20221011Comments(13)_13.pdf

From:PUCWeb Notification
To:Jan Noriyuki
Subject:Notice: A comment was submitted to PUCWeb
Date:Saturday, October 8, 2022 10:00:07 AM
The following comment was submitted via PUCWeb:
Name: Scott Neumann
Submission Time: Oct 8 2022 9:57AMEmail: [e-mail]
Telephone: [phone]Address: 217 Willoway Rd.
Hailey, ID 83333
Name of Utility Company: Idaho Power
Case ID: IPC-E-22-22
Comment: "We should encourage the adoption of residential solar by compensation for generation at reasonable rates. the proposed rate of 3.8 cents would discourage the adoption of
a truly renewable energy source."
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From:PUCWeb Notification
To:Jan Noriyuki
Subject:Notice: A comment was submitted to PUCWeb
Date:Saturday, October 8, 2022 5:00:08 PM
The following comment was submitted via PUCWeb:
Name: tamar dolgen
Submission Time: Oct 8 2022 4:02PMEmail: [e-mail]
Telephone: [phone]Address: 205 Sutton place
Ketchum , ID 83340
Name of Utility Company: Idaho power
Case ID: IPC-E-22-22
Comment: "I currently do not have solar power but I am thinking about it and believe that it is important for energy sustainability for our state. Please do not reduce the rate to buy back
solar energy. It’s important to keep the higher rates as an incentive for homes to move to solar. "
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From:Ann Swanson ([e-mail]) Sent You a Personal Message
To:Jan Noriyuki
Subject:IPC-E-22-22 Public Comment
Date:Saturday, October 8, 2022 7:45:58 PM
CAUTION: This email originated outside the State of Idaho network. Verify links and attachments BEFORE you
click or open, even if you recognize and/or trust the sender. Contact your agency service desk with any concerns.
Dear Idaho Public Utilities Commission,
Dear IPUC,
I invested in solar panels for my home several years ago. Idaho Power is trying to shortchange those who changed
to solar, claiming the compensation rates are now too high. This was the conclusion of their own study.
Crossborder's study shows Idaho Power often used outdated data and made poor assumptions to arrive at lower
compensation rates. The company also neglected to include benefits such as the long-term hedge against volatile
natural gas prices and avoiding the rate impacts of carbon emissions, resulting in artificially lower values that will
ultimately discourage locally-owned solar.
We should be doing everything to ENCOURAGE solar and alternative energy. A decrease in rates would
disincentivize this choice.
Thanks,
Ann
Please look carefully at the independent study conducted by Crossborder Energy, which points out several
shortcomings in Idaho Power's own study on the costs and benefits of customer-owned rooftop solar. Idaho Power
will use this study to justify trying to reduce compensation rates to solar owners. To arrive at fair rates, we first
need a fair study.
Crossborder's study states, "We conclude that Idaho Power?s choice of assumptions and calculation methods
significantly undervalue the five components that the utility quantified. We present our own calculations of an ECR
with these five elements. In addition, the VODER Study fails to quantify important benefits of distributed solar that
the Commission directed the utility to analyze in Order No. 35284 -- benefits that are known and measurable, will
impact rates, and will benefit Idaho ratepayers and citizens.?
Idahoans deserve solar rates based on a more fair and complete analysis. I urge you to reject Idaho Power's study
and look to Crossborder's study as a more accurate measure of the value (to ALL ratepayers) of customer-owned
solar power.
Sincerely,
Ann Swanson
2161 Diane Lane
Pocatello, ID 83201
[e-mail]
[phone]
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If you need more information, please contact Lillian Miller at Sierra Club at [e-mail] or (415) 977-
5500.
From:LISA HECHT
To:Jan Noriyuki
Subject:Case Comment: IPC-E-22-22
Date:Sunday, October 9, 2022 11:59:09 PM
Attachments:Comments for IPC-E-22-22.docx
CAUTION: This email originated outside the State of Idaho network. Verify links and attachments BEFORE youclick or open, even if you recognize and/or trust the sender. Contact your agency service desk with anyconcerns.
Dear PUC,

My comments on Case IPC-E-22-22, the Idaho Power VODER study, are
attached.

