20211201Comments(27)_27.pdf

From:Kevin Bradshaw
To:Jan Noriyuki
Subject:Solar Panel Discussion
Date:Tuesday, November 30, 2021 6:09:57 PM
IPC-E-21-21
I am writing to express my support for solar energy panels for residential homes and being a part of "netmetering", environmental solutions to help with low carbon and no carbon emissions and economicbenefits.
It is a critical time to speak up for an electric grid that fosters energy independence, the creation ofgreen jobs, and the public’s best interests by growing solar use! The public has made it clear that individually-owned rooftop solar systems and other distributed energysystems should remain a viable economic and environmental solution for businesses, homeowners, andgovernment agencies.
We’ve seen Idaho residents demand this for a variety of reasons, including:
Idaho Power has a 100% clean energy goal - let the public join in and contribute to that goal with fairprograms
Customers of all types deserve programs that help make the right choice for their family’s energy use,ensuring pathways to universal access for all Idaho residents to participate in energy production
Local clean energy systems provide grid security and reliability while protecting our climate and publiclands from catastrophic events like wildfires
Distributed energy system owners should be fairly compensated for the services they provide andprograms should enable a local energy economy
Thank you for placing this into the discussion.Kevin
Kevin Bradshaw1193 Eastridge CirTwin Falls, ID 83301208-212-0265
From:William McCombs
To:Jan Noriyuki
Subject:Stand up for solar! Case Number: IPC-E-21-21.
Date:Tuesday, November 30, 2021 7:24:07 PM
Dear Idaho Public Utilities Commission Commission Secretary,
With the amount of Solar available in Idaho, it is an important player in Idaho’s clean energy
future! I have a significant investment in solar and want to expand. Having lived in Floridaand worked with Volusia county in emergency preparedness, I realize how important
emergency power can be from outages during hurricanes/tornados and fires as well as cleanenergy. The use of generators, etc during long term outages has its own issues that solar
doesn't have. Plus solar provides reserve energy that may not be available from other sources.
I would like the study to be fair, conducted by a neutral outside party and provide fair
compensation to those who have made this long term investment. A significant portion of mysolar goes to the utility that is not compensated.
Regards,
William McCombs 9925 ID-52
Horseshoe Bend, ID 83629
From:Rod Fonda
To:Jan Noriyuki
Subject:Stand up for solar! Case Number: IPC-E-21-21.
Date:Tuesday, November 30, 2021 9:15:32 PM
Dear Idaho Public Utilities Commission Commission Secretary,
My wife and I have had rooftop solar for 3 years, so we are grandfathered in. New solar
customers should have the same opportunities we had, at the same rates. Idaho Power may notthink it needs the power produced by rooftops, but the facts say otherwise. Last summer the
power grid was stressed; rooftop solar can help. Idaho Power wants to have clean powerwithin the next few years; replacing coal with hydroelectric is a step in the right direction, but
solar is much better environmentally than hydro. Ask the salmon! I attended the hearing inBoise in December, 2019. It was an impressive assembly of concerned Idaho citizens from all
walks of life, young and old, some prosperous and some not so prosperous. All had installedsolar for their own combination of reasons, but that decision involved weighing an uncertain
financial cost. To encourage solar--not to mention to stabilize the fragile solar installationindustry--it is very important that the rates people need to contemplate encourage them to take
the plunge and install solar. We should also be encouraging the power company to considersolar farms--we make far more solar power up in Blaine county, even in winter, than we do in
the California desert. There just is no excuse anymore to ignore what we can do for this planetwhen we power up from the sun!
Regards,
Rod Fonda PO Box 3649
Hailey, ID 83333
From:Claudia Fernsworth
To:Jan Noriyuki
Subject:Case # IPC-E-21-21
Date:Tuesday, November 30, 2021 9:20:09 PM
Claudia Fernsworth
8088 W Pocono Lane
Boise, ID 83714
Dear Commission Secretary,
I am an Idaho Power customer. It just makes sense to encourage as many people as possible to join in reducing our
dependence on non renewable energy sources. People contributing to Distributed Energy programs should be fairly
compensated .
From:Alex McKinley
To:Jan Noriyuki
Subject:Comment: IPC-E-21-21
Date:Tuesday, November 30, 2021 10:23:40 PM
Concerning case number: IPC-E-21-21

I am writing to the commission to ask that the cost benefit study of distributed generation
that is to be undertaken, be done so in a fair, transparent, and comprehensive manner. In
order for the outcome of this study to be considered a credible result it is imperative that the
full range of costs and benefits be accounted for.

IPC presupposes the result of the study in the initial application – “The Company's primary
objective of the study process is to establish a sustainable on-site generation offering that
limits subsidies by implementing a more equitable pricing and compensation structure.“ By
initiating the process with the assumption that the current on-site generation agreement is
not equitable, IPC demonstrates that they have a desired outcome that is not based on the
result of a thorough and unbiased study. Unfortunately, it now becomes the duty of the
commission to assure that the cost/benefit analysis is fair and comprehensive. IPC has done a
thorough job in their initial filing and subsequent comments of discussing the cost side of the
equation. The commission must ensure the benefits are included and weighted appropriately.

