20200110Baskin Petition for Reconsideration.pdf

Thomas Baskin
3688 N. Willowbar Way
Garden City, ldaho 83714
Tombaskin3@gma il.com
RECEIVED
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CQ
January 10, 2020
ldaho Public Utilities Commission
PO Box 83720
Boise, ldaho 837?O-OO7 4
Re: IPC-E-18-15
Members of the Commission;
ldahoPower(lPC) has contacted me to talk a bout my plans. lnthecourseofourdiscussionllearned
that IPC takes the position that if I expand my current system I will lose grandfathered status for my
ENTIRE system. I have again reviewed the Order and do not believe that IPC'S interpretation is correct.
ln pertinent part the Order reads: "...[W]e are grandfatherinB the customer at the meter site at the
originally installed nameplate capacity of the system. We are not grandfathering the system...." lt
seems to me that the Order unambiguously gives the grandfather right to the customer for the capacity
that existed as of 12/20/19. I see nothing in the Order that supports IPC'S stated position that my right
to grandfather that pre-existing capacity evaporates if ladd to it. Of course, I recognize that the new
capacity must follow rules for systems installed aftet 72l2O/L9. However, lfail to see how that should
affect the rights the Commission established for my existinB generation capacity,
I am a residential rooftop solar producer who is grandfathered pursuant to the terms of the ].z/21llg
Order for the system I installed 2-3 years ago. I intend to expand my current system by five panels to
accommodate an electric vehicle. I did not make a financialcommitment on this expansion on or before
l2/20h9. I concede that the expansion I propose would not be Brandfathered. I did make a financial
commitment to my installer before the end of 2019, in order to take advantage of 2019 federal tax
cred it.
I recognize that there is only one meter at my residence, and this may present some difficulty in treating
power produced by a mixed system. However, if my current system capacity is 20 panels, and I am
adding 5, it seems that some simple rule could be established to define what percentage of my power
generation should be subject to the grandfathered export credit rate.
lask for clarification on this point. ln the alternative, if you share IPC's view on this issue, laskthatyou
reconsider your L2/2Oll9 Order. I would do this by way of forma I pleading, but time is tight, and I only
learned of IPC's position in the last hour.
Yours Very Truly,
Thomas Baskin
Cc: ldaho Power
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