20211029Sierra Club Comments_1.pdf

October 28,2021
IDAHO CHAPTER
Idaho Public Utilities Commission
11331 W. Chinden Blvd.
Boise,ID 83714
Public Hearing Comments R;e: IPC-E-21-21, Idaho Power Application Tb Initiate A Multi-Phase
Process For The Study Of Costs Bene/its And Compensation Of Net Excess Energt Associated
With Customer On-Site Generation
Good Evening Commissioners,
My name is Lisa Young. I'm the Director for the Idaho Chapter of the Sierra Club, speaking
today on behalf of over 10,000 members and supporters in southern ldaho, many of whom are
Idaho Power customers, and many of whom are interested in owning a solar system to help meet
their energy needs. I will be submitting written comments on this case before the comment
deadline, but appreciate the opportunity to speak with you during the hearing tonight. Thank you
for offering this forum to hear directly from customers and other stakeholders.
Our members and supporters are also eager to submit their own personal written comments over
the next few weeks, since this is an issue that they care deeply about and that directly impacts
them, and I want to thank you in advance for taking the time to read and consider each of their
comments, as well.
I'll start by saying that it's no secret that our organization and its members care a lot about the
health and wellbeing of the so-called "natural world." But what motivates many of us is how the
environment ultimately impacts people, communities and the economy, which of course are
inextricably linked. Harm to the environment does harm to families and businesses. And
benefits to the environment provide benefits to families and businesses.
And these costs and benefits canbe measured. Numerous studies have assessed and quantified
the tangible environmental benefits from distributed customer-owned solar, ranging from lower
public health costs from cleaner air to local green job development to strengthened grid
resiliency in the face of climate change impacts.
That's why we were so disappointed to see ldaho Power's proposed study framework present
such a weak and empty "Environmental Benefits" section. Despite being provided with the PUC
Staffs five specific suggested measurements for this section, and telling us in its reply comments
in Case IPC-EA0-26 that they would indeed use those as the basis for this study, Idaho Power
left the specifics for this section blank in its latest proposal. It just said "Evaluation of the
quantifiable environmental and other system benefits." The Commission has already directed
503 W Franklin St, Boise, ID 83702
208-384- I 023 | [e-mail]
www.sierrac lub.org/idaho
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SIERRA CLUB
IDAHO CHAPTER
Rocky Mountain Power in Case PAC-E-I9-08 to analyze those five specific environmental
benefits that PUC Staffpreviously outlined in its own identical solar study. Idaho Power should
be required to do the same, for a sound and well-rounded analysis and to ensure fairness between
ldaho Power and Rocky Mountain Power customers in Idaho. For ldaho Power to remove
details like this from its own "Environmental Benefits" section of this study leaves us concerned
that it's trying to avoid analyzing these critical metrics.
For too long, the very real environmental costs and benefits of infrastructure projects have been
swept aside and disregarded. They must be accurately studied and quantified, particularly as
environmental changes continue to have a greater and greater impact on our cities, our
communities, our homes, our grid, and consequently our economy and the public at large.
Please direct ldaho Power to, at the very least, study the exact same parameters as Rocky
Mountain Power in its "Environmental Benefits" section of its customer solar study, and consider
the recommendations by several other intervening parties who have already provided feedback
on that section, as well.
On behalf of Sierra Club members I want to thank you, again, for hosting this forum for public
comment and hearing our concerns and suggestions. We look forward to continue engaging in
this important process as it moves forward.!-1./
Lisa Young
Director, Idaho Chapter Sierra Club
Rochy Mountain Power Solar Study Paramcters (PAC-E-1948, Order 31753):
Avoifud Fnvironmenlal Co.qtc and Other Renqfits
I 5. Quantify the potential value of grid slability, resiliency, and cybersecurity protection provided by on-sile
generators os a class and dffirent penetration levels.
16. Quantify the value to local public health and safety from reduced local impacu of global warming such as
reduced extreme lemperatures, reduced snowpackvariation, re&tcedwildfire risk, qnd other impacts that can have
direct impacts on RoclE Mountain Power customers.
17. Quantify local economic benefits, including local job crealion and increased economic activily in lhe immediqte
service terrilory.
18. Quantifl the possible net value of Renewable Energ Credit sales produced by net meter@ exported energt.
19. Quantify the reduced riskfrom end-of-life disposal concerns for the Company compared to fossil-fueled
resources
503 W Franklin St, Boise, ID 83702
208-384-1023 | [e-mail]
www. sierraclub.org/idaho
SIERRA CLUB
IDAHO CHAPTER
October 28,2021
Idaho Public Utilities Commission
I l33l W. Chinden Blvd.