In comments, Idaho Power Company (IPC) spends a significant amount of time focusing on
billing structure, but this is intended to be a study of the cost and benefits of distributed
generation, not rate structure design. These are different items and IPC is putting the cart
before the horse because an informed rate design should result from the findings of the cost
benefit analysis. For example, a potential outcome of this study could be that costs and
benefits of distributed generation are different for different seasons/times of day/etc… If that
were the case, that could inform future rate design. Furthermore, rate design should not be
done when only considering one specific group of customers. In order to best fulfill their duty,
the PUC should advocate for an additional study to inform rate design over a wide range of
customer types (costs/benefits of rural vs. urban customers or full time vs. part time
customers, etc.., etc…, there are many groups that use electricity differently). The current
study should be a cost/benefit analysis, not a rate design.

An independent 3rd party designing and conducting this study with input from parties
involved would lend credibility to the outcome. Staff states, “if a third-party contractor does
perform the study, funding to conduct it and who will pay for it, customer generators or all
customers, will need to be identified.” This is true, but should not preclude a third party from
conducting this study. The idea that since IPC is happy to cover the cost of the study, it should
design and conduct the study, runs very contrary to the goal of a fair, balanced, transparent,
and legitimate cost/benefit study. The commission should strongly consider enlisting a third
party. In addition, within the current proposal the public cannot weigh in on the details and
specifics of how this study will be conducted. The details are complicated, but they are what
matter. In order for the study to be transparent a comment period after initial study design
should exist.

IPC is granted a monopoly and the PUC needs to ensure that the customers in IPC’s service
area are treated fairly, that begins with a study which includes the benefits of distributed
generation. When biased cost/benefit studies of customer generation are conducted, the
result has a chilling effect to the growth of customer generation. IPC continually touts the goal
of 100% renewable generation in advertising. In the most recent Integrated Resource Plan
(IRP) IPC has a substantial portion of the preferred portfolio assigned to solar. IPC obviously
sees the value of solar generation, but the PUC needs to make sure that the value of
distributed generation is accounted for in this study. IPC seems to frame the issue as
customers with distributed generation vs. customers without distributed generation. The PUC
however should not see these as different groups. Customers currently without distributed
generation are very likely customers who in the future will have distributed generation or will
benefit from those who do.

Many of the interveners have provided significant resources designed to help the commission
appropriately value the benefits of distributed, customer owned, generation. IPC however has
provided only cursory mention of environmental and other benefits with no detail as to what
would be included in a study. The study should be designed to value benefits such as:
• How distributed solar generation adds to the reliability and resilience of our power grid. The
importance of this will only grow as our region experiences more droughts, heat waves,
wildfires, and other events that stress the network. We saw this first hand this past summer.
• Investment in distributed generation by customers reduces Idaho Power’s need to invest in
their own centralized production facilities. This saves all customers money in the long run.
• Customers with solar can have predictable electricity bills for years to come. As our region
grows and weather events impact the price of electricity more frequently, solar can help
individual customers maintain affordable utility bills.
• Producing clean energy at a local level can help IPC meet the stated goal of 100% clean
energy by 2045.
• Local electricity production reduces the need for Idaho Power to purchase electricity from
other utility companies during high demand times.
• The majority of our state is currently experiencing “severe”, “extreme”, or “exceptional”
drought conditions. Diversifying our energy resources with distributed solar will help our
electricity system be more resilient and buffer us from future drought related price increases.
It will also make water available for other uses. Water is a scarce resource, especially in a
rapidly growing region.
• As previously stated, IPC’s most recent IRP proposes to add a great deal of solar, therefore
IPC sees a value in solar. Customers should be able to take advantage of this value, not only
the utility company.
• A robust and dynamic electric grid is important as homeowners rapidly adopt electric
vehicles. The PUC should consider the long-term negative ramifications of a biased
cost/benefit study. Electric F150s are not 10 years away, our grid is changing as this case plays
out. A biased study, that slows the transition to a dynamic power grid, will hurt all customers.

Over the last few years the public has expressed its alarm that the PUC may put IPC’s short
term financial benefit above the long term public good. It is time for the PUC to act on its
fundamental mission, which is to regulate utilities in Idaho. When doing so, the numerous
studies, both academic and private sector, that address methods for quantifying the value of
distributed solar should be the starting point. It is of great concern that conducting a fair and
balanced study has been left up to interveners and the community to push for, instead of
being the agreed upon foundation of this cost/benefit study. Many of the interveners have
made recommendations for methods of quantifying the benefits of customer owned,
distributed, renewable generation. I and other members of the community can supply both
commission and staff with literature reviews if the great variety of publicly available
information is not being used as the basis for study design.
Thank you for your work,
Alex Mckinley
1407 E. Jefferson
Boise, Idaho 83712
Idaho Power Customer
From:William Fowkes
To:Jan Noriyuki
Subject:IPC-E-21-21
Date:Tuesday, November 30, 2021 10:33:36 PM
I fully support net metering in Idaho. I have installed 18 solar panels at my home in Boise.The
most responsible thing I have done decades.I am an Idaho Power customer, the address is 4001 West Clement Road Boise Idaho 83704
William Fowkes2089723901
From:Jessica Cabral
To:Jan Noriyuki
Subject:Move toward a brighter future! Case Number: IPC-E-21-21.
Date:Tuesday, November 30, 2021 10:45:52 PM
Dear Idaho Public Utilities Commission Commission Secretary,
I want the rooftop solar valuation study to be fair so I can participate in the program and help
move Idaho towards a clean energy future! We must work together to ensure local, clean,customer-owned power is an option for all Idahoans.
