Tha nk you. Amy Taiva lkoski 1 Unique ldentifier: 164.L65.206.42 Diane Holt From: Sent: To: Subject: shirleenroark@gmail.com Tuesday, December 3, 2019 4:52 PM Diane Holt Case Comment Form: Wayne Roark Name: Wayne Roark Case Number: IPC-e-18-15 Email: shirleenroark@gmail.com Telephone: 208-789-2059 Address: 2351 N. Tan8ent ave. Meridian ldaho, 83646 Name of Utility Company: ldaho Power Co. Comment: The PUC should uphold the Original program that was agreed upon by ldaho Power and solar customers. ldahoans have invested in local clean enerBy expecting a fair deal ldaho families shouldn't have the rules changed on them after they have already made their investment. Allowing existing net metering program and applying the new customers is a commonsense compromise. 1 Uniq ue ldentifi er: L64.165.206.42 Diane Holt From: Sent To: Subject: Kstea rns@arcadvisers.net Tuesday, December 3, 2019 4:53 PM Diane Holt Case Comment Form: Katherine Stearns Name: Katherine Stearns Case Number: IPC-E-18-15 Email: Kstearns@arcadvisers.net Telephone: Address: 805 East State St. Boise lD , 83712 Name of Utility Company: ldaho Power Comment: lwould like to voice my opposition to the proposed net metering changes. My understanding is that net metering customers comprise less than 1% of ldaho Power's customers, meaning that this change will not have a significant financial impact on ldaho Power. lt will, however, deter residentlal solar which should be encouraged rather than discouraged. Furthermore, the installation of rooftop solar was a significant financial commitment for us (and others) based on projected long-term recovery of our investment (and environmental benefits). There is no compelling reason to approve the proposed changes. Thanks for your consideration. Unique ldentifier: 154.765.206.42 1 Diane Holt From: Sent: To: Subject: craignpennyTS@gmail.com Tuesday, December 3.2019 5:09 PM Diane Holt Case Comment Form: Craig Morrow Name: Craig Morrow Case Number: IPC-E-18-15 Email: craignpennyT6@gmail.com Telephone: 907-602-1399 Address: 110 Voyager St. Middleton ldaho, 836214 Name of Utility Company: ldaho Power Company Comment: I find that your act of using my solar energy for your own purposes and taxing me for the use of it is highly unethical. lt's much like me helping a friend who got a job but has no transportation. I purchase a car and make the lone payments and tell him he can use the car for transportation. He need not pay the registration fee, maintenance costs, or anything other than the gas. Time goes by and then he comes to me and tells me that he is going to charge me a fee for the use of a car I am letting him use. Now my question, is this ethical? ls this fair? No, it's not. But in reality, that is exactly what you are proposing. You want to basically charge me for the excess energy I am allowing you to use for your own purposes. Unique ldentifier: 764.1.65.206.42 1 Diane Holt From: Sent: To: Subject: halliekail 300@gmail.com Tuesday, December 3, 2019 5:31 PM Diane Holt Case Comment Form: Hallie Hinchman Name: Hallie Hinchman Case Number: IPC-E-15-18 Email: halliekai1300@Bmail.com Telephone: Address: Boise ldaho, 83702 Name of Utility Company: ldaho Power Comment: l'm a student in ldaho and have lived here my whole life. l've always noticed how far behind we seem in relation to other states, particularly on the issue of renewable energy. By increasing the payback time on solar panels, they will be less financially advantageous for customers. I understand your want to protect your non-renewable energy business. However, we must be on board, all together, for making the switch. Please make it as feasible as possible for customers to choose the type of energy they really want, and do not increase payback time. Thank you. Unique ldentifi er: 764.L65.206.42 I Diane Holt From: Sent: To! Subject: joshuashill@gmail.com Tuesday, December 3, 2019 5:39 PM Diane Holt Case Comment Form: Joshua Hill Name: Joshua Hill Case Number: Email: joshuashill@gmail.com Telephone: Address: Boise ldaho, 83705 Name of Utility Company: ldaho Power Comment: This comment should include attached graphics e-mailed to Curtis Thapen and Stacey Donohue of the Publlc Utilities Commission. l, Joshua Seth Hill, do swear that the below testimony is true and accurate to the best of my ability. I am a customer of ldaho Power residing at 1625 S. Latah St, Boise, ldaho 83705. A full rate change is necessary and I would suggest a simple time of use rate across all schedules to solve the problem and be updated in future rate cases as needed. ldaho Public Utilities Commission previous Order regarding Accumulated Net Excess Energy Credit Balances and potentially grandfathering: ln Order No. 32846, the Commission stated, "we find it fair, just, and reasonable for the kwh credit to indefinitely carry forward to offset future bills for so long as the customer remains on the net metering service at the same generation site. Allowing the credits to carry forward indefinitely ensures that customers will be able to use their credits when they need them and thus receive the benefits of their systems." lT lS HEREBY ORDERED that ldaho Power shall close Schedule 84 and create new Schedule 6: Residential Service On-Site Generation and new Schedule 8: Small General Service On-Site Generation. lT lS FURTHER ORDERED that ldaho Power shall initiate a docket to comprehensively study the costs and benefits of on- site generation on ldaho Power's system, as well as proper rates and rate design, transitional rates, and related issues of compensation for net excess energy provided as a resource to the Company. lT lS FURTHER ORDERED that ldaho Power shall file a study with the Commission exploring fixed-cost recovery in basic charges and other rate design options prior to its next general rate case. 1 I testify that the settlement in case IPC-E-18-15 is unfair, unjust and unreasonable. The proposed rates for on-site generation customers are discriminatory and unfair. Before any changes to Schedules 6 and 8 can be made, a full study of the benefits of solar should be completed by multiple parties, including independent third parties. IPC-E-17-13 - IDP - New schedules for customers with on-site generation When Customers go solar, they are paying for the generation, not ldaho Power. Savings and cost-shift from solar when compared to energy efficiency is very similar to the grid. ln many ways solar is more beneficial. From ldaho Powe/s 2018 Annual report: "ln 2018, 2oL7, and 2016, ldaho Power expended approximately S44 million, S48 million, and $43 million, respectively, on both energy efficiency and demand response programs." IDP STAFF: "Demand-Side Management Marketing Expenses versus Total Program Expenses Pages 19-20 of the Demand- Side Management 2018 Annual Report breaks out the marketing expenses of S1,270,112 from the portfolio total spend ot $44,252,080." That means the Company spends around?.87yoon marketing to customers encoura8ing energy efficienry. "ln 2OL8,ldaho Powe/s energy efficiency programs reduced energy usage by approximately 173,000 MWh." 173,000 MW or 514,878,000 (at 50.086 per kWh, which is less than the actual retail value) of revenue was lost in 2018 due to customers becoming more efficient. On-site generation customers can function exactly the same as energy efficient customers. Solar is simply one way to be energy efficient AND provide the benefits of distributed energy to the grid. 514,878,000 + 51 ,270,112 = 516,148,112 in total cost of energy efficiency. Quote from ldaho Power/s 2018 Annual Net metering report: "There are roughly 650 electrical distribution circuits in the Company's service area. As of March 31, 2018, there were 2,068 active net metering systems totaling approximately 16 MW on 377 distribution circuits." 16+ MW of generation which costs ldaho Power 50 to install and maintain. The value of distributed generation is VERY SIGNIFICANT. "The Company had accumulated approximately 0.5 million, 1.3 million, 2.3 million, and 2.6 million unused excess net enerBy credits by the end of years 2014, 2015, 2016, and 2017, respectively." 