20220720Comments(2)_2.pdf

July 19, 2022

Case ID: IPC-E-22-12

The Idaho Grain Producers Association (IGPA) appreciates the opportunity to provide brief
comments on Case IPC-E-22-12. With over 600 wheat and barley farm families as members, IGPA is
the key policy advocacy organization working on behalf of Idaho’s grain industry with local, state,
and federal leaders.

It is IGPA’s longstanding policy that Idaho’s farmers should be supported in their ability to
participate in renewable energy opportunities. Accordingly, we request that the PUC give strong
consideration to Clean Energy Opportunities’ petition to both increase the eligibility cap for
customer generation projects and to improve the predictability and stability of the export credit
value.

The current 100kW cap on irrigator projects imposes unnecessary costs on farmers who want to
invest in solar. Rather than being able to design, build, and connect a single site to match their
consumption, farmers are instead required to build multiple, smaller sites in multiple locations –
which is more expensive and less efficient for all parties involved. If a farmer is going to invest in
solar generation, we would ask that they be able to install an appropriately sized project to offset
their energy consumption.

IGPA noted in our 2020 letter to the PUC that, “the lack of clarity for the future of net metering for
irrigators provides no sideboards for operators to gauge the risk and return of such projects.” This
fact has been shown to have a profoundly negative impact on farmer investment in solar
generation. Improving the predictability and stability of export compensation rates is critical for
farmers. Providing growers with this much-needed transparency would support both irrigators’
interests in offsetting their sizeable power costs and Idaho Power’s need to supply energy to their
customers, as well as supporting the company’s stated goal of expanding their green-energy
portfolio.

In closing, we ask that you give favorable consideration to Clean Energy Opportunities’ petition.

Sincerely,

Lucas Spratling
President, Idaho Grain Producers Association
Idaho Public Utilities Commission
11331 W. Chinden Blvd.
Boise, ID 83714
July 19, 2022
Re: Case # IPC-E-22-12, petition to modify the 100 kW limit on solar for farms and businesses
Dear Commissioners,
In October 2020, our organizations submitted a joint comment on IPC-E-20-26 with the following
request:
“[W]e urge you to lift the arbitrary 100 kilowatt-per-meter cap on customer-owned solar
installations that creates significant financial and logistical barriers for farmers and business
owners who deserve the ability to invest in solar energy systems that are large enough to meet
their energy needs.”
With the new case before you on this matter (IPC-E-22-12), we now re-submit this same request and urge
you to a) not dismiss this petition and b) address this issue immediately and without delay.
We stand by our former comments about the critical importance of fair solar options for Idaho’s farmers
and business owners.
Respectfully,
Climate Action Coalition of the Wood River Valley
Conservation Voters for Idaho
Idaho Organization of Resource Councils
Portneuf Resource Council
Snake River Alliance
New signatories:
Idaho Chapter Sierra Club
Idaho Sustainability and Energy Coalition