Regards,
Jessica Cabral 2759 S Creek Pointe Ln
Eagle, ID 83616
From:Joel Stark
To:Jan Noriyuki
Subject:IPC-E-21-21
Date:Tuesday, November 30, 2021 10:45:56 PM
Hi, I tried submitting comment on Idaho Public Utilities Commission but the comment section wouldn't accept mycase number
here is my comment on Solar power possible changes:
A change to net metering could affect me by continuing to raise pricing making the
use of Solar unaffordable. And it's important to offset our usage and be
compensated fairly for power we send back to the grid.
If you need more than 25 KW of solar to meet those needs, an expansion to the limitof residential solar could help users.
A study on net metering should be conducted as such:
The study should be conducted by a third-party that is non-biased, not Idaho Power.
The study should consider not only the impacts solar has on the grid, but also how itbenefits the grid by adding resiliency and diversification.
thank you for the opportunity to comment
Joel Stark
From:Jeffrey Woodworth
To:Jan Noriyuki; Jan Noriyuki
Subject:Comments for IPC-E-21-21
Date:Tuesday, November 30, 2021 10:53:08 PM
Dear Secretary of the Idaho Public Utilities Commission:
The case comment form is cutting off my comments, so please submit the below comments:
Case Number: IPC-E-21-21
First Name: JeffreyLast Name: Woodworth
Address: 2522 E Plateau Dr.City: Boise
State: IDZip: 83712
Daytime Phone: [phone]Email: [e-mail]
Utility Company: Idaho Power
Comment:My goal in commenting is to encourage the Idaho Public Utilities Commission to adopt rulesthat incentivize good behavior and disincentivize bad behavior by solar and other customers. In the instant case, the Commission appears to be planning to lock in a framework that will beused to determine the export credit rate for solar customers. Accordingly, the Commission inthis case should choose a framework that will allow it to properly structure the incentives. While there has been improvement from the framework of IPC-E-18-15, the currentlyproposed framework still fails to incentivize good behavior in a number of instances andshould be restructured.
For context, I am a solar customer grandfathered under the final order in IPC-E-18-15. I donot currently own a solar battery, an electric car, nor power quality equipment. (By “powerquality equipment,” I am referring to equipment that removes harmonics or noise fromexported power, provides reactive power, or fixes similar such issues with exported solarpower.) I would consider purchasing a solar battery or power quality equipment to help thepower system if Idaho Power compensated for the benefits to the grid. I will likely buy anelectric car as my next vehicle, and I would consider using it to provide power to the grid attimes of peak demand if the technology and incentives exist to do so.
Problems with Avoided Cost Methodology
The existing proposal uses an avoided cost methodology. As I noted in IPC-E-18-15:
The purpose of the DSM avoided cost framework is to allow a utility companyto determine how to best invest money. As the name suggests, the DSM avoidedcost framework involves determining the amount of cost avoided by variousdemand-side interventions. The utility company can then determine how best toallocate their resources by comparing the cost avoided to the cost of thevarious interventions. This purpose does not suggest it is an appropriateframework for determining rate structures.
Solar customers exist in a monopsony and monopoly relationship with Idaho Powerand suffer from an information imbalance with Idaho Power. The study seeks toquantify every cost avoided and use this to determine the export rate. This requires
proving a negative and any error works against the solar customer. The study shouldinstead quantify the benefits provided by the solar export, quantify the actual costincurred by Idaho Power handling solar exports, and subtract the costs from thebenefits. Note that Idaho Power receives full price compensation from a solar owner’sneighbors for exported solar power with no capital outlay and minimal usage of thegrid. Idaho Power can also sell renewable energy credits to receive additional incomefor the exported energy, and the exported energy helps Idaho Power meet its net-zeropledge, which clearly has a business value to Idaho Power. Idaho Power should berequired to quantify what costs are incurred by Idaho Power in this situation anddeserve to be charged to solar customers to offset the many easily quantifiablebenefits. Costs related to solar customers consuming during times of peak demand orlow supply should be incorporated into the rate charged to solar customers forconsuming electricity, and the study should explicitly consider how to structure therate charged to solar customers (and/or other customers) for energy consumption inconjunction with the export credit rate rather than trying quantify every issue in thecalculation of the export credit rate.
One important benefit of this reframing is that it requires a proper accounting of howto divide up costs of issues like the duck curve. The duck curve is a problem of peakdemand and peak supply being misaligned. Part of this problem lies with solar energynot aligning with demand patterns, but part of the problem also lies with the demandside using energy when it is not most prevalent. Any methodology that holds solarproviders solely responsible for the costs of providing peaking power will not properlyincentivize solar adoption and also not properly disincentivize the use of power duringtimes of peak demand. The study should be required to propose how much of the costsof peaking power should be charged to demand customers and how much, if any, tosolar customers. (Solar customers can be charged for the costs of peaking power byadjusting the rate charged to solar customers for energy consumption rather thanadjusting the export credit rate.)
Form of Credit
The staff argues that the export credit rate should be a price-per-kWh credit and not a kWhcredit. The price-per-kWh credit would vary based on the time of day. While I would supportinstantaneous net metering and even dynamic pricing that varies based on experiencedconditions as the best way to incentivize good behavior, it will create subsidies among classesif only solar customers are subject to such a system. Solar customers would bear the full bruntof the demand-supply mismatch while other customers would get to pay the same price forenergy when it is plentiful and cheap as they would when it is scarce and expensive. Theother customers are subsidized in their purchase of energy at times when it is expensive, andthere is no incentive for them to reduce consumption at times of peak demand. The studyshould quantify the subsidy from solar customers to other customers when a price-per-kWhregime is used for the export credit rate (e.g., the price varies throughout the day), but theimport rate charged to other customers is constant throughout the day. Alternatively, the studyshould consider how to set the export credit rate in a regime in which other customers arecharged for consumption at rates that vary based on the time of day and prevalence of energy.