2,500,000 * SO.O80 = 5223,600.00+ in FREE ELECTRICIry in 2017. PUC STAFF: "Distributed energy is every bit as valuable as energy efficiency." The Energy lnformation Administration estimates that national electricity transmission and distribution losses average about 5% ofthe total electricity generated in the United States each year. (40- lndependent Statistic & Analysis-U.S. Energy lnformation Administration. Accessed April 2,20t5: http:l/www.eia.gov/tools/faqsfaq.cfm?id=105&t=3.) Distributed Generation lowers the transmission cost to the grid Provides an overview and explains how came to numbers (15:45) open case filed "fixed cost report" - case 18-16 JSH: "When is our peak pricing?" COMPANY STAFF: "lt depends, but power system peaks in late afternoon/evening in summertime." JSH: "What solar benefits were set aside?" z COMPANY STAFF: "Regarding the 7070 fixed cost claim - the Company filed a cost of seNice study. looklng at overall costs. A "class cost of service study' was uploaded as work papers in IPC-E-18-16 docket." (This study looks at ldaho Powe/s Overall cost of operating). COMPANY STAFF: "Three components - avoided transmission and distribution capacity, integration costs, environmental benefits." ldaho Power's Annual Net metering report quotes: 20170428ANNUAL NET METERING REPORT VII. SYSTEM RETIABILITY CONSIDERATIONS The circuits that contain the greatest number of net metering systems are largely located in northeast Boise and in thewood River Valley area, while the circuits that contain the greatest amount of connected net metering capacity tend to be located in mostly agricultural and rural areas. The greatest number of active net metering systems that currently exist on a single distribution circuit is 30 totaling approximately 139 kW. On another distribution circuit, from a capacity perspective, seven generators (all solar) rated at approximately 606 kW are located on that single distribution circuit. That circuit serves mostly rural customers with a calculated summer peak load of approximately 1,900 kW. The net metering penetration on the circuit is approximately 32 percent. The net metered connected kW capacity on the Company's distribution system continues to remain small and the Company has not yet experienced significant operational impacts on these circuits. ...This review may include determining if there is adequate transformation and conductor capacity, as well as a phasing (single- versus three-phase) match. The Company has not denied any net metering applications due to system limitations, but continues to carefully monitor requests for connection to ensure ongoing safe and reliable service is available to both existing and new customers. ...As net metering system penetration increases, the Company will keep the Commission apprised of experienced or anticipated system reliability impacts and will propose mitigation as needed. This may include additional inverter requirements such as smart inverter technology, which can mitigate many high penetration issues. 20180423 ANNUAL NET METERING REPORT II. SYSTEM RELIAEILITY CONSIDERATIONS The circuits that contain the greatest number of net metering systems contlnue to be located primarily in northeast and east Boise and in the Wood River Valley. However, greatest net metering connection capacity tends to be on mostly agricultural and rural serving circuits. For example, the largest number of net metering systems connected on a single distribution circuit are 47 which total approximately 244 kilowatts ('kW'). The distribution circuit that leads in connected capacity has only eight solar PV system that are rated at approximately 667 kW. This circuit seNes mostly rural customers with a calculated summer peak load of approximately 2,100 kW. During minimum load conditions, the 550 kW of power flows from the circuit into the substation and on to other circuits. Although growing quickly, the net metered connected kW capacity on the Company's distribution system continues to remain small relative to the total load and the Company has been able to manage the minimal operational impacts on these circuits. ...Although some service transformer upgrades have been required, and further study has been necessary, the Company has not denied any net metering applications due to system limitations. ...The use of smart inverter technology, with reactive support capability enabled, may mitigate many high penetration issues and provide additional distributed generation hosting capacity. Above graphic shows one of many projects where a customer and/or the solar provider fully funded a S2,0O0 - 53,000 transformer upgrade. Upgraded transformers allow the utility company's system to be more efficient as well as recover more revenue due to added capacity on the upgraded circuit (more potential customers). Below is a check sent to ldaho power to fund a transformer upgrade, this necessary upgrade to the grid was fully funded by the customer. Eventually, if this customer had not gone solar, ldaho Power would have had to fund this up8rade with revenue from every customer. ldaho power company's comments in support of settlement - pg -7 'The Signing Parties agreed that other costs and benefits (avoided T&D [Transmission & Distribution] capacity, integration costs, and environmental benefits) may be measurable, but agreed not to include those costs or benefits as part of the settlement Agreement." 3 "When customers reduce their usage for any reason, that creates under-recovery for the utility and what we're left to do is collect that from other customers. The company's position is that isn't a solar problem, that's a rate design problem. And we have repeatedly stated that in these cases." "and what we've tried to do in the 18-15 report, is lay that out. That this needs to be addressed for ALL of our customers, we're not trying to single out solar." ln Order No. 34046, the Commission closed Schedule 84 to R&SGS customers with on-site generation and created new tariff Schedule 6, Residential Service On-Site Generation, and new tariff Schedule 8, Small General Service On-Site Generation. The Commission also ordered ldaho Power to initiate a docket to comprehensively study the costs and benefits of on-site generation on ldaho Power's system, as well as proper rates and rate design, transitional rates, and related issues of compensation for net excess energy provided as a resource to the Company. Order No. 34045 at 31. So lask you, as a solar professional, a local business owner, and a concerned citizen: how can the PUC pass any settlement without inclusion of all the benefits of solar, when they ordered a comprehensive study of costs and benefits of on-site generation customers? Environmental benefit of land use, grandpa hill used to say, they aren't making any more of it...use our rooftopsl Time of use across all rate schedules is a fair, just and reasonable solution. lncentivizing West facinB solar is a fair, just and reasonable solution. lncentivizing battery stora8e with solar, allowing ldaho power access to a percentage of stored kWh's during peak loads is a fair, iust and reasonable solution. I emplore the esteemed ldaho Public Utility Commissioners to not pass, in whole or in part, any aspect of case IPC-E-18- 15 until all issues mentioned above are rectified. Please find below two programs implemented by Utah and Nevada power companies: Utah: Pricing With Time of Day, your basic service rates still apply. You also pay:. 1.5334 cents less than your basic service rate (Schedule 1or Schedule 3) for each kilowatt-hour (kwh) of electricity used during off-peak hours. 4.3550 cents more than the basic service rate for each kwh of electricity used during on-peak hours Nevada: Net Metering 4 COMPANY STAFF: "What are we trying to solve? ...whats the problem? Well the problem is, while the maiority of our underlying cost structure is fixed, the way that we collect those costs is throuBh volumetric rates. And when customers reduce their usa8e for any reason, that creates under-recovery for the utility and what we're left to do is collect that from other customers, and for the residential class that happens through the FCA (Fixed Cost Adjustment). I would tell you that... the company's position is that isn't a solar problem, that's a rate design problem. And we have repeatedly stated that in these cases, and what we've tried to do in the 18-16 report is lay that out, that this needs to be addressed for all of our customers. We are not trying to sinBle out solar." I would further like to inform the Commission and the public that directly in response to this and other cases filed by ldaho Power, I have spent considerable time and resources to begin a solar advocacy company Awaken Energy LLC - DBA as "Awaken Solar". I have become distraught at the unfair practices of the utility company, and am dedicating a majority of my time and resources to foster an independent and educational company in the interest of what is fair, just and reasonable to the public regarding their energy rights. Net metering (NEM) allows you to receive a credit for the energy generated by your renewable energy system, which you can use to offset your monthly energy bill. All customers with renewable energy systems may be eligible for NEM. See below for more information if you are interested in applying for net metering. Rate Types Net Metering Rider-405 (NMR-405) Customers who installed or had an active application for a rooftop solar system of 25 KW or less on or after June 15, 2Ot7 are automatically placed on this rate and in the applicable tier. LEARN MORE Net Metering Rider-G (NMR-G) Customers who installed or had an active application for a rooftop solar system of 1,000 KW or less as of December 31, 2015 are grandfathered into original NEM rules and rates. LEARN MORE Net Metering Rider-A (NMR-A) Southern Nevada customers who installed or had an active application for a rooftop solar system of 1,000 KW or less between January 1, 2016 and June 14,20!7 .fhis rate is not available in northern Nevada. Unique ldentifi er: L64.L65.206.42 5 Flom: Sent: To: Subject: spencer.morleyT0@gmail.com Tuesday, December 3, 2019 5:42 PM Diane Holt Case Comment Form: Spencer Morley