Respectfully,

Lisa Hecht
4920 E Sagewood Drive
Boise, ID. 83716

Comments for IPC-E-22-22

10/9/22

Who I am and my perspective:
My name is Lisa Hecht. I live at 4920 E. Sagewood Drive in Boise, Idaho. I have been an Idaho
Power customer since 1980, a shareholder since I was 3 years old, and an IRP attendee for
about 10 years. My degree was in Electrical and Computer Engineering.

What isn’t in the study and should be:

Value of Reduced Risks:
• Climate change impacts (e.g., fire, flooding) could damage transmission and distribution
(e.g., wooden poles), major generating facilities, or loss of major interconnections. DERs
and micro-grids could keep power functioning in local areas and reduce losses due to
outages. Solar, other customer generation, and storage are valuable in reducing losses.
• Risk due to hacking, e.g., from Russia or hostile sources that could bring down major
power centers. Customers who can continue to generate locally with DERs and storage
could reduce risk. If solar is discouraged, batteries will be also, since that is a natural
next step, which also sometimes occurs in tandem with customer solar installation.
• Consideration of customers in Idaho Power’s Territory with rooftop solar generation
help Idaho Power to meet Oregon’s RPS. What is the value of avoided cost of non-
compliance to Oregon’s RPS?
• Coal- and gas-fired plants have significantly greater planned and unplanned downtime
compared to distributed solar with no mechanical moving parts and no potential fuel
disruption or price risk. How much greater is the total planned and esp. unplanned
downtime for fossil fuels and fuel supply vs. customer-generated solar?
• Price-and availability risk-hedge:
o In section 4.1.1.2 is noted: “The value for the ECR, for purposes of the study, uses
a historically based indicative price based on a 3-year average of the ELAP price.
Appendix 4.3 provides the average ELAP hourly price for 2019 through 2021.” The
analysis would therefore not have captured the dramatic increases in price and
availability of fossil fuels based on bounce back from the depths of COVID-19 and
Russia’s invasion of Ukraine. Per the PUC’s directive, a final VODER study should
incorporate this data.
o Fuel availability and price for fossil fuels fluctuate based on world events and has
recently had a large impact on natural gas, oil, and transportation fuels. Locally-
generated solar-, wind-, or small-hydro power could reduce demand for
worldwide commodities like fossil fuels, thus reducing energy prices for all Idaho
Power customers.

Value of Avoided Energy Costs:
• To postpone distribution upgrades, Idaho Power should provide incentives for energy
efficiency to all who apply for solar PV installations.
• The potential for Vehicle-to-Grid energy to lower peak costs. Solar and batteries are
increasingly found in the same household. If solar power is not valued, more solar
customers will choose to keep rather than export the energy (e.g., become non-
exporting systems). This could reduce energy available for peak demand situations,
creating greater risk of Loss of Load.
• Why does Idaho Power not simply implement a more granular Time of Day pricing?

Comments on what is in the study:
• Measurement interval—should continue to be calculated monthly.
o Page 1 of Idaho Power’s VODER executive summary states: “The ECR benefit and
cost components described in the study can vary in value depending on the use
of net excess exported energy measured on a net hourly or real-time
measurement Executive Summary Value of Distributed Energy Resources Study
Page 2 interval”. Rather than change the measurement interval, why not
implement more granular Time-of-Day pricing? Customers generating power
typically have more power over their use than their generation. And TOD is
applicable to, and can be acted on by, all customer classes. Thus, it lowers risk of
excessive demand at peak, and is fairer. This also reduces the need for
customers to purchase new bi-directional meters.
o Page 6 of the VODER Introduction states:
“The circumstances that existed when the Commission initially established Idaho
Power’s net metering policies and practices have changed dramatically over the
last two decades. As more customers install on-site generation, the existing
compensation structures do not account for the nuances of the current
environment. For example, on-site customer-generators use energy from the
utility at night, when the sun doesn’t shine, or at any moment the on-site
generation system cannot meet a customer’s energy needs. As a result, a
monthly measurement interval doesn’t accurately reflect the value of the grid’s
bi-directional service (energy sent both to and from the utility’s electric grid)
provided to on-site customer-generators during different hours and days of the
billing period nor the value of the energy being produced. “

