20220712Comment(1)_1.pdf

From:Robert E. Rutkowski
To:Jan Noriyuki
Cc:Keith Abouchar
Subject:Idaho Power Releases Study Taking Aim at Rooftop Solar
Date:Tuesday, July 12, 2022 1:43:37 PM
Commissioners
P.O. Box 83720 Boise, ID 83720-007411331 W. Chinden Blvd. Building 8, Suite 201-ABoise, ID 83714Phone: [phone]Toll Free: 1-800-432-0369Fax: [e-mail]
Re: Idaho Power Releases Study Taking Aim at Rooftop Solar
Dear Commissioners:
Idaho Power submitted its long-promised "Customer Generation Study" tothe (IPUC) just over a week ago, continuing its efforts to reducerooftop solar accessibility and affordability for its customers.
The study — which was conducted by Idaho Power itself, Idaho's largestfor-profit monopoly utility corporation — shows that it is consideringreducing the current export credit rate of 8-10 cents per kilowatt hour(the same rate that customers pay for power) to 2.8-4 cents per kilowatthour, cutting the credit rooftop solar owners would receive for sellingtheir energy back to the grid by over 60 percent.
It seems like Idaho Power wants to be the only one to benefitfinancially from Idaho's energy transition. If approved by the IPUC,this will take away opportunities for families, business owners, orfarmers who want to produce their own renewable power to meet theirenergy needs and lower their energy costs.
In 2018, the IPUC ordered Idaho Power to “comprehensively study thecosts and benefits of on-site generation on ldaho Power's system […] andrelated issues of compensation for net excess energy provided as aresource to the Company.” Idaho Power proposed drastically lowering thesolar export price in 2019, triggering backlash from public and energyindustry professionals. The IPUC rejected those rates and ordered IdahoPower once again to conduct “a credible and fair study on the costs andbenefits of distributed on-site generation to the company's system.”Idaho Power finally submitted the study on the last day of June, 2022.
The study notably fails to address environmental impacts and societalbenefits of rooftop solar, despite previous promises to stakeholders asoutlined in its IPUC-approved Study Framework. The study left the"avoided environmental costs" section virtually blank, claiming theutility can't include "non-quantifiable and speculative values."
Idaho Power was disingenuous in agreeing to quantify the environmental,public health, and local economic benefits of individual-owned solar—andthen not doing so. By not including any of these critical metrics in its
study, its proposed export credit rates are far lower than they should
be, and it disregards the very real and measurable contributions of
solar owners in our communities in reducing pollution and creating greenjobs.
Many are disappointed in the low value that Idaho Power has placed oncustomer-owned solar. If the utility’s suggested values are accepted bythe Commission, families and business owners will be functionally unableto take part in the financial and environmental benefits of solar.
Idaho has over 1,500 workers in the renewable industry, including 693 insolar, according to a 2021 Department of Energy analysis. Idahoconservation groups put out a statement earlier this year promotingcommunity-owned solar, a vision of an alternative model of renewableenergy development that's less reliant on for-profit, investor-ownedutilities like Idaho Power and that results in more locally-based jobcreation and economic benefits.
The utility claims solar customers create "fairness" issues on theelectric grid, pushing infrastructure and administration costs on toother customers. However, more clean energy production by customersmeans the utility doesn’t have to build expensive new power plants andcan avoid other costs, thereby keeping utility rates lower for allcustomers. Multiple independent studies confirm that there arenet-positive economic benefits for all customers from rooftop solar,including recent studies in neighboring states of Wyoming and Utah.
Idaho Power should continue to buy energy from solar generators, likethe customers, at the same rate they charge them, as there are just asmany economic benefits to the utility and the power grid as there areimpacts. Customers who add renewable energy to their home andparticipate in net metering help Idaho Power meet their own clean energygoals. Our customers personally invest in new generation sources thatthe utility and rate-payers don't have to support and the excess energysent back to the grid helps to alleviate demand issues the utility faces.
If new rates are approved, customers who installed solar prior toDecember 2019 are able to maintain the current export credit rates over25 years, but new customers would face the less affordable rate.
The IPUC will review Idaho Power's study and open it up for publiccomment in the coming months. A final decision on lowered export creditrates could be made by the end of the year.
Yours sincerely,Robert E. Rutkowski
cc:Legislative Correspondence TeamLongworth House Office BuildingWashington DC [e-mail]
2527 Faxon CourtTopeka, Kansas 66605-2086P/F: 1 785 379-9671
Quotes
"Idaho Power should continue to buy energy from solar generators, likeour customers, at the same rate they charge them, as there are just asmany economic benefits to the utility and our power grid as there areimpacts,” said Josh Powell, CEO of Revolusun. “Customers who addrenewable energy to their home and participate in net metering helpIdaho Power meet their own clean energy goals. Our customers personallyinvest in new generation sources that the utility and rate-payers don'thave to support and the excess energy sent back to the grid helps toalleviate demand issues the utility faces."
“When someone provides clean power back to the grid from their solarpanels, they deserve to be adequately compensated by the utility,” saidMartha Bibb, a resident of Hailey who installed solar on her home. “Iinstalled solar to help the environment, and I’ve not regretted thatinvestment. Net metering [receiving an export credit rate equal to theretail rate] helped to defray the initial investment. I’m worried otherswon’t get that opportunity now.”