Name: Spencer Morley Case Number: IPC-E-18-15 Email: spencer.morleyTo@Bmail.com Telephone: Address: Meridian ldaho, 83642 Name of Utility Company: ldaho Power Comment: I have worked in the solar industry in ldaho for 3 years now. I am an apprentice electrician and the experience I have gained installing solar has been invaluable to my career and life goals. With this job I have seen much of the State and met many good ldahoans along the way. When I heard about the rate chanBe for solar customers here in ldaho I was very concerned. lf it were to be so drastically adjusted as it is currently proposed to be, the people that my company (Auric Energy) currently employs would be directly affected in a very negative way. Not to mention the countless good people in this state that I have installed solar for who would lose thousands on their investment in clean energy. The benefits for ldaho solar owners have not been wei8hed in this decision. What I see is that the cons have been considered only, and if ldaho Power and the PUC were to investigate the good that solar energy brings they would draw a different conclusion. The proposal as it currently stands is direct discrimination against solar power, homeowners, and the solar industry. lf this change were brought about it would not remediate the issues ldaho Power claims that it will. Alterations of power rates instead on a statewide scale including peak demand, time of use, etc, would largely resolve the matter at hand. By targeting solar owners ldaho Power is simply injuring a small number of their customers, and missing the bigger picture. I propose that the PUC and ldaho Power put the effort into real research on solar benefits here in ldaho, and make changes to help their customers as well as our environment. Sincerely, Spencer Morley Unique ldentifier: L64.165.206.42 1 Diane Holt Diane Holt From: Sent: IO: Subiect: Ben@campurllc.com Tuesday, December 3, 2019 5:43 Pl,/ Diane Holt Case Comment Form: Ben Pursley Name: Ben Pursley Case Number: IPC-E-18-15 Email: Be n @ca m purllc.com Telephone: 2O8472283t Address: 4015 N Whitehead St Boise ldaho, 83703 Name of Utility Company: ldaho Power Comment: Allowing ldaho Power to reduce net meterin8 credit to producers of green energy , throuBh their proposed transition from retail rate monthly net metering to net hourly billing at an Export Credit Rate is unconscionable, it is wrong, and this case should be thrown out. Consumers and local sustainable energy producers should be valued higher than public utility companies. ldaho Power should embrace green energy, and look for opportunities and programs that encourage further and future development and implementation of sustainable energy production. Unique ldentifier: 164.t65.206.42 1 Diane Holt From: Sent: To: Subject: cat@gietzensolar.com Tuesday, December 3,2019 5:47 PM Diane Holt Case Comment Form: Cat GieEen Name: Cat Gietzen Case Number: IPC-E-18-15 Email: cat@gietzensolar.com Telephone: 2087358990 Address: 120 gth Ave South Buhl ldaho, 83316 Name of Utility Company: ldaho Power Company Comment: Dear IPUC, First and foremost, thank you for being the voice of the public and allowing comment as you navigate the cases before you. As a solar installer and ldaho Power consumer, we have always understood that rates change with utilities. At the same time, this is not a simple rate change. We see this as a complete restructuring of an entire program. We have sold and installed many systems under this net metering agreement and never promised rates would be the same, but this new program will drastically affect the payoff and their investment. Please at the very minimum, grandfather the current on site generation customers with the current program so they can continue on with their investment as they intended and continue to be satisfied solar and ldaho Power Customers. lf this new program is what we move forward with, that's fine as we still see it as a valuable investment for those who want to be energy independent. We have worked very hard at keeping the integrity of selling solar very high and in accordance with the Consumer Protection Act and will continue to do so as we now have a tangible set of parameters for the new program. Please at the minimum, protect the small businesses and families of ldaho who have made a decision to invest in renewable energy under the current program. Sincerely, Cat Gietzen Unique ldentifier: L64.1.65.206.42 I From: Sent: To: Subject: i nfo@alternatepowerdesi gns.com Tuesday, December 3, 2019 5:58 PM Diane Holt Case Comment Form: Scott Moore Name: Scott Moore Case Number: IPC-E18-15 Email: info@alternatepowerdesigns.com Telephone: 2OA2759655 Address: 1840 E. Mary Lane Meridian lD, 83642 Name of Utility Company: Alternate Power Designs, LLC Comment: Dear, ldaho Public Utilities Commission ln response the IPC proposed Net Metering (NM) changes and the lntervening parties agreed settlement. lwould like to you to consider denying the requested changes based on my following observations. 1. IPC claims that these changes are needed to cover the actual cost of maintaining a NM customer that offsets a portion or all of their monthly power usage, otherwise non-net meterin8 customers have that cost unfairly shifted to them. 2. lfthat cost can be measured or calculated accurately for delivering power during times when the on-site Beneratlon is below consumed power usage, it would likely be a very small or insignificant cost compared to all of the other cost shifted amounts that non-NM customers already pay. These cost would include customer that cost much more provide power to such as summer cabin in Lowman, lD compared to a Boise area. Yet they both pay the same base service charge and while the cabin may use less power and send much less annually with lPC. 4. There is also unfairness or cost shifted to customers under the IPC's Energy Efficiency Services Program with adds a monthly fe e of -4Yo to all customers bill to pay for IPC's business customer to install higher efficiency devices to reduce power consumption. This program had been justified by IPC before the PUC as 51 spent on power reduction can save 53 in new power and distribution. Yet went a NM customer not only reduces their daytime load and possibly their neighbor's load, lt appears to have no value. 5, IPC also has a time of day billing rate that allows customer to Bet a lower rate at night to encourage shed daytime load. This again is what solar NM customer accomplish. 6. Many things in life and business are unfair in some way or another if examined close enough and that why the significance of the situation matters. IPC has about 5000 NM customer out of 570,000 tota I customers which is less than 0.17o and if 1/2 of those NM customers where at net-zero annually, that would be 0.05%. I doubt that this is in the top 10 thing of cost unfairness or cost shifted to IPC'S non-NM customers! 7. I believe that Net Metering in ldaho will continue the be a problematic issue before the PUC until ldaho passes laws pertaining to Net Metering like so many other states have. For example Oregon statue give NM customers a 1:1 power credit and annual expiration in March that credits the customer at avoided cost back to the customer. 1 Diane Holt 8. IPC also justifies this current action as needed to avoid problem from a rapid increase in NM customers. This condition is likely caused by the 30% Federal tax credit expirinB startinB next year. For a customer considering NM based on financial return on investment, this change makes not feasibly any longer. This would be a good reason to deny the settlement to determine if NM applications diminish and if the State can address this in new laws. Unique ldentifier: 164.155.206.42 2 From: Sent: To: Subject: mikekochert46@ gmail.com Tuesday, December 3,2019 6:13 PM Diane Holt Case Comment Form: Michael Kochert Name: Michael Kochert Case Number: IPC-E-18-15 Email: mikekochert46@gmail.com Telephone: 2083088046 Address: 1622 S 1525 E Gooding ldaho, 83330 As a resident of ldaho who installed residential solar panels in 2015, lam extremely concerned about the proposed settlement that would decrease the value of the credits that we receive from ldaho Power for electricity that we generate under their net pro8ram. My wife and I have a 6 kW system consisting of 24 ground mounted panels in our barnyard north of Gooding ldaho. After having solar for only 4 years, we have not yet reached our return metering on lnvestment. lt is extremely unfair for ldaho Power to renege on their promised agreement, which was the basis for our decision to lnvest ln solar panels. We had considered adding more solar generation to the farm, but ifthese new rules are in place, any project would be cost-prohibitive. This proposal could cost us and the more than 4,000 other ldaho families that have lnvested in solar generation literally thousands of extra dollars on our electricity bills. Those of us who invested early in local, clean energy should not be penalized for doing the right thing at the right time. We acted in Bood faith, and ldaho Power should keep up their end of the bargain. The rules shouldn't change after families and lndividuals have already made their large lnvestments. ldaho Power should keep up its end of the bargain. ldahoans have invested in local clean energy expecting a fair deal Climate change is already threatening our infrastructure and our environment in many ways. 