The fact that the sun doesn’t shine at night hasn’t changed. The most direct way
to reflect the value of the value of electricity *in either direction* is to create
Time-of-Use charges that are more granular than those implemented now. This
would apply to all customer classes and therefore be most powerful and fair.

• Value of RECs sold by Idaho Power should acknowledge value of customer-generated
excess energy as at least as valuable as the RECs it sells, since that customer-generated
clean has the characteristics that Idaho Power is selling at a premium to other
customers.
• Timing of updates to export credit rate, expiring credits, billing structure
o Updates should not occur more frequently than the average homeowners’ stay
in their homes, at least 7 years, or longer, since this is a significant investment
and customers should at least be able to break even within an average stay.
Many customers who spoke at earlier PUC hearings on the Value of Solar were
making purchases for their retirement, so have predictable, stable costs.’

Other perspectives:
• Idaho Power will be challenged not only to meet rapidly-growing customer demand for
electricity (including EV growth and electrification of HVAC and water heating) in its
territory, but also to do it with clean energy. Idaho also needs to preserve as much land
as possible for housing and crops, and can best conserve land by encouraging use of
existing rooftops with favorable characteristics for solar to provide electricity
generation. This is a larger but important social imperative that will be encouraged by a
fair return on customers’ investments in energy generation on their homes. It could also
impact food prices, since food grown locally incurs fewer transportation costs.
• Idaho Power and its customers can lower cost of electricity to all by combining customer
investment in solar PV power, Time-of-Use, and ultimately, some battery storage to
cover peak hours from 4-10pm in the summer. Fair returns will encourage both solar PV
and battery investments and demand reduction during peak hours. Vermont has
“rented” batteries to customers to cut peak, which saved all customer energy due to
avoided generation, shutdowns, and T&D losses.
• High connection costs have been shown to discourage energy efficiency. The cost of
connecting a customer-generation system to IPC should remain low to encourage this.
• Acknowledge and address risks:
o Fuel price and availability (“price-hedge”)
o Downtime of coal-fired and gas-plants, for maintenance and unexpected events
o Cyber risks and the advantages of distributed power to single major power sites
o Carbon tax risk: all the U.S.’ major trading partners have implemented or are
soon expected to implement, carbon pricing, as a carbon tax or cap-and-trade.
Carbon border adjustments will raise the price of U.S. exports and prod the U.S.
government into creating our own carbon pricing, to capture the revenue
internally to the U.S. that would otherwise flow to other countries as part of the
Carbon border adjustment.
• How does customer generation (e.g., rooftop solar) affect Idaho Power’s Power Cost
Adjustment? How does this affect Idaho Power’s compensation and preferences?

Thank you, PUC, for providing us this opportunity to comment on the VODER study.