Firm vs. Non-Firm Power
I very much agree with comments from the staff that the study should consider the impact ofbatteries. The export credit rate should be designed to incentivize battery usage and to smooththe duck curve. My concern is that the staff seemed to be suggesting that solar customerswould be classified as firm or non-firm with firm customers receiving a fixed, higher rate andnon-firm customers receiving a fixed, lower rate. Such a cliff edge would not optimallyincentivize the delivery of power to the grid when it is most needed. It would be better to use
pricing to encourage delivery of power when it is needed. For example, electric vehicles areunlikely to be a source of firm power because they may not always be connected to the grid. Nonetheless, it would be good to properly compensate and incentivize customers having non-firm sources of power, such as electric vehicles, to deliver energy to the grid when it is mostneeded. The study should consider whether incentivizing delivery of energy at the right timesthrough variable pricing mitigates the need for a discount due to lack of firmness. The studyshould also consider what technology is available to assist with firmness (e.g., technology tocommunicate how much energy is available from storage systems and/or to allow forcommunication to energy storage systems of dynamic pricing or requests from Idaho Powerfor the energy). The study should consider whether pricing incentives and/or technology canresolve firmness issues in the aggregate.
Power Quality
Little has been said regarding the issue of power quality. Like with batteries, power qualityequipment provides additional benefits to the system and allows Idaho Power to avoidinstalling power quality equipment. The study should consider the costs imposed due to poorpower quality and whether different rates should be charged to customers with power qualityequipment versus those without. (It is not clear whether it would be more efficient for IdahoPower to pay for installing power quality equipment or solar customers, but setting a ratewould make it clear who can most efficiently bear this burden. It would also incentivize goodbehavior by solar customers if they can most easily bear the burden.)
Final Notes
Solar and battery costs continue to fall while the world continues to get more serious aboutreducing carbon emissions. This creates a perilous situation in which we must get theeconomics and incentives right to maintain a healthy grid. If the result of the study andeventual rate setting is that solar customers are inadequately compensated and forced tosubsidize the bad behavior of other customers, it will encourage solar customers to choosesystems that allow them to go off the grid. Idaho power will end up with a shrinking customerbase just as it needs that base to fund decarbonization effort. This could create a death spiraldynamic in which higher costs cause more customers to flee the grid, which further raisescosts on the remaining customers, who may be least able to bear the cost. The Commissionshould select a study framework that ensures solar customers are adequately compensated andare only charged for the actual costs imposed on the company (plus a reasonable profit) andthat properly incentivizes increased supply and decreased demand at times of peak demand.
From:PUCWeb Notification
To:Jan Noriyuki
Subject:Notice: A comment was submitted to PUCWeb
Date:Wednesday, December 1, 2021 8:00:10 AM
The following comment was submitted via PUCWeb:
Name: Vanesa Perkins
Submission Time: Dec 1 2021 7:19AMEmail: [e-mail]
Telephone: [phone]Address: 3150 S Mystic Seaport Ave
Nampa, ID 83686
Name of Utility Company: Idaho power
Case ID: IPC-E-21-21
Comment: "My name is Vanesa Perkins and I am an Idaho Power customer living in Nampa. I am a long time resident of Nampa. My husband and I have 3 kids together and have raised our
children in the Nampa area. We enjoy the outdoors and during winters enjoy having movie night at the house every weekend! My husband and I travel to Boise for work and it is
amazing to see the increase in people and traffic in our area. I care about supporting fair solar options for Idaho customers because we have thought about going solar but had a really hard
time making a decision due to net metering and if it will be worth it. We want to make sure that we are doing our part for the environment and others with helping the power grid. We
want to ensure that those that are helping are fairly compensated for their efforts and long term costs associated with solar. Solar has made a huge impact on sustainability. Idaho Power was
probably not predicting to have an increase of people moving to the valley at an unusually high rate so it is presumed that our grid is not currently able to handle the load without help. It
is vital to make sure those that are doing their part to help the grid is treated fairly for their efforts to help Idaho Power and the grid in the valley. Please direct Idaho Power to conduct a
fully comprehensive study of solar so that customers can be fairly compensated for all the value they’re providing to our environment, economy, and families. This study should be
conducted publicly and transparently by a non-biased third-party and evaluate the sustainability, efficiency and resilience that solar adds to the grid."
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From:Fred Reed
To:Jan Noriyuki
Subject:IPC-E-21-21
Date:Wednesday, December 1, 2021 10:07:29 AM
Dear Idaho PUC Secretary,
I am writing to express my desire that the PUC mandate Idaho Power offer a net metering
pricing that provides a fair and reasonable incentive for customers to invest in distributed solarsystems.
The urgency of getting to 100% clean energy is getting more obvious by the day. The public
should be encouraged to join in and contribute to Idaho Power's 100% clean energy goal - andhopefully accelerate its achievement (2045 is almost a quarter of a century away!). In
addition, local clear energy systems provide important grid security and energy independence.