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 made in good faith. Now is not the time to discourage lnnovative clean energy solutions. Residential solar ener8y will be a critical part of a more reliable, sustainable energy future for ldaho. Unique ldentifier: 164.165.206.42 1 Diane Holt Name of Utility Company: ldaho Power Co Comment: Thank you for the opportunity to comment on the proposed action. I urge you to allow existing customers to stay on the existing net metering program. Diane Holt From: Sent: To: SubJect: ron-hill@q.com Tuesday, Decembet 3,2019 6-.27 PM Diane Holt Case Comment Form: Ron Hill Name: Ron Hill Case Number: IPC-E-18-15 Email: ron-hill@q.com Telephone: 2085145739 Address: 10459 W Shadow Rock St Boise lD, 83714 Name of Utility Company: ldaho Power Comment: I have two major concerns. ExistinB on-site generators should be grandfathered, and the eventual export credit rate of 4.4 cents per kW-hr is too low for Schedule 6 customers when combined with net hourly billing. Existing on-site generators conducted economic feasibility calculations based on ldaho Powe/s current net metering rate structure. lt is not fair for ldaho Power to pull the rug out from under these customers because these proposed changes will drastically change the payout times for existing systems. For example, in my case the payout time for my solar panel system is 22 years under the current net metering rules, but it becomes 38 years under the proposed new rules. Not fair! Existing on-site generators should be grandfathered-in at the current net meterinB rate structure. More specifically, any customer with an approved Schedule 6 or Schedule 8 application, dated on or before the final promulgation date of the proposed new net metering rules, should be grandfathered-in. I fully agree that new on-site generators should pay their fair share to financially support the grid infrastructure. However, the proposed eventual export credit rate of 4.4 cents per kW-hr is too low for Schedule 6 customers when combined with net hourly billing. On the one hand, ldaho Power promotes conservation by, for example, sending out LED light bulbs to customers free of charge. But yet, at the same time, they want to financially penalize on-site generators who are also conserving electricity. Pragmatically, the excess electricity generated in my solar panels is used by my next door neighbors. The only portion of the grid that I am using is the electric line between my house and theirs. ldaho power wants to buy my excess power at 4.4 cents per kW-hr and sell it to my neighbors 80 feet away at double the price. The fact ofthe matter is that I am saving ldaho Power transmission costs because of the short distance between my house and my neighbot's houses. At our house we typically use electricity first thing in the morning and then again in the evening. But, during the day when our solar panels are producing power, the only thing running in our house is the refrigerator. So, under the proposed hourly net metering rules, lwould be selling almost all of my generated electricity to ldaho Power on-the- cheap, and purchasing almost all of the electricity used in our house at retail. My point is the proposed eventual export credit rate of 4.4 cents per kW-hr is too low for Schedule 6 customers when combined with net hourly billing. In conclusion, I encourage ldaho Power to strive hard to make rooftop solar and other forms of on-site generation a hi8h priority in reaching toward the goal of 100% renewable by 2045. Unfortunately, the proposed changes to net meterin8 will make rooftop solar economically unviable. 1 From: Sent: To: Subject: suerS'l 'l @gmail.com Tuesday, December 3,20'19 6:30 PM Diane Holt Case Comment Form: Susan Ripley Name: Susan Ripley Case Number: IPC-E-18-15 Email: suer811@gmail.com Telephone: 2088822974 Address: Moscow ldaho, 83843 Name of Utility Company: ldaho Power Comment: Dear Commissioners: The League of women Voters of ldaho (LWVID) strongly urges you to reject the settlement agreement presented in IPC- E-18-15 for the following reasons. . ln case IPC-E-17-13, we, and many others, asked for ldaho Power Co. (lPC) to complete studies that investigate the benefits and costs of roof top solar to the company before creating a new customer class. None of those studies has been completed. The settlement is based on assumptions and conjectures put forth by lPC.We believe the studies must be done before any valid settlement agreement is reached.. None of the affected parties appear to have been included in the settlement agreement discussions. None of the roof top solar investors are signatories to the agreement and they will be most affected by the regressive rate structure proposed by the company. ln addition, the new rate class effectively will kill the incentive for future roof top solar investment by individuals.. There is an energy policy vacuum in ldaho. Since the legislature will not tackle these tough issues, we urge the Public Utilities Commission to be bold in advancing progressive policies that give the ability of individuals and small businesses the choice to be part of the solution to energy and climate problems. The future is going to be different from the past. The cost of a kWh is no longer the only factor to consider in rate cases and settlement agreements. The public interest must play a lar8e role. The LWVID is a statewide, nonpartisan organization that studies an issue and comes to consensus before adopting a position. The League has adopted positions that support policy, legislation, regulation and funding to attain clean air standards, to reduce greenhouse gas emissions and to increase energy efficiency and reliance on renewable energy resources. Regards, Susan Ripley President, League of Women Voters of ldaho Unique ldentifier: L64.I55.206.42 1 Diane Holt Diane Holt From: Sent: To: Subject: jcinsara@hotmail.com Tuesday, December 3, 2019 6:44 PM Diane Holt Case Comment Form: ,ustin Crevier Name: Justin Crevier Case Number: IPC-E-18-15 Email: jcinsara@hotmail.com Telephone: Address: Eagle lD, 83616 Name of Utility Company: ldaho Power Comment: Before they try to buy the power we generate at a low price and resell it to consumers at higher price, ldaho Power needs to consider the long term. (1) Solar batteries are becoming cheaper. lf running solar imposes an unfair cost on us, we will eventually just buy a battery and effectively leave the grid. (2) Their customer base will continue to expand-they can feed this with either locally-purchased power (from us, at a fair market rate) or buy surplus need from generators in California and elsewhere. Short term minor profits or long term stable income flow? Their choice. Unique ldentifier: 764.f65.206.42 1 Diane Holt From: Sent: To: Subject: jmrohling@gmail.com Tuesday, December 3, 2019 5:48 PM Diane Holt Case Comment Form: Jane Rohling Name: Jane Rohling Case Number: IPC-E-18-15 Email:.imrohling@gmail.com Telephone: 2089383529 Address: 582 Palmetto Drive Eagle lD, 83616 Name of Utility Company: ldaho Power Company Comment: ldaho Power company's (lPC) own website states: "We are alternative energy leaders - as investors, developers, operators, and strategists." lf that's the case, then the company's settlement (Order No. 34046 and Case No. IPC-E17-13) regarding net metering, which will directly and negatively impact constituents who have actually invested in on-site solar power systems, should not have been approved without input from the current net-metering customers. 