Lisa Hecht

From:PUCWeb Notification
To:Jan Noriyuki
Subject:Notice: A comment was submitted to PUCWeb
Date:Monday, October 10, 2022 8:00:13 AM
The following comment was submitted via PUCWeb:
Name: Michael Kochert
Submission Time: Oct 10 2022 7:35AMEmail: [e-mail]
Telephone: [phone]Address: 1622 S 1625 E
Gooding, ID 83330
Name of Utility Company: Idaho Power Company
Case ID: IPC-E-22-22
Comment: "My wife and I have a 6 kW solar array on our farm north of Gooding, and I would like to comment on Idaho Power (IPC) Value of Distributed Energy Resources Study
(VODER Study). I am concerned because I believe that the VODER Study is biased. IPCs choice of assumptions and calculation methods significantly undervalue the five components
(avoided energy costs, avoided generation capacity, T&D deferral, avoided line losses, and integration costs) that the utility quantified. The VODER Study also fails to quantify important
benefits of distributed solar that the Commission directed the utility to analyze in Order No. 35284. These benefits are known and measurable. They will impact rates and will benefit
Idaho ratepayers and citizens. These include the benefits of a long-term physical hedge against volatile natural gas prices and of avoiding the rate impacts of carbon emissions. "
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From:Ruth Merrill ([e-mail]) Sent You a Personal Message
To:Jan Noriyuki
Subject:IPC-E-22-22 Public Comment
Date:Monday, October 10, 2022 9:19:45 AM
CAUTION: This email originated outside the State of Idaho network. Verify links and attachments BEFORE you
click or open, even if you recognize and/or trust the sender. Contact your agency service desk with any concerns.
Dear Idaho Public Utilities Commission,
I am sure you are aware of the continuing, devastating impacts of climate change. I write this plea to you as the full
Hunter Moon rises orange in the smoke from still raging wildfires in October. We all must do whatever we can to
curb the impact. In Idaho, one dramatic contribution is solar energy. People who are considering going solar need
to have every incentive. Please consider the findings of the independent solar study for fair rates and reject Idaho
Power's findings.
Please look carefully at the independent study conducted by Crossborder Energy, which points out several
shortcomings in Idaho Power's own study on the costs and benefits of customer-owned rooftop solar. Idaho Power
will use this study to justify trying to reduce compensation rates to solar owners. To arrive at fair rates, we first
need a fair study.
Crossborder's study states, "We conclude that Idaho Power?s choice of assumptions and calculation methods
significantly undervalue the five components that the utility quantified. We present our own calculations of an ECR
with these five elements. In addition, the VODER Study fails to quantify important benefits of distributed solar that
the Commission directed the utility to analyze in Order No. 35284 -- benefits that are known and measurable, will
impact rates, and will benefit Idaho ratepayers and citizens.?
Idahoans deserve solar rates based on a more fair and complete analysis. I urge you to reject Idaho Power's study
and look to Crossborder's study as a more accurate measure of the value (to ALL ratepayers) of customer-owned
solar power.
Sincerely,
Ruth Merrill
2047 South Broxon Street
Boise, ID 83705
[e-mail]
[phone]
This message was sent by KnowWho, as a service provider, on behalf of an individual associated with Sierra Club.
If you need more information, please contact Lillian Miller at Sierra Club at [e-mail] or (415) 977-
5500.
From:PUCWeb Notification
To:Jan Noriyuki
Subject:Notice: A comment was submitted to PUCWeb
Date:Monday, October 10, 2022 1:00:07 PM
The following comment was submitted via PUCWeb:
Name: Jay Krajic
Submission Time: Oct 10 2022 12:40PMEmail: [e-mail]
Telephone: [phone]Address: 808 N 25th Street
Boise, ID 83702
Name of Utility Company: Idaho power
Case ID: IPC-E-22-22
Comment: "I am urging the PUC to keep the credit rate for Idaho Power’s solar credit program. My house is all electric and have solar panels on my roof. "
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From:Deanie Gilbert ([e-mail]) Sent You a Personal Message
To:Jan Noriyuki
Subject:IPC-E-22-22 Public Comment
Date:Monday, October 10, 2022 2:19:05 PM
CAUTION: This email originated outside the State of Idaho network. Verify links and attachments BEFORE you
click or open, even if you recognize and/or trust the sender. Contact your agency service desk with any concerns.
Dear Idaho Public Utilities Commission,