Fred Reed410 E Old Saybrook Dr
Boise, Idaho 83706
From:Cameron Wagner
To:Jan Noriyuki
Subject:Case # IPC-E-21-21
Date:Wednesday, December 1, 2021 1:32:52 PM
Cameron Wagner
4198 Spring House Drive
Eagle, ID 83616
Dear Commission Secretary,
I am an Idaho Power customer and I want clean energy choices that will make it financially practical to go solar. I
call on the Idaho Public Utilities Commission to ensure solar has a fair market valuation. This would help all
Idahoans by creating resilient local grid systems, reducing transmission line impacts on wildfires and wildlife
ecosystems, growing the clean energy economy, creating good-paying local jobs, and helping Idaho Power meet its
100% clean energy goals.
From:PUCWeb Notification
To:Jan Noriyuki
Subject:Notice: A comment was submitted to PUCWeb
Date:Tuesday, November 30, 2021 5:00:05 PM
The following comments were submitted via PUCWeb:
Name: Bradley Smith
Submission Time: Nov 30 2021 4:43PMEmail: [e-mail]
Telephone: [phone]Address: 2983 N Tattenham Ave
Boise, ID 83713
Name of Utility Company: Idaho Power
Case ID: IPC-E-21-21
Comment: "I have been a student of electrical power for over 60 years. I hold a degree inPhotovoltaics, am a licensed Electrician, certified electric car mechanic, and a 35 year veteran
of the entertainment industry as a stage electric, and special events power engineer. I am also aremodel contractor, and am heavily engaged in updating the electrical backbone, and systems
in residences in the state of Idaho. We are also the owners and drivers of two electric cars, andwe install charging systems for electric cars. To put it succinctly, the local grid, and regional
grids in the state of Idaho cannot support the conversion to electric heat pump heating systems,demand hot water systems, and the charging of electric vehicles. When you factor in the
summer afternoon demands of air conditioning houses and business, commercial buildings,you have a perfect storm brewing. Local, community and microgrid PV energy systems and
storage are a necessity of the grid of the near future, or we face massive shortages, and hugeinfrastructure improvement projects for the next few decades. Don't take my word for it, just
do the math. When properly weighted by the costs of the upgrades that would be required touse the grid essentially one way, the value of local, end of line solar becomes clearer. An hour
by hour, minute by minute valuation of electrical power is easy to get started, and once thoserates are established, a valuation of the costs of maintaining the grid and the operating costs of
the electric utility can also be established. There are plenty of outside consultancy think tankssuch as the Rocky Mountain Institute that can assist utilities with the math of these
projections. Only by establishing value at time of use and generation, can we get the rates forgeneration matched up with the rate of the demands. Local, community, microgrid and
personal rooftop solar is a critical component to make the grid stronger, more resilient, andmore reliable. Let's get the math, the rates based on true value and costs right, and build the
grid of the future, together. Sincerely, Bradley Hillock Smith Proud resident of the great stateof Idaho "
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Name: Mary Hunter
Submission Time: Nov 30 2021 4:49PMEmail: [e-mail]
Telephone: [phone]Address: 173 N Sierra View Way
Eagle, ID 83616
Name of Utility Company: Idaho Power
Case ID: IPC-E-21-21
Comment: "I am writing to ask the IPUC to move toward a future where people can reduce their carbon footprint by installing solar panels. It is ridiculous that the power from the sun is
not being utilized to generate the electricity we all need. I am not on top of the proposed study that Idaho Power is trying to do but ask you to move toward a future including more solar, and
wind power while reducing demand for hydrolic power and coal. Water is becoming more scarce but there is plenty of sun and wind. As a society, we need to work in the direction of
using clean energy and Idaho Power can play a role in that by managing the system while as many of us as possible can be generating the power that Idaho Power can then distribute as
needed. I make more electricity than I use and Idaho Power gets to sell it to others. Let us continue to build in that direction as a society. Thank you. Mary Hunter"
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Name: Laurie Zuckerman
Submission Time: Nov 30 2021 4:21PMEmail: [e-mail]
Telephone: [phone]Address: 3909 W. Camas St.
Boise, ID 83705
Name of Utility Company: Idaho Power
Case ID: IPC-E-21-21
Comment: "I would like the PUC to create a strong incentive program for distributed solar because our summers will continue to have periods of intense heat. Homes and businesses
need to be able to help provide power during these high-usage times. It's no longer a luxury; it's critical for survival and economic growth. "
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From:PUCWeb Notification
To:Jan Noriyuki
Subject:Notice: A comment was submitted to PUCWeb
Date:Wednesday, December 1, 2021 7:00:08 AM
The following comments were submitted via PUCWeb:
Name: Charles Gains
Submission Time: Nov 30 2021 7:36PMEmail: [e-mail]
Telephone: [phone]Address: 1721 E. Canova Dr.
Boise, ID 83706
Name of Utility Company: self or individual
Case ID: IPC-E-21-21
Comment: "As a home owner and supporter of clean, safe, renewable, solar energy generationI want to comment on the solar energy case before the PUC. This includes the totality of the
energy needs within the IPCO service area. This geographic area is unique in that the majorpower source of energy has been hydro-generated power, a natural resource of this region.