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. IPC acknowledges this decision will have impact the return on investment that customers will realize from their investment in solar systems on IPC's own website: "please be sure to educate yourself about the current cases before the ldaho Public Utilities Commission that could change your expected payback date when making a solar investment." (https://www.idahopower.com/energy-environment/green-choices/solar-power-options-customer-generation/) 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. Unique ldentifier: f64.t65.206.42 1 From: Sent: To: Subject: ryan.bushland@gmail.com Tuesday, Decembet 3,2019 7:13 PM Diane Holt Case Comment Form: Ryan Bushland Name: Ryan Bushland Case Number: IPC-E-18-15 Email: ryan.bushland@gmail.com Telephone: Address: Meridian lD, 83646 Name of Utility Company: ldaho Power Comment: I have been selling solar in ldaho for 4 years. I belleve that the proposed settlement will have a devastating impact on future residential and commercial solar projects funded by private parties. Compensating small scale overproduction at wholesale rates will be a deterrent for many interested parties, especially for small scale solar. lf these changes are passed then many solar professionals will be forced to leave the state to support their families. I feel more important is the issue of grandfathering current customers under the current agreement. lt is seems like changing a system after prlvate individuals invested their hard earned money is wrong. lf a change is made then it is fair for future customers make their decision off what changes get made. lt is not reasonable to make a change if a customer bought solar with the current net metering agreement. Unique ldentifier: L64.755.206.42 1 Diane Holt Diane Holt From: Sent: To: Subject: leigh4dl @gmail.com Tuesday, December 3, 20'19 7:19 PM Diane Holt Case Comment Form: Victoria Ford Name: Victoria Ford Case Number: IPC-E-18-15 Email: leigh4dl@gmail.com Te le p ho ne : 2OA-297 -36L4 Address: 927 N Bell Ln Boise lD, 83703 Name of Utility Company: ldaho Power Comment: Thank you for the opportunity to comment on ldaho Power's proposed rate changes. I would like to do the right thing for my children's (and all children's) future and get solar. I am not rich and am aware that solar is expensive, but thought if I saved it would pay itself off in the long run. The plan ldaho Power would like adopted makes residential solar as financially unfeasible. Currently only about 5000 people have residential solar this cannot be about recovering costs. lt seems they only want to stop us from getting solar. For those that already have solar, the proposed changes would also be unfair. These ldahoans have invested in local clean energy expecting a fair deal. ldaho Power should keep up their end of the bargain. 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. ldaho Power has an interest (and probably requirement) to increase the profit of their shareholders but can they do that at all of our expense? We share the same air and water and it's our children that will have to live with the consequences of our mistakes. Thanks again for the chance to comment Unique ldentifier: 764.165.206.42 1 Diane Holt From: Sent: To: Subject: pei-linyu@boisestate.edu Tuesday, December 3, 2019 7:33 PM Diane Holt Case Comment Form: PEI-LlN YU Name: PEI-LIN YU Case Number: IPC-E-18-15 Email: pei-linyu@boisestate.edu Telephone: 2088635681 Address: 250 williams st boise id, 83705 Name of Utility Company: LAH ldaho PUC Comment: I urge you in the strongest terms to grandfather existing net-metering customers under the program which drove the designs and installations of their systems. Around the U.S., in other states, 20 years from installation has been a typical grandfathering period, which coincides with the expected lifetime of solar PV panel generation. That grandfathering should follow our accounts, if not our addresses. Exlsting customers MUST be grandfathered, which is fair and economically just to the citizens of ldaho. Thank you for the opportunity to comment. Unique ldentif ier: L64.L65.206.42 1 From: Sent: To: Subject: gemmautting 1 @gmail.com Tuesday, December 3, 2019 7:35 PM Diane Holt Case Comment Form: Gemma Utting Name: Gemma Utting Case Number: IPC-E-18-15 Email: gemmauttingl@gmail.com Telephone: 208-340-8989 Address: 424 N. Mobley Drive Boise IDAHO, 83712 Name of Utility Company: ldaho Power Comment: My husband and I invested most of our saving this past summer into installing both a new roof and 15 beautiful solar panels on the new roof,throuBh Auric. We did so for three reasons: 1. Doing something to lighten our carbon footprint feels vital as we think about the world our children will be inheriting. Even though we have geothermal heat, no clothes dryer, and our old electric bills were around 550 a month - this was something we could do to make a difference. 2. This being said, we made the decision based on a sound financial reckoning - a 1:1 ratio on the net metering as stated in all the literature we read and signed during this process. 3. Any addltional savings we may make to allow our 15 panels to "go farther" would allow us to plug in an electric car sooner than later - also a goal. My request of you Public Utility Commissioners is this: lnsist ldaho Power maintain a 1:1 ratio not only for those of us who have already signed up, but going forward. The goal here out to be focused on long term Blobal benefit, not company profits. Also, they need to maintain the 24 hour day unit of measure - not the I hour. Thank you. Unique ldentifier: 764.765.206.42 Diane Holt 1 From: Sent: To: Subject: ml.stuart+ puc@gmail.com Tuesday, December 3,2019 8:00 Pt/ Diane Holt Case Comment Form: lvlichael Stuart Name: Michael Stuart Case Number: IPC-E-18-15 Email: ml.stuart+puc@gmail.com Telephone: Address: Boise lD, 83713 Name of Utility Company: ldaho Power Comment: I am a private homeowner in the Treasure Value that installed a solar panel array this year. I have four comments regarding ldaho Powe/s proposal to alter its rate structure for customers such as myself. 1) At a minimum, it is most fair for solar installations built under previous programs to continue to be billed at the terms in effect at the time of installation. "Grandfathering" current Net Metering customers acknowledges the risk and initiative taken by these customers to invest significantly in a capital asset (the solar system) that benefits the community and the environment. Studies have shown that the fraction of total customers these early adopters represent to ldaho Power is not significant enough to materially shift utility costs to traditional customers. (See'"The Value of Rooftop Solar Power for Consumers and Society'' by Environment America Research & Policy Center at https://environmentamerica.or8/sites/environment/files/reports/AME%20ShiningRewards%20Rpt%20Oct16%201.1.pdf and "Putting the Potential Rate lmpacts of Distributed Solar into Context" by Lawrence Berkeley National Laboratory at https://emp.lbl.Bov/publications/putting-potential-rate-impacts) The Settlement Agreement's shift to "Net Hourly Billing" encourages the pairing of generation and consumption of electricity within the same hour as "exports" to the grid are valued substantially less than "imports." Existing installation owners designed systems for a reconciliation of imports and exports at a much larger time interval: monthly or annually. The design of a system under one program would obviously be substantially different than under the other. Furthermore, customers with existing installations have virtually no economically viable options to adjust their systems to match the change. lnstead, they must absorb the cost. lnsignificant cost to the community of electricity consumers versus distinct and measurable cost to existing installation owners. The prior is far fairer than the latter. Please, at a minimum, grandfather existing installations to the current Net Metering plan. 2) The grandfathering dates proposed by ldaho Power are unreasonable. A "legacy custome/' should be any customer with an active installation when the new policy is approved by the commission (is real) not when changes to that policy is proposed (is not real). Additionally, a 1o-year end date is not necessarily enough to cover the payback horizon on a newly installed installation at the beginning of this window. (My system, for example, has a payback horizon of 14 years.) 3) ldaho Power describes their legal language around the risk of rate structure changes in the application for on-site generation. legally, the language is correct. I ask the commission to consider the impact of policy beyond mere legalities. What is fair? What is best for the community? What is best for ldaho? Legal is not synonymous with "best." Diane Holt 1 4) Finally, most of the 50 states in the Union have funded studies into the value of solar. The variability in the results of these studies makes it clear that determining the value of solar and assessing the impact of distributed generation of electricity is a complex issue. Yet ldaho Power's argument that on-site generation customers are shifting costs to traditional customers is lackin8 in detail. I strongly encourage the commission to expect more from ldaho Power. Put the state of ldaho on the list of states/commissions that have further studied this complex issue in a scientifically disciplined way. ldeally ldaho can contribute to the body of knowledge leading to a fair, rational and scientifically defensible policy by publishing the results. Direct ldaho Power to explain the math behind their position. This issue has been under discussion for over a year. Where on ldaho Powe/s website is the Value of Solar described for their service area? I couldn't find anywhere. Where do they describe the components of the costs? Again, only simplistic statements without backing. How are dlstributed solar areas funded by customers worse for the utility than centralized arrays build by ldaho Power? Nothing is described. Utilities are regulated for a reason. To protect the public good and ensure that the utility acts in the best, ongoing interest of the people in their service areas. The public good is measured by a yardstick far more particular than "legal." Legality is the minimum expectation. "For the good of the people" is the real expectation (while remaining legal, obviously). Unique ldentifier: L64.L65.206.42 2 Diane Holt jekel_7@msn.com Tuesday, December 