20230525Comments_5.pdf

The following comment was submited via PUCWeb:

Name: Daniel Bagley
Submission Time: May 25 2023 9:27AM
Email: [e-mail]
Telephone: [phone]
Address: 4703 W Kendall St
Boise, ID 83706

Name of U�lity Company: Idaho Power

Case ID: IPC-E-23-14

Comment: "As far as I can tell, the decision to designate some solar power systems as "legacy" before
12/20/2019 is arbitrary. What is behind that cut-off date? Remember, if you allow Idaho Power to
effec�vely disincen�vize solar power genera�on for certain customers, that decision will need to stand
up in a court of law in a class-ac�on lawsuit that will inevitably be filed. It would seem that, for Idaho
Power's purposes, legacy solar systems would be those installed a�er the onsite genera�on
compensa�on structure is officially changed. "

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The following comment was submited via PUCWeb:

Name: Jacob Waffle
Submission Time: May 25 2023 10:49AM
Email: thejakewaffl[e-mail]
Telephone: [phone]
Address: 16916 Carmichael Ave
Caldwell, ID 83607

Name of U�lity Company: Idaho Power

Case ID: IPC-E-23-14

Comment: "I do not agree with the change in compensa�on for customers with their own solar
genera�on solu�ons. The "equity" term used in a recent leter on the changes highlights the issue.
Equity is not the same as equality. We want equality, not equity."

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The following comment was submited via PUCWeb:

Name: Jennefer Kopczynski
Submission Time: May 25 2023 11:51AM
Email: [e-mail]
Telephone: [phone]
Address: 11322 W Portola St
Boise, ID 83709

Name of U�lity Company: Idaho Power

Case ID: IPC-E-23-14

Comment: "Removing Netmetering is a bad idea for Idaho. We already lag behind in renewable energy
consump�on, and net metering allows for people to recoup their installa�on costs more quickly than
wai�ng for the for-profit company to decide their going rate. This is a short sighted atempt to claw back
funds - especially when the solar customers are s�ll paying your monthly service fees. Don't lead the
race to the botom on sustainable solu�ons."

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The following comment was submited via PUCWeb:

Name: Russell Graves
Submission Time: May 25 2023 1:36PM
Email: [e-mail]
Telephone: [phone]
Address: 3791 Southside Blvd
Melba, ID 83641

Name of U�lity Company: Idaho Power

Case ID: IPC-E-23-14

Comment: "I have a number of concerns about Idaho Power’s (IP) recent proposal for changing the net
metering system. One in par�cular argues that IP has not properly considered the incen�ves their
proposed billing plan encourages, and the financial rewards provided for being “grid-hos�le” during peak
demand �mes.

First, I ques�on the objec�vity of the VODER study. IP claimed that nobody else could understand their
power system and they had to do the study, which is self-serving nonsense - power systems are well
understood and largely similar throughout the country. That they did not wish to share data with a
neutral third party either implies that they don’t have it in useful forms, or that they wished to interpret
it in the most-op�mis�c-for-Idaho-Power sense. They ignore a range of environmental benefits of solar,
claiming that as there is no direct monetary value on them, they’re worth $0 and should be ignored.

The Crossborder Energy response to the VODER study raises many places where the numbers used in the
VODER study are excessively op�mis�c, or simply missing, and also raises a number of places where IP’s
math simply doesn’t make sense - applying average line losses to peak marginal kW offset by distributed
energy, or ignoring solar produc�on consumed behind the meter when calcula�ng the ELCC of the
distributed solar resources. They come up with a far higher number than IP for the value per kWh
exported, and while they have their own biases, the PUC should consider their analysis as well, and have
their engineers atempt to determine where the truth lies.

The real�me monitoring has several concerns as well. First, it results in what amount to demand charges
on residen�al customers - how your power consump�on peaks over a period of �me impacts your cost,
even with equal power used on otherwise iden�cal days. Power companies have historically been
reluctant to put demand charges on residen�al customers, as it’s hard to reason about for most
customers, and most homes are not equipped to level demand, with power companies instead relying
on aggregated demand to large residen�al areas being fairly smooth and predictable.

However, I’m most concerned about the fact that nobody at IP seems to have considered that the
incen�ves with their preferred real�me metering encourage grid abuse during peak demand �mes -
which seems at odds with the intended goals.

Consider a summer peak export rate of $0.20/kWh and a consumed energy retail rate of $0.10/kWh, and
an hour with solar produc�on of 10kWh (an even 10kW for the hour) and 5kWh of variable loads during
the hour.

If the 5kWh of load is consumed evenly at 5kW, the export during that hour will be 5kWh, and the credit
received for future use will be 5 * 0.20 = $1.

However, consider the result if a consumer “stacks loads” such that the 5kWh is consumed in the first 15
minutes of the hour, with the same 10kW of solar produc�on.

If the customer consumes power at 20kW for the first 15 minutes against their 10kW solar produc�on,
they will net consume 10kW for 15 minutes - so 2.5kWh from the grid at a cost of $0.25. The next 45
minutes, they will export at 10kW (totaling 7.5kWh) for a credit of $1.50. The net credit for this hour,
then, is $1.25 - meaning that this situa�on of heavy demand followed by heavy export is encouraged
over the smooth consump�on and export of power.

This seems, to me, to be opposed to what would be preferred in a high demand situa�on, which is a
con�nuous export of power during peak credit hours. Moving to hourly net metering would discourage
this somewhat, though the same s�ll holds with hour to hour import and export. Daily net metering
would mostly discourage this sort of grid abuse.

That IP hasn’t observed this sort of behavior yet is simply a result of the fact that there is no benefit to it
under current net metering rules. I would fully expect homeowners with solar to op�mize the credit to
their benefit, and IP should not be moving to a net metering replacement that encourages this sort of
use. Their proposed structure encourages grid-friendly energy expor�ng during off-peak �mes, and
encourages grid-hos�le energy expor�ng during peak demand.

I encourage the PUC to look at the en�rety of the situa�on, and do their own evalua�on on expected
costs and benefits using current fuel rates and realis�c numbers. If, as the CrossBorder study argues, the
value of an exported kWh is more than the retail rate, then there is no need to remove the current kWh
for kWh net metering system. However, if the PUC determines that the IP’s values are closer to correct, I
would encourage them to consider the various ways in which the real�me, hourly, or daily net metering
incen�vizes different customer behaviors. Real�me metering, as I show above, seems to encourage
par�cularly bad behaviors

I recognize that IP wants to change things, but I encourage the PUC to make sure that the changes make
grid-sense!"

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The following comment was submited via PUCWeb:

Name: Albert Nasby
Submission Time: May 25 2023 2:54PM
Email: [e-mail]
Telephone: [phone]
Address: 902 Cornwall Way
Fruitland, ID 83619

Name of U�lity Company: Idaho Power

Case ID: IPC-E-23-14

Comment: "I am against the proposal to raise u�lity prices and cut net metering on homes that have
solar energy. The purpose of solar energy is to help reduce the load on power companies. Therefore,
home owners with solar energy should not be punished by increased u�lity bills. "

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