20211206Comments(2)_2.pdf

Please submit my comments to the Commissioners regarding the above referenced IPUC case.
Thank you,
Sincerely,
Charles Gains
[e-mail]
1721 E. Canova Dr.
Boise, Idaho 83706
208.830.3787

As a home owner and supporter of clean, safe, renewable, solar energy generation I 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 major power 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 for dam 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 has enjoyed 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 the annual 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 argument of 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 now being
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 that individuals 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 in development of its hydro-power i.e., licensing,
power harvesting, power generating, power wheeling, and distribution.
Charles Gains
Boise,
SOLAR POWER STUDY AND SURVEY QUESTIONS:
• What are the existing Solar Power policies and practices of IPCO, the IPUC, and private Solar
Generators been to date?
o What are the elements (permitting, contracting, roles and responsibilities, operating
conditions and responsibilities, uses and distribution of solar power, etc.)?
 What happens to existing 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 in or replacing a new technology
inverter in an existing system void the net-metering grandfathered agreement?
o What are the costs, benefits, demand, needs, relevant uses/consumption/delivery/
regulatory compliance/laws, and impacts e.g., climate, IPCO, etc?
o What are other PUCs, States, Power Companies, Public entities, and general population
programs 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 this region 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 generated power?
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. timed operating system cycles?
• What is an equitable rate balance when IPCO wants to charge customers for generation vs.
when solar generators create storable generation capacity for IPCO?
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 high reservoir
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
solar generator?
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 the
solar 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 of whether 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 happen unless 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 Should there 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 supplanting IPCO 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 generation cleanup 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-scale solar 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 power generation?
• Should businesses enjoy the same net-metering benefits as small solar generators?
o Ditto the above supplementary questions.
• Would promotion of a solar generation industry bring new jobs, technology, businesses to the
Idaho economy?