3,2019 8:'10 Pt!4 Diane Holt Case Comment Form: barbjekel Name: barb jekel Case Number: IPC-E-18-15. Email: jekel_7@msn.com Telephone: Address: 2862 N Haven Dr eagle id, 83616 Name of Utility Company: ldaho Power Comment: I have read over the issues in play due to this change over in metering measurement methods and affects to those already on the "off' line. ldaho power should be so proud of these individuals, and supportive of their work and dedication in beinB the forerunners and enthusiasts in shaping solar energy growth in ldaho. They were oriBinators, they did the work, the research, and made it a viable entity here in ldaho as first and sole users. They should be in the fairest rate charge service grouping above all broach. ln the biB picture of ldaho Power service, these dedicatees would be but a minute increment and the most deserving. ln ldaho's reach to 100%, will it be achieved with the character and good business practice those seeking natural remedies for our power needs just automatically brings to the table? Unique ldentifier: 164.165.206.42 1 From: Sent: To: Subject: Diane Holt From: Sent: to: Subject: Richardschupack@cox.net Tuesday, De€ember 3, 2019 8:20 PM Diane Holt Case Comment Form: Richard Schupack Name: Richard Schupack Case Number: IOC-eE-18-15 Email: Richardschupack@cox.net Telephone: 2087201446 Address: 417 N 5th st Bellevue ldaho,83313 Name of Utility company: ldaho power Comment: We should not let ldaho power decrease the rate that we have had over the years. We spent a lot of money putting those solar panels in 515,000. And for them now to come from behind and say they want to Bive us a lower rate is ridiculous. Let's support solar powered please. Do you not believe in global warming please vote no thank you Unique ldentifi er: 164.765.206.42 I Diane Holt From: Sent: To: Subject: meadarqj@gmail.com Tuesday, December 3, 2019 8:25 PM Diane Holt Case Comment Form: Russell Johnson Name: Russell Johnson Case Number: IPC-E-18-15 Email: meadargi@gmail.com Telephone: Address: Boise lD, 83709-1242 Name of Utility Company: ldaho Power Comment: ldaho Power has served us well for many decades, but this change of policy should die here ! ln good faith, we set up solar power at great expense for our home and our business to be good citizens. We also have enjoyed the many benefits from our solar arrays. We also believe that fewer citizens will consider solar as a good future investment, if this change is allowed to move forward. We predict that more of our neighbors will turn to wood stoves that pollute our beautiful valley, because investing in solar will have become unreliable. We also believe that many solar companies will find homes in more welcoming states We strongly object to this change of policy!! Retroactive changes should be bad policy for this and any future decisions, but also consider the message that this sends to others who want to improve their world. Unique ldentifier: 154.165.?06.42 1 Diane Holt From: Sent: To: subject michaelschnT5@gmail.com Tuesday, December 3, 2019 8:34 PM Diane Holt Case Comment Form: Michael Schneider Name: Michael Schneider Case Number: IPC-E-18-15 Email: michaelschnT5@gmail.com Telephone: 2087240373 Address: 1715 South Oakley Avenue Nampa lD, 83686 Name of Utility Company: ldaho Power Comment: I would like to add comments to the current case of ldaho Power changing the net-metering a8reement. I am opposed to the change. ldaho Power should honor the a8reement with current solar customers. ldaho Power should also continue to encourage clean energy use. I do understand that ldaho Power has to continue to operate a public utilities business model and they made the existing net-metering in that model. I am a home solar owner. lt is going to take about 18 years for the system to pay for itself. And my monthly payments are slightly more than the regular electric bill. Getting solar is not about my profit bit an equitable way for me to iovest in clean energy. The IUC should continue to support clean energy options for consumers. Unique ldentifi er: 764.165.206.42 1 From: Sent: To: Subject: chadmw3@gmail.com Tuesday, December 3, 2019 8:46 PM Diane Holt Case Comment Form: Chad Wahlquist Name: Chad Wahlquist Case Number: IPC-E-18-15 Email: cha d m w3 @gma il.com Telephone: Address: 3122 Central Park Ct Caldwell lD, 83505 Name of Utility Company: ldaho Power Comment: I am opposed to altering the net metering rules as they currently stand. Customers generate power for the utility company, which the utility company then gets to sell to other, non-solar customers. That means they get to sell electricity that they don't produce, which means they get a 100% profit margin on that electricity. This smacks of greed to me; they want to lower the fair, one-to-one net metering credit in favor of (basically) a 0.4-to-1 net metering. This will hurt our ldaho economy. Solar providers will leave the state, resulting in less jobs and less tax revenue for the state. The solar industry, according to a recent article I read, is the fastest growing industry in America right now. The article said that if every job in the coal industry was lost tomorrow, the solar industry (at its current rate of growth) would absorb all of those jobs within less than one year. Solar is the future and our state should be doing everything we can to fosterthis industryand incentivize it. The fact that ldaho Powergetstosell the customer-generated solar electricity during the daytime with a 100% profit margin makes the 1-to-1 credit more than fair. I believe it behooves the future of our state for the PUC to do everythinB in its power to preserve the net metering program as a fair, 1-to-1 program to keep solar as a boominB industry here in ldaho. This translates to iobs, tax revenue, and energy efficiency in the State of ldaho. This seems like a no-brainer to me. A vote to keep the 1-to-1 credit in ldaho is a vote to secure the future of ldaho as well as a vote to curb the monopoly that ldaho Power has on energy in the state. As Americans, we want the right to determine where our power comes from. lf the net metering is changed as ldaho Power has proposed in their docket, solar will no longer be a viable industry in the state. Solar companies will move out of the state, taking iobs and money with them, and the people of ldaho will be stuck with no options other than ldaho Power. That's just unAmerican. We want the abllity to choose for ourselves. Thank you for taking the time to read my comment. I hope that you will vote in favor of our great state and our future by preseNing solar. Unique ldentifier: 164.165.206.42 Diane Holt 1 Diane Holt From: Sent To: Subject: P-Neill@outlook.com Tuesday, December 3, 2019 8:46 PM Diane Holt Case Comment Form: Paul Neill Name: Paul Neill Case Number: Docket IPC-E-18-15 Email: P-Neill@outlook.com Telephone: 2085149491 Address: 11753 Good Day Road Melba lD, 83641 Name of Utility Company: ldaho Power Comment: I would like to encourage the IPUC to allow the grandfather provision for solar installations and other home generation systems. As a homeowner, we've invested a tremendous amount of money to do what's right for the environment, the State of ldaho and it's residents. The only way we can recoup our initial investment to offset our electric utility bill. I feel it's simply not fair to change the terms that homeowner's used to calculate their investment payback. I ask you to please grandfather all projects currently installed and all projects which have submitted applications. Thank Youl Unique ldentifi er: 764.L65.2O5.42 1 Diane Holt From: Sent: To: Subject: GARNERSINM H@HOTMAIL.COM Tuesday, December 3, 2019 8:59 PM Diane Holt Case Comment Form: SCOTT GARNER Name: SCOTT GARNER Case Number: IPC-E-18-15 Email: GARNERSINMH@HOTMAlL.coM Telephone: 2085900591 Address: 1885 NORTH 5TH EAST MOUNTAIN HOME ID, 83647 Name of Utility Company: ldaho Power Comment: Recently I received a letter from ldaho Power stating intentions of Boing back on their agreement to give a fair rate of credits on my solar system. This after they claim to be green by 2045. They will need solar to achieve this goal yet they want solar systems to give them our power at ridiculously lower and lower rates while they sell that power at much higher rates. They are already get a great deal on the power I create. Please have them Grandfather us in or keep the agreement they made originally made. Thank You Scott Garner Unique ldentifi er: f64.L65.206.42 1 Diane Holt From: Sent: To: Subject: todynewb@gmail.com Tuesday, December 3, 2019 9:01 PM Diane Holt Case Comment Form: Cody Newbill Name: Cody Newbill Case Number: IPC-E-18-15 Email: todynewb@gmail.com Telephone: Address: Meridian ldaho, 83542 Name of Utility Company: ldaho Power Comment: This last summer I had solar panels installed on my home. Part of making this significant investment was the current net metering policy and is what lagreed to when I decided to have them installed. Changing these terms for existing customers is a breech in that agreement. Please do not punish people for making a decision that made sense at the time and changing the rules so that their decision, through no fault of their own, may no longer make financial sense now. Unique ldentifier: 164.165.205.42 1 From: Sent: To: Subject: info@a lternatepowerdesigns.com Tuesday, December 3, 2019 9:05 PM Diane Holt Case Comment Form: Scott Moore Name: Scott Moore Case Number: PUC-E-18-15 Email: info@alternatepowerdesigns.com Telephone: 2082759655 Address: 1840 E. Mary Lane Meridian lD,83642 Name of Utility company: Alternate Power Designs, LLC Comment: Please add or replace this corrected comment with my earlier submitted comment today. Dear, ldaho Public Utilities Commission ln response the IPC proposed Net Metering (NM) changes and the lntervenin8 parties agreed settlement. I would like to you to consider denying the requested changes based on my following observations. 