Boise, lD 83714
Public Hearing Comments Re: IPC-E-21-21, Idaho Power Application To Initiate A Multi-Phase
Process For The Study Of Costs Benefits And Compensation Of Net Excess Energt Associated
With Customer On-Site Generation
Good Evening Commissioners,
My name is Lisa Young. I'm the Director for the Idaho Chapter of the Sierra Club, speaking
today on behalf of over 10,000 members and supporters in southern ldaho, many of whom are
Idaho Power customers, and many of whom are interested in owning a solar system to help meet
their energy needs. I will be submitting written comments on this case before the comment
deadline, but appreciate the opportunity to speak with you during the hearing tonight. Thank you
for offering this forum to hear directly from customers and other stakeholders.
Our members and supporters are also eager to submit their own personal written comments over
the next few weeks, since this is an issue that they care deeply about and that directly impacts
them, and I want to thank you in advance for taking the time to read and consider each of their
comments, as well.
I'll start by saying that it's no secret that our organization and its members care a lot about the
health and wellbeing of the so-called "natural world." But what motivates many of us is how the
environment ultimately impacts people, comrnunities andthe economy, which of course are
inextricably linked. Harm to the environment does harm to families and businesses. And
benefits to the environment provide benefits to families and businesses.
And these costs and benefits canbe measured. Numerous studies have assessed and quantified
the tangible environmental benefits from distributed customer-owned solar, ranging from lower
public health costs from cleaner air to local green job development to strengthened grid
resiliency in the face of climate change impacts.
That's why we were so disappointed to see ldaho Power's proposed study framework present
such a weak and empty "Environmental Benefits" section. Despite being provided with the PUC
StafIs five specific suggested measurements for this section, and telling us in its reply comments
in Case IPC-E-20-26 that they would indeed use those as the basis for this study, Idaho Power
left the specifics for this section blank in its latest proposal. It just said "Evaluation of the
quantifiable environmental and other system benefits." The Commission has already directed
503 W Franklin St, Boise, D 83702
208-384-1023 | [e-mail]
www.sierraclub.org/idaho
SIERRA CLUB
IDAHO CHAPTER
Rocky Mountain Power in Case PAC-E-19-08 to analyze those five specific environmental
benefits that PUC Staffpreviously outlined in its own identical solar study. Idaho Power should
be required to do the same, for a sound and well-rounded analysis and to ensure fairness between
Idaho Power and Rocky Mountain Power customers in ldaho. For ldaho Power to remove
details like this from its own "Environmental Benefits" section of this sfudy leaves us concerned
that it's trying to avoid analyzing these critical metrics.
For too long, the very real environmental costs and benefits of infrastructure projects have been
swept aside and disregarded. They must be accurately studied and quantified, particularly as
environmental changes continue to have a greater and greater impact on our cities, our
communities, our homes, our grid, and consequently our economy and the public at large.
Please direct Idaho Power to, at the very least, study the exact same parameters as Rocky
Mountain Power in its "Environmental Benefits" section of its customer solar study, and consider
the recommendations by several other intervening parties who have already provided feedback
on that section, as well.
On behalf of Sierra Club members I want to thank you, again, for hosting this forum for public
comment and hearing our concerns and suggestions. We look forward to continue engaging in
this important process as it moves forward.!-1./
Lisa Young
Director, Idaho Chapter Sierra Club
Rocky Mountain Power Solar Study Paromctas (PAC-E-19-0&, Oiler j175j):
Avoided Fntironmental Costs and (hher Renefits
15. fuantify the polential value of grid stability, resiliency, and cybersecurity protection provided by on-site
generators as a clqss and different penetration levels.
16. Quontify the value to local public health and sofetyfrom reduced local impacts of global worming such as
reduced extreme temryratureq reduced snowpack voriation, reduced wildfire risk, and other impacts that cqn have
direct impacts on Roclry Mountain Power customers.
17. Quontify local economic beneJits, inchtding local job creation and increased economic activity in the immediate
service lerrilory.
18. Quanlify the possible net value of Renevtable Energt Credit sales produced by net metering exported energt
19. Quantify the reduced riskfrom end-of-life disposol concernsfor the Company compared tofossil-fueled
resources
503 W Franklin St, Boise, ID 83702
208-384-1023 | [e-mail]
www. sierraclub.orglidaho