IPCO has had a monopoly of this natural resource. IPCO has enjoyed exclusively charging fordam licensing, power harvesting, power generating, power wheeling, and distribution to its
customers within its geographic service area. In return for its firm delivery of power IPCO hasenjoyed guaranteed returns on its investments and profits. Enter the advent of solar generated
power. The IPUC, not the IPCO, seeing the potential and the need for alternative, renewable,clean energy promoted the concepts of solar energy through its net-metering program. At that
same time solar was seen as an answer to reduction of “peak demands” at the time in theannual hydro power generating cycle (in late summer when irrigation power was in high
demand and generating capabilities was waning). Today, we are again engaged in an argumentof who controls, is entitled to, and “owns” the power generating resource – The SUN. The
same complicated arguments about costs and ROI that IPCO has made in the past are nowbeing made by the individuals investing in their own solar exploits. IPCO has devised policy
and made lop-sided arguments that it is entitled to returns on solar generation investments thatindividuals spend. The only way to settle this dispute is to make study (Solar Study) of the
facts, operations, costs, etc. involving the same power elements IPCO has enjoyed indevelopment of its hydro-power i.e., licensing, power harvesting, power generating, power
wheeling, and distribution. Charles Gains Boise, "
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Name: Jesse SimpsonSubmission Time: Nov 30 2021 5:20PM
Email: [e-mail]: 208-501-5417
Address: 2708 S Inverness Way Boise, ID 83705
Name of Utility Company: Idaho Power
Case ID: IPC-E-21-21
Comment: "Dear IPUC, I have been involved in rate cases involving customer generation over
the past 8 years and have experienced Idaho Power's attempt to degrade the adoption rate ofprivately owned renewable energy year after year. We appreciate the decisions made on prior
cases and in 2019 to protect Idahoans. We welcome a fair and thorough study so that thepurgatory period of solar investment comes to an end. I request this study include how much
money private Idahoans have invested into renewable power generation since December 2019and evaluate increased capacity to the grid this has brought to the State. How much money
would Idaho Power have had to spend and pass onto rate payers for similar renewablegeneration capacity. The private sector has taken this burden and in turn they are rewarded
with owning the power they produce. It is clear that Idaho Power wants to reverse thisopportunity to protect profits and share holders. Thanks for overseeing a fair study to protect
Idahoans and to allow for fair customer generation policy going forward. "
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Name: Malcolm WilsonSubmission Time: Nov 30 2021 9:12PM
Email: [e-mail]: 801-652-3866
Address: 563 East Fork RoadHailey, ID 83333
Name of Utility Company: Idaho Power
Case ID: IPC-E-21-21
Comment: "My name is Malcolm Wilson and I am an Idaho Power customer (account No.s
2225530407 and 2225530472) living in Hailey, Idaho. I recently retired from the Bureau ofReclamation as a Water Resource Manager and purchased a retirement home near our
grandson in Triumph outside of Hailey which I am working on restoring. My wife works at ahospital where they see significant numbers of cases of pulmonary diseases due to air quality.
As a result of my work with Reclamation, I am very aware of the impacts that climate changeis having on our runoff and resulting hydropower production in the West. I am also very aware
of the effects of burning fossil fuels in contributing to climate change and the resulting effectsupon our air quality and its contribution to poor health. I care about supporting fair solar
options for Idaho customers because I believe that we as individuals, businesses and societyneed to make concerted efforts to move away from fossil fuel sources of electricity to reduce
climate change for our health, for our children’s health and future and for the planet, even if itcosts individuals and businesses more up front. I would like to install solar power panels for
those reasons. Central Idaho is a prime place for the development of solar energy. Even withnet metering however, It will be a significant personal investment to install solar on our home.
The cheaper approach for me would be to just continue to rely solely on commerciallyproduced power from the grid. I believe that companies such as Idaho Power can, and should
step up and make their contribution by making options such as net metering available to theircustomers. I believe it is in the interest of Idaho and its citizens for the Public Utilities
Commission to conduct a non-biased, third-party and transparent study considering the fullbenefits of net metering and costs (health, contribution to climate change, etc.) of relying on
fossil fuel power production. Please direct Idaho Power to conduct a fully comprehensive
study of solar so that customers can be fairly compensated for all the value they’re providingto our environment, economy, and families. This study should be conducted publicly and
transparently by a non-biased third-party and evaluate the sustainability, efficiency andresilience that solar adds to the grid. Thank You Sincerely Malcolm Wilson "
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Name: Mary Anne Saunders
Submission Time: Nov 30 2021 9:45PMEmail: [e-mail]
Telephone: [phone]Address: 2230 Schreiner Lane
Star, ID 83669
Name of Utility Company: Idaho Power
Case ID: IPC-E-21-21
Comment: "It is with dismay that I learned of the proposal to essentially delete net zero forhome solar installations and put in its place a pittance credit. That you would give such a plan
serious consideration flies in the face of our planet's desperate need to address globalwarming. I actually thought you saw the critical need to leave an intact planet for our
grandchildren. We must have public policy that encourages expansion of crucial alternativeenergy. This proposal changing the formula discourages such expansion. Further, it will
seriously penalize those who already have installed solar panels. The implications of yourdecision on this matter are substantial - do you support alternative energy development at all
levels or do you not? Making this change will defeat such development.. I had carefullyconsidered installation of solar panels on my home this past year.. As currently structured, the
incentives' costs are high yet the payback is considerable for the environment. If you approvethis change it will bring a halt to solar conversion by homeowners in our state and eliminate
the benefits of homeowner participation.. ."