1. IPC claims that these changes are needed to cover the actual cost of maintaining a NM customer that offsets a portion or all of their monthly power usage, otherwise non-net metering customers have that cost unfairly shifted to them. 2. lf that cost can be measured or calculated accurately for delivering power durinB times when the on-site generation is below consumed power usage, it would likely be a very small or insignificant cost compared to all ofthe other cost Currently being shifted to non-NM customers. These shared or shifted cost would include customer that cost much more provide power to such as summer cabin in Lowman, lD compared to a home the Boise area. Yet they both pay the same base service charge and while the cabin customer may use less power and spend much less annually with tPc. 4. There is also unfairness in cost shifted to customers under the IPC'S Energy Efficiency Services ProBram with charges a fee of -4% to all customers monthly bill to pay for IPC's business customer to install higher efficiency devices to reduce power consumption. This program had been justified by IPC before the PUC as 51 spent on power reduction can save $3 in new power and distribution cost. Yet when a NM customer reduces their daytime load and possibly their neighbor's load, it appears to have no extra value. 5, IPC also has a time of day billing rate that allows customer to get a lower rate at night to encourage shedding of daytime load. This again is what solar NM customer accomplish. 6. Many things in life and business are unfair in some way or another if examined close enough and that is why the significance of the situation matters. IPC has about 5000 NM customer out of 570,000 total customers which is less than 0.1% and if 1/2 ofthose NM customers where at net-zero annually, that would be 0.05%. I doubt that this is in the top 10 thing of unfairness or cost shifted to lPc's non-NM customers! 1 Diane Holt 7. I believe that Net Metering in ldaho willcontlnue the be a problematic issue before the PUC, until ldaho passes laws pertaining to Net Metering like so many other states have. For example Oregon statue gives NM customers a 1:1 power credit with annual expiration in March that credits excess power back to the customer at avoided cost rate. 8. IPC also justifies this current action as needed to avoid future problems from the rapid increase in NM customers. This condition is likely caused by the 30% Federal tax credit expiring startinB next year. For a customer considering NM based on financial return on investment, this change alone will make investment in solar much less practical. This alone would be a good reason to deny the IPC case at this time to determine if NM applications diminish and if the State can address this in new laws. Sincerely, Scott Moore Unique ldentifier: 164.165.206.42 2 Diane Holt From: Sent: To: Subject: jilIianemmahanson@gmail.com Tuesday, December 3, 2019 9:08 PM Diane Holt Case Comment Form: Jillian Hanson Name: Jillian Hanson Case Number: IPC-E-18-15 Email: jillianemmahanson@gmail.com Telephone: 2088412225 Address: 2303 N 22nd St Boise lD, 83702 Unique ldentifier: t64.L65.206.42 1 Name of Utility Company: ldaho Power Comment: The Commission should uphold the original program that was agreed upon by ldaho Power and solar customers. We expect the utilities commission to stand up for what is best for the people of ldaho. This would be a step backwards; we need to move towards 10O% renewable energy as fast as possible. This is unfair and not in the interest of ldahoans. lt is in the interest of a large utility (ldahoPower). From: S€nt: To: Subject: dunksond@juno.com Tuesday, December 3,2019 9:10 PM Diane Holt Case Comment Form: Sondra Dunkle Name: Sondra Dunkle Case Number: IPC-E-18-15 Email: dunksond@juno.com Telephone: Address: 965 Sagewood Pl Pocatello lD, 83201 Name of Utility Company: ldaho Power Comment: I'm commenting on the proposal by ldaho Power Company to change their net metering program, to lower the amount of credit a customer receives for generation of solar power into the IPC grid. I am STRONGLY opposed to the requested changes, and urge the lPUc to vote No. We paid (borrowed) over 525,000 of our own money to purchase solar panels for our roof, get them installed, all the wiring completed, the shut-off switch installed, a net meter installed, get all inspections passed, and our solar system connected to the meter and IPC Brid. We did that, in part, because last year the IPUC did not allow IPC to change or remove their net metering system for solar generating customers. (THANK YOU !) Thus we knew that we would receive equal compensation in credits for the excess solar power that we generated that went back into IPC grid. (Powerthe IPC could then sell to other customers). ln Pocatello this year (2019), roughly 90 households had solar installed through the Solarize Pocatello campaign (organized & run by volunteers). Boise ran the same campaign. Moscow did so a few years ago. A conservative estimate ofthe average cost per household for Pocatello residents to go solar was S24,000. That amounts to -SZ.0fU that IPC did not have to spend on infrastructure in order to receive our excess energy free! And IPC doesn't pay to maintain our solar systems. (we do). Good deal for lPC. But that's not good enough, now they want to change their net metering system, so that the free energy they receive from our solar systems is credited back to us at lower rates than net metering! So we would put in more ener8y to get less credit back towards our IPC bills. They hoodwinked us, after we had solar installed on net metering! ln other words, net metering was used to calculate how many solar panels we would need to supply our home energy needs. lf IPUC doesn't stop this power grab by lPC, we could end up paying for our solar system, plus extra to IPC to offset their proposed lower rates of crediting us for the energy that we produce. (le, lt wouldn't take long before our credits would no longer cover our energy consumption, even though we're supplying all the power!). This is grossly unfair, and an attempted power grab by lPC. I urge you to consider the citlzens of our state, those who have installed solar, those who may in the future, and to vote NO on IPC'S proposed change to howthey wantto change net metering for solar energy producing customers. The IPC proposal isthe antithesis of helping our state become more energy independent, & move towards clean energy. ldaho salaries are notoriously low, and many of us went into debt to put in solar, because it's the right thing to do. Now please do the right thing yourselves and vote NO on IPC's new proposal. Thank you. Unique ldentifier: 764.765.206.42 1 Diane Holt From: Sent: To: Subject: tcwolfenden@gmail.com Tuesday, December 3,2019 9:34 PM Diane Holt Case Comment Form: Teresa Cohn Name: Teresa Cohn Case Number: IPC-E-18-15 Email: tcwolfenden@gmail.com Telephone: Address: 300 May Rd. Mccall lD, 83638 . Many of us have budgeted for and installed energy infrastructure based on long-term financial planning and standing aBreements with ldaho Power. lt is essential that ldaho Power respect such agreements with customers, in transparent ways that respect personal expense. We have invested in both our own financial futures as part of our personal commitment to support renewable energy infrastructure for the state of ldaho. . Given the severity of carbon emissions and climate change, we as a state should do everything possible to encourage expansion of solar power in our state, not discourage it. We see countries like England and Germany subsidizing and supporting the expansion of solar power in ways that we should replicate, not discourage. . According to the Yale Climate Opinion Maps (2019), 81% of ldaho adults support tax rebates for people who purchase energy-efficient vehicles or solar panels,83% of ldaho adults support funding research into renewable energy sources, and 62% of ldaho adults support requiring utilities to produce 20% of electricity from renewable sources. ldaho supports renewable energy. ldaho Power should invest in, and support renewable energy, too. Unique ldentifi er: L64.t65.206.42 1 Diane Holt Name of Utility Company: ldaho Power Comment: lam writing to express my opposition to changes in ldaho Powe/s solar metering program. From: Sent: To: Subject: rangerider_45@outlook.com