We purchased our rooftop solar Array in December 2021, fully anticipating to be FAIRLY Compensated by Idaho
Power for our contribution to the energy grid and to a carbon neutral future to preserve our planet for our
descendants for years to come
Please look carefully at the independent study conducted by Crossborder Energy, which points out several
shortcomings in Idaho Power's own study on the costs and benefits of customer-owned rooftop solar. Idaho Power
will use this study to justify trying to reduce compensation rates to solar owners. To arrive at fair rates, we first
need a fair study.
Crossborder's study states, "We conclude that Idaho Power?s choice of assumptions and calculation methods
significantly undervalue the five components that the utility quantified. We present our own calculations of an ECR
with these five elements. In addition, the VODER Study fails to quantify important benefits of distributed solar that
the Commission directed the utility to analyze in Order No. 35284 -- benefits that are known and measurable, will
impact rates, and will benefit Idaho ratepayers and citizens.?
Idahoans deserve solar rates based on a more fair and complete analysis. I urge you to reject Idaho Power's study
and look to Crossborder's study as a more accurate measure of the value (to ALL ratepayers) of customer-owned
solar power.
Sincerely,
Deanie Gilbert
5304 Auburn Pl
Caldwell, ID 83607
[e-mail]
[phone]
This message was sent by KnowWho, as a service provider, on behalf of an individual associated with Sierra Club.
If you need more information, please contact Lillian Miller at Sierra Club at [e-mail] or (415) 977-
5500.
From:Kari Wolff ([e-mail]) Sent You a Personal Message
To:Jan Noriyuki
Subject:IPC-E-22-22 Public Comment
Date:Monday, October 10, 2022 2:54:44 PM
CAUTION: This email originated outside the State of Idaho network. Verify links and attachments BEFORE you
click or open, even if you recognize and/or trust the sender. Contact your agency service desk with any concerns.
Dear Idaho Public Utilities Commission,
Please look carefully at the independent study conducted by Crossborder Energy, which points out several
shortcomings in Idaho Power's own study on the costs and benefits of customer-owned rooftop solar. Idaho Power
will use this study to justify trying to reduce compensation rates to solar owners. To arrive at fair rates, we first
need a fair study.
Crossborder's study states, "We conclude that Idaho Power?s choice of assumptions and calculation methods
significantly undervalue the five components that the utility quantified. We present our own calculations of an ECR
with these five elements. In addition, the VODER Study fails to quantify important benefits of distributed solar that
the Commission directed the utility to analyze in Order No. 35284 -- benefits that are known and measurable, will
impact rates, and will benefit Idaho ratepayers and citizens.?
Idahoans deserve solar rates based on a more fair and complete analysis. I urge you to reject Idaho Power's study
and look to Crossborder's study as a more accurate measure of the value (to ALL ratepayers) of customer-owned
solar power.
Sincerely,
Kari Wolff
12562 Deerbrush Ct
Nampa, ID 83651
[e-mail]
[phone]
This message was sent by KnowWho, as a service provider, on behalf of an individual associated with Sierra Club.
If you need more information, please contact Lillian Miller at Sierra Club at [e-mail] or (415) 977-
5500.
From:PUCWeb Notification
To:Jan Noriyuki
Subject:Notice: A comment was submitted to PUCWeb
Date:Monday, October 10, 2022 4:00:08 PM
The following comment was submitted via PUCWeb:
Name: Jesse Simpson
Submission Time: Oct 10 2022 3:14PMEmail: [e-mail]
Telephone: [phone]Address: 2708 S Inverness Way
Boise, ID 83705
Name of Utility Company: Idaho Power
Case ID: IPC-E-22-22
Comment: "Dear Idaho PUC, Idahoans deserve the right to own their electricity viaphotovoltaics, to utilize the sunshine, and be given an equal exchange rate for that power.
Idaho Power only gains from these individual investment as do all Idaho residents. IPC istrying to further their grip on the available profits from Idahoans pockets. They have no
problem spending money to fight solar options because they want the consumer to have paythem till the end of time. Solar PV gives the consumer an option along with Idaho Power
company. Nobody knows what the future climate holds for us and whether there will be waterin the dams or cheap fossil fuels that currently provide rate payers cheap power. The sun is a