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Name: Burton SmithSubmission Time: Nov 30 2021 9:33PM
Email: [e-mail]: 208-308-3535
Address: 2651 E 4000 NTwin Falls, ID 83301
Name of Utility Company: Idaho Power
Case ID: IPC-E-21-21
Comment: "Honorable PUC Commissioners, I am a proponent of home solar electricity
generation. I want to see a continued strong incentive program in place for this type ofdistributed power. It only makes sense that we take advantage of the footprints on the land that
we have already created, our homes. With strong incentive programs, more homeowners willbe motivated to become part of the solution to our climate change woes by installing clean
solar energy generation. The study that will be undertaken by Idaho Power needs to be donefairly and with complete transparency. If this is done I am certain that the conclusion will be
one that continues to provide an incentive to homeowners and is fair to Idaho Power. Withmore homeowners participating in solar generation, we all benefit by way of less carbon
dioxide emissions, cleaner air, less mining for coal and natural gas, and we take advantage ofusing the footprints on the land we have already created from the placement of the houses.
With more household solar generation, electricity can flow from house to house, business tobusiness, thus fewer transmission lines will be needed because the amount of centralized
electricity generation will be reduced. This will create more efficient transport of electricity asthe current loss of electricity due to resistance will be reduced. I have enjoyed generating solar
power on my rooftop since 2015. I would like to expand my array so when I purchase an EVvehicle I can use the sun to power my car. How exciting if all can do this. As we look to the
future, EV vehicles will be the norm; homeowners should be incentivized to be able to userooftop solar to charge their cars of the future and their home as well. Please seriously
consider my comments as you make your decisions about the equity of rooftop solargeneration. Increased rooftop solar is good for our economy, it is good for energy
independence, it is good for the creation of jobs, it is great for our environment. All of thesethings are in the best interest of our citizenry. Thank you. Burton Smith "
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Name: Carol Ogburn
Submission Time: Nov 30 2021 9:02PMEmail: [e-mail]
Telephone: [phone]Address: 4261 E Vacheron St
Meridian, ID 83642
Name of Utility Company: Idaho Power
Case ID: IPC-E-21-21
Comment: "I strongly support the PUC proposed cost/benefit analysis related to customer andsolar power usage. PUC's analysis would give a clear transparency and accountability public
interest message . I further promote the ENCOURAGEMENT OF SOLAR POWER : 1. it is anatural for the Idaho climate/ 2. solar energy is a win/win for both Idaho Power and the
customer - both contributing to the control of climate change/ i.e. saving the planet and futuregenerations/ 3. solar energy is needed for the increase use of electric energy - electric cars and
the reduction in fossil fuels/ 4. buying back extra solar from customers is a second win/win -Idaho Power shows respect for customer-the planet-and its own conscious future-thinking
business practice and Idaho Power gets energy it doesn't have to create."
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Name: Alyson MartinSubmission Time: Nov 30 2021 11:16PM
Email: [e-mail]: 208-484-3241
Address: 3716 E Timbersaw DrBoise, ID 83716
Name of Utility Company: Idaho Power Company
Case ID: IPC-E-21-21
Comment: "Climate change can no longer be denied or ignored. Our atmosphere is being
altered by greenhouse gas emissions which will remain there for generations. I bought myresidential solar array solely reduce my GHG emissions in an effort to do my small part to
address the climate crisis. It is imperative that Idaho Power and the IPUC recognize theurgency of this crisis and take all steps possible to reduce GHG emissions. This crisis
threatens the existentence of all life on Earth. Please face this reality and think of our childrenand their children in your decision-making. Profits will be of little consolation when the Earth
is no longer livable."
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Name: Theresa KaufmannSubmission Time: Nov 30 2021 10:16PM
Email: [e-mail]: 208-252-4464
Address: 4977 Clearview AvePocatello, ID 83204
Name of Utility Company: Idaho Power
Case ID: IPC-E-21-21
Comment: "I am a homeowner in Pocatello and had rooftop solar panels installed in the
summer of 2019. I did this as one way to address the critical issue of climate change and a wayto assist Idaho Power realize their clean energy goal for 2045. It benefits the community in
many other ways by creatng jobs, economic activity and health improvements. I am urging theIPUC to conduct a solar study that is fair and credible and that takes into account all the
benefits and aspects of power generation. This should include an equitable and predictable ratestructure that will allow all to participate in their own power generation. Citizens also need
transparency and access to information that will help them make good decisions aboutparticipating in their own power generation. Thank you for your consideration."
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Name: Charles Gains
Submission Time: Nov 30 2021 9:48PMEmail: [e-mail]
Telephone: [phone]Address: 1721 E. Canova Drive
Boise, ID 83706
Name of Utility Company: Idaho Power
Case ID: IPC-E-21-21
Comment: "SOLAR POWER STUDY AND SURVEY QUESTIONS: • What are the existing
Solar Power policies and practices of IPCO, the IPUC, and private Solar Generators been todate? o What are the elements (permitting, contracting, roles and responsibilities, operating
conditions and responsibilities, uses and distribution of solar power, etc.)? What happens toexisting solar installation agreements (e.g. net metering) if the solar system is repaired with
system upgrades or new technologies before any contract rights expire? E.g. would putting inor replacing a new technology inverter in an existing system void the net-metering
grandfathered agreement? o What are the costs, benefits, demand, needs, relevantuses/consumption/delivery/ regulatory compliance/laws, and impacts e.g., climate, IPCO, etc?