Tuesday, December 3, 2019 9:48 PM Diane Holt Case Comment Form: Charlie Swearingen Name: Charlie Swearingen Case Number: IPC-E-18-15 Email: rangerider_45@outlook.com Telephone: 208-896-5117 Address: 9526 Sleepy Hollow Dr Melba lD, 83641 Name of Utility Company: ldaho Power Company Comment: Dear Sirs; ln reference to ldaho Power's Net Metering Policy changes, I think existin8 customers should be grandfathered in and protected from ldaho Power's proposed changes. lam retired and live on a very finite income that decreases each year thanks to inflation. ln trying to plan for the future I have invested 565,000 in a solar power system designed to meet our electrical needs in our old age. currently, our solar system produces enough electricity that I don't have a power bill, but I still have to pay the bank for oursolar power system. Now I learn from ldaho Power that they want to charge us more money, and I will have to pay a power bill. I will have to pay 555,000 for the solar system as well. How will I pay for both when my youth is gone and I don't have the option of going back to work? This will put many eldedy people in a very serious bind. lf you have questions about my situation feel free to call and talk to me. Unique ldentifi er: 164.L65.206.42 1 Diane Holt Respectfully, Charlie Swearingen Diane Holt From: Sent: To: Subject: kluckhohn@gmail.com Tuesday, December 3,2019 10:16 PM Diane Holt Case Comment Form: Richard Kluckhohnb Name: Richard Kluckhohnb Case Number: IPC-E-18-15 Email: kluckhoh n @gma il.co m Telephone: 208-941-4186 Address: 2564 W Park Stone Dr Meridian lD, 83545 Name of Utility company: ldaho Power Company Comment: The time to recover my costs in a solar system is 15 years under the current Net-Monthly metering program and thus this specific program must continue until I recover my costs or 16 years, anything less is a taking of my asset by ldaho Power, as commented at the public hearing THEFT. The PUC must consider those who took out loans to finance their solar system, as putting such owner of solar system on the proposed NET-HOURLY program will likely cause that family to be upside down on their loan, their electrical bill will not be reduced and probably return to about 50% of their previous bills and thus the saving will not cover their land payment. Tis could easily cause a family to loose their home, A perfect example is the gentle man who testified that he purchased a 591,000 system and spoke with banks about loans. The manufactured payment rate for exported power needs to be tested. lf ldaho Power is saying our exported power is only worth S.042IKWH (which is what they are saying) then the PUC should immediately order ldaho to stop charging customer more than S.042/KWH plus a reasonable profit. This means that ldaho Power share holders must take an immediate assist reduction and loss (as ldaho Power is proposing to solar families like mine) to bring their cost of power in-line with the .5042. lf that rate is good the goose (we independent solar producers) it is good for the gander (ldaho Power). Their claim, as I have hear, is they can buy power for S.027/KWH. lf that is true then ldaho Power is over charging it customers and again, ldaho Power must write off the cost that exceed the S.027/KwH rate. ldaho Power is talking out of both sides of its mouth, when it comes to market value of solar power. No ldaho Power customer should be paying more than this "5.042" rate ifthat is the true value ofthe solar power. The truth is, they have manufactured a rate that obtain a desired outcome for ldaho Power executives and shareholders not for the customers of ldaho Power. There is no real transmission cost for solar power as it flows out of my home into the home next door. My solar system is the ONLY one in my subdivision. Unique ldentifier: t64.L65.206.42 1 Diane Holt From: Sent: To: Subject: blaise.gS l @gmail.com Tuesday, December 3, 2019 '10:32 PM Diane Holt Case Comment Form: Darren Exon Name: Darren Exon Case Number: IPC-E-18-15 Email: blaise.g8l@gmail.com Telephone: Address: 2372 E Mores Trail Dr Meridian lD, 83642 Name of Utility Company: ldaho Power Comment: I'm writinB in reference to ldaho Power's desire to change their current net metering policy. My wife and I recently installed a solar power system in our home, and one of the key decision points in doing so was ldaho Power's current net metering program. ldaho Power's proposed change to that program would significantly impact our current investment, resulting in notable increases in our power bill over the coming decades. We are not necessarily against them changing the policy if they would do so in a ma nner that does not negatively impact current owners of solar systems in their service area. Maintaining the current net metering policy with current solar system owners, and applying the revised policy with future solar system owners seems very sensible, and fair to those who have already committed to investing in solar power. Please do not approve of this policy change. Sincerely, Blaise Exon Unique ldentifier: !64.165.206.42 I Diane Holt From: Sent: To: Subj€ct: k2hurley@msn.com Tuesday, December 3, 2019 10:35 PM Diane Holt Case Comment Form: Kathleen Hurley Name: Kathleen Hurley Case Number: IPC-E-18-15 Email: k2hurley@msn.com Telephone: 2088632872 Address: 3392 S Ashbury Place Boise ldaho, 83705 Name of Utility Company: ldaho Power comment: ldaho Power should not be allowed to reduce the one-for-one credits for solar customers. They did NOT share in the cost of our capital improvement when we installed our solar panels. We pay the same monthly flat fee as all other customers for being hooked up to the power infrastructure but we allow ldaho Power to reduce its power demand. We should not be penalized by reducing our credits. Sincerely, Kathy Hurley U nique ldentifier: 164.765.206.42 I From: Sent: To: Subject: jenna.whitlock@gmail.com Tuesday, December 3,2019 10:52 PM Diane Holt Case Comment Form: Jenna Whitlock Name: Jenna Whitlock Case Number: IPC-E-18-15 Email: jenna.whitlock@gmail.com Telephone: 2088657055 Address: 1511 N 11th Street Boise lD, 83702 Name of Utility Company: ldaho Power Company Comment: I live in Boise's North End - I found a patch of sunshine and installed a rooftop solar system on my home over 2 years ago. My system was purchased and engineered based on existing net metering policies that track production and usage on a monthly basis. The current settlement agreement would completely undercut my investment. . I ask that the ldaho PUC reject the settlement and send the parties back to re-negotiate an agreement that is just, fair and equitable.. No changes should be made to ldaho Powe/s net metering program untilthere is a comprehensive and independent study of the costs and benefits of rooftop solar. The current proposal is arbitrary.. ln any case, those of us who installed panels should be grandfathered in to the current net metering program. Further, systems should be grandfathered with the meter number and not just my account number. An expected increase in my home value was a major factor in my solar investment.. Any implemented changes that may happen should become effective 30 days from the PUC'S decision and should not take place retroactively. People who are under a contract for solar prior to the IPUC'S decision should also be grandfathered. The changes proposed in the settlement - hourly metering and a 4.4 cents per kWh - will kill rooftop solar in ldaho. lt would be impossible to economically justify rooftop solar given the terms of the current settlement. Please don't kill rooftop solar in ldaho - we need this option of renewable energy going forward to address the impacts of climate change in the State. Plus we ldahoans should have the ability to produce our own power. I recently retired from a 35-year career with the Bureau of Land Management and was heavily involved in standing up renewable energy development on public lands. Hydropower and large scale solar and wind farms have significant impacts to the environment. Look at the situation with ldaho salmon - ldaho runs are on the verge of going extinct. why not use roof tops instead? Please preserve this option for ldaho. Thank you. Jenna Unique ldentifier: 764.L65.206.42 1 Diane Holt Diane Holt From: Sent: To: Subject: billiefarley@q,com Wednesday, December 4, 2019 8:39 AM Diane Holt Case Comment Form: Billie Farley Name: Billie Farley Case Number: Email: billiefarley@q.com Telephone: 2084478842 Address: 15383 Cypress Street Caldwell lD, 83607 Name of Utility Company: ldaho Power comment: I am opposed to the proposed changes for reimbursement of solar energy providers to ldaho Power. Residential solar power providers allow the power company to not have to maintain equipment not invest in the equipment from which they derive ener8y for their other customers. Keep the original agreement and compensation rates, please. Help ldaho move away from power plants like the natural gas one between Caldwell and Ontario. Keep your promises to residential customers who make the investment in equipment to provide clean energy to ldahoans. Unique ldentifi er: t64.165.206.42 1