resource that we all "equally" have access to. Idaho Power wants to de-value that equal accessfor their own future gains. Solar PV provides a way for individuals to empower themselves,
support their families, educate younger generations, and utilize the sunshine which riseseveryday, PV technology is a part of the answer to creating Equality and Equity for all. Let the
fair market play out here and please do not give Idaho Power the ability to control thisabundant resource we all EQUALLY have access to. Please stand up for the people not for the
Utility by NOT devaluing the electricity created by the sun via photovoltaics. Our kids arecounting on us to build a better place than we have now and this case is a catalyst for that
future. Thanks for a fair chance at equality and taking a deep look at what this situation withIdaho Power and their fight to devalue the sunshine Best Regards, Jesse Simpson "
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[Open in the PUC Intranet application]
From:Doug Wagoner ([e-mail]) Sent You a Personal Message
To:Jan Noriyuki
Subject:IPC-E-22-22 Public Comment
Date:Tuesday, October 11, 2022 2:16:59 AM
CAUTION: This email originated outside the State of Idaho network. Verify links and attachments BEFORE you
click or open, even if you recognize and/or trust the sender. Contact your agency service desk with any concerns.
Dear Idaho Public Utilities Commission,
Please look carefully at the independent study conducted by Crossborder Energy, which points out several
shortcomings in Idaho Power's own study on the costs and benefits of customer-owned rooftop solar. Idaho Power
will use this study to justify trying to reduce compensation rates to solar owners. To arrive at fair rates, we first
need a fair study.
Crossborder's study states, "We conclude that Idaho Power?s choice of assumptions and calculation methods
significantly undervalue the five components that the utility quantified. We present our own calculations of an ECR
with these five elements. In addition, the VODER Study fails to quantify important benefits of distributed solar that
the Commission directed the utility to analyze in Order No. 35284 -- benefits that are known and measurable, will
impact rates, and will benefit Idaho ratepayers and citizens.?
Idahoans deserve solar rates based on a more fair and complete analysis. I urge you to reject Idaho Power's study
and look to Crossborder's study as a more accurate measure of the value (to ALL ratepayers) of customer-owned
solar power.
Sincerely,
Doug Wagoner
4989 E Saint Anthony Lane
Post Falls, ID 83854
[e-mail]
[phone]
This message was sent by KnowWho, as a service provider, on behalf of an individual associated with Sierra Club.
If you need more information, please contact Lillian Miller at Sierra Club at [e-mail] or (415) 977-
5500.
From:PUCWeb Notification
To:Jan Noriyuki
Subject:Notice: A comment was submitted to PUCWeb
Date:Tuesday, October 11, 2022 3:00:06 PM
The following comment was submitted via PUCWeb:
Name: Kim Mazik
Submission Time: Oct 11 2022 2:37PMEmail: [e-mail]
Telephone: [phone]Address: 561 Chesrnut Loop
Belluvue, ID 83313
Name of Utility Company: ID Power
Case ID: IPC-E-22-22
Comment: " Very disappointing these words from CrossborderEnergy: 'We conclude that Idaho Power’s choice of assumptions and calculation methods significantly undervalue the
five components (avoided energy costs, avoided generation capacity, T&D deferral, avoided line losses, and integration costs) that the utility quantified." Idaho Power please don't attempt
to make it harder on people to get solar -especially in light of the effects that the status quo has on the planet."
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From:PUCWeb Notification
To:Jan Noriyuki
Subject:Notice: A comment was submitted to PUCWeb
Date:Tuesday, October 11, 2022 5:00:10 PM
The following comment was submitted via PUCWeb:
Name: Lyle Zufelt
Submission Time: Oct 11 2022 4:39PMEmail: [e-mail]
Telephone: [phone]Address: 9965 GRAND TARGHEE TRL
Middleton, ID 83644
Name of Utility Company: Idaho Power
Case ID: IPC-E-22-22
Comment: "It would be fair at this point to allow current solar panel customers to continue to receive the full Export Credit Rate for electricity generated. And the proposed change in ECR
to apply to new solar panel projects. I believe you would see a drastic reduction in the number of customers willing to put out the money for solar panels. And when the situation becomes
drastic and more electricity is needed than can be purchased elsewhere Idaho Power will realize how foolish and short-sighted they were in their proposal."
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