o What are other PUCs, States, Power Companies, Public entities, and general populationprograms doing about solar power design, generation, distribution, policy, around the
nation/world? o What are the existing laws regarding solar power rights and regulation in thisregion and others? • Who owns and has the rights to solar power i.e. who is entitled to the
design, generation, limits, operation of, use of, distribution of, and future of solar generatedpower? o What are the differences between large-scale, single-point-power generation and
distribution of existing plant systems vs. solar generation? o What are the needs of the end-users (customers)? What are the projected chronological generating abilities and demands
of customers in this and other service regions, e.g., MWH generating and demands vs. timedoperating system cycles? • What is an equitable rate balance when IPCO wants to charge
customers for generation vs. when solar generators create storable generation capacity forIPCO? o If IPCO saves $1 in avoided cost due to solar generation, should it return that $1 to
the customer? o If a solar generator supplants the need for IPCO to generate power at highreservoir capacity time of year and IPCO can save that capacity until August (a low reservoir
capacity time of year) should IPCO rebate that actual cost of generation to the solar generator?o If solar generators negate need for long-distance wheeling costs, step up and step down and
line-loss transmission costs, should IPCO rebate those actual avoided costs to the solargenerator? o If solar generators produce excess power during high-demand periods and IPCO
sells that power to nearby customers should IPCO rebate the higher KWH sales rate to thesolar customer? o Should solar generators be entitled to ROI when returning power to the
IPCO grid? • Should solar generators be entitled to operate their own systems regardless ofwhether IPCO is delivering power? o Technology now exists for solar generators to use solar
power when the power grid is inactive, but current switching does not allow this to happenunless the solar system is not an IPCO customer. Is this equitable? o Under what conditions
should the solar generator be allowed to operate independent from the IPCO grid? o Shouldthere be a limit to the size of system solar generators can operate? o Should there be a limit to
the size of storage a solar generator is allowed to install? • What is the value to supplantingIPCO coal-fired generation with solar generation? o Should reducing CO2 emissions be
embedded in the IPCO rate as an avoided cost? o Should imputed coal-fired generationcleanup costs be included as an avoided cost due to solar generation? • Should governmental
agencies enjoy the same net-metering benefits as small solar generators? o Cities, counties,school districts, State agencies, Parks, Universities, etc. could reduce taxes if they could lower
their power bills. Should IPCO give the same rebates to these agencies as other small-scalesolar generators? o Should cities, counties, school districts, State agencies, Parks, Universities,
etc. have the right to choose whether it wants to use IPCO power or its own solar powergeneration? • Should businesses enjoy the same net-metering benefits as small solar
generators? o Ditto the above supplementary questions. • Would promotion of a solargeneration industry bring new jobs, technology, businesses to the Idaho economy? "
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Name: Frederick Belzer
Submission Time: Nov 30 2021 8:17PMEmail: [e-mail]
Telephone: [phone]Address: 4977 Clearview Ave
POCATELLO, ID 83204
Name of Utility Company: Idaho Power
Case ID: IPC-E-21-21
Comment: "Re: Idaho Power Solar Case Study I am a Pocatello homeowner with rooftop solarpanels since 2019 and I participate in net metering. I urge that this study be undertaken by an
independent entity rather than the regulated business. I am interested in expanding my rooftopsolar panels but I am concerned that I will not be treated fairly by Idaho Power in setting the
net metering rate by considering the full range of costs to the homeowner and benefits to IdahoPower and the public of home generation of clean renewable energy. "
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Name: Daniel Hartigan
Submission Time: Nov 30 2021 6:20PMEmail: [e-mail]
Telephone: [phone]Address: 267 e schmeizer Ln
Boise, ID 83706
Name of Utility Company: Idaho Power
Case ID: IPC-E-21-21
Comment: "Dear Commission, I’m writing in regards to the upcoming Idaho Power study ofon-site generation. I am an Idaho Power customer. I am intending to purchase solar and
storage before the completion of the study process. I have several thoughts on the process.First, as it seems clear that Idaho Power will be conducting the study, an independent audit
conducted by a reputable knowledgeable group should follow. The review should not be left tostrictly public comment. I know I certainly do not possess the experience or expertise to
perform such a task. Second, on-site generation is broader than solar. The study should fairlyand equitably include all types of on-site generation and grid supply including storage. When
considering on-site generation we should be forward looking to new technologies such asElectric Vehicle battery grid tie or any other soon available capabilities. I would encourage the
Commission to avoid making this just a solar study. Third, keep aware in this process thatother regions of the country have not only chosen to maintain net metering but added
incentives from the utility company to their customers for installing clean energy production.It seems likely Idaho Power could encourage on-site clean energy production through policy
and still meet their financial needs. Finally, as I read Idaho Power’s proposal and listened totheir online public workshop, one recurring thought was I wish I could drop these guys and get
a new power company. It turns out, at least in Idaho, I can’t. Since we’re all in this together,let’s make it equitable for all. Regards, Daniel Hartigan"
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Name: Patti Raino
Submission Time: Nov 30 2021 8:27PMEmail: [e-mail]
Telephone: [phone]Address: 4905 W Outlook Ave
Boise, ID 83703
Name of Utility Company: Idaho Power
Case ID: IPC-E-21-22
Comment: "My name is Patti Raino and I am an Idaho Power customer living in Boise. I am retired, raised two children in Idaho and love my state and have concerns about climate change
impacting my family. I care about supporting fair solar options for Idaho customers because it is important to use encourage and use solar generation to help mitigate the impact of climate
change. I installed solar in my home this past year and find it exciting to think that I am making an impact clean air. I would like to see more of my neighbors use solar and it’s cost
effectiveness through net metering is important in increasing it’s usage. Please make sure the Idaho Power study on net metering looks at the importance of growing and sustaining solar on
Idaho homes and businesses. "
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