20231020Comments_2.pdf

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-----Original Message-----
From: Jay Basen <[e-mail]>
Sent: Thursday, October 19, 2023 8:14 PM
To: Jan Noriyuki
Subject: IPC-E-23-14

Hi,

my name is Jay Basen and I'm an Idaho Power customer. I'm concerned about the very limited public
access to the upcoming hearings on Idaho Power's roo�op solar changes. The hearings need to be a�er
general working hours, be long enough to allow everyone to speak, be located in at least two more
ci�es, and include a virtual tes�mony op�on for all the people who can't atend in-person. Please help
people par�cipate in our democracy, par�cularly on proposals coming from a monopoly u�lity.

Thanks
Jay
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The following comment was submited via PUCWeb:

Name: STEPHEN HILLIER
Submission Time: Oct 20 2023 12:15PM
Email: [e-mail]
Telephone: [phone]
Address: 15157 N Bonelli Ave
Nampa, ID 83651

Name of U�lity Company: Idaho Power

Case ID: IPC-E-23-14

Comment: "Having reviewed Idaho Power's request to change to real �me net metering, I found their
defini�on of what they claim to be 'Peak Hours' to be extremely limited; given the data set they provided
- it seems that a lot more �me should be considered peak hours. Backing up this observa�on - Idaho
Power's own Time of Day Plan has a much broader defini�on for what is considered 'Peak Hours' for
customers in Idaho.

What I find most interes�ng is that their 'Peak Hours' defined here match their Time of Day Plan hours
for Oregon customers. They have a separate Time of Day Plan for Idaho customers, as I men�oned
previously. The Idaho plan changes peak hours from 3:00 PM - 11:00 PM down to 1:00 PM - 9:00 PM. It
also opens up the en�re year to peak hours (which seems appropriate based on their provided power
demands in their document writeup).

By their own admission based on their Time of Day Plan for Idaho customers, power is more valuable
from 7:00 AM - 9:00 PM on non-summer months. This �me should be included as another 'Peak Hour'
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window. Admitedly, it is billed at a lower rate than the summer Peak Hours - which their proposed
reimbursement changes could have easily accounted for - but don't.

Around 20% of the power my system produces in the summer is between the hours of 1:00 and 3:00 PM.
Idaho Power claims that the power my system generates during that �me period isn't worth anything to
them in their writeup. However, on the other hand they claim that power usage during that �me period
is in high demand based on their Time of Day Plan pricing.

In summary - I feel strongly that Idaho Power, if they are permited to switch over to Real Time Net
Metering, should be constrained on how they are defining 'Peak Hours' to match the 'Peak Hours' that
they themselves use in their Time of Day Plan pricing.

If they aren't - I would be interested to see how their Time of Day Plan par�cipants will interpret Idaho
Power's double standard when it comes to the value of electricity. Based on their own writeup - wan�ng
customers to pay their fair share - this proposal seems like it is accomplishing quite the opposite of that;
and makes me ques�on their other current billing prac�ces.

Finally, I no�ced that there doesn't seem to be any defined controls or processes in place for how they
determine how much to reimburse customers for on-site power genera�on with regards to future
budgetary years. With how this proposal is writen - I would expect Idaho Power to con�nue to reduce
the reimbursement rate; as they seem to view solar customers as an en�tlement. Their claim that solar
isn't valuable to them because most of the power it produces it produces outside of �mes of high
demand is ridiculous - seeing that most of the power they generate is from hydro electric sources. How
will that work for them in years of drought - is it s�ll reliable? We've received a lot of moisture in the last
few years, but that wont con�nue.

I feel that their proposed changes are short sighted. They should be looking into beter ways to capture
and store renewable energy instead of looking for ways to prevent its buildout. By their own admission -
these changes could very well make it so that customers stop building solar systems en�rely - as the
incen�ve to do so is being removed.

Thank you for considering my thoughts on this subject.

Sincerely,
Stephen
(An Idaho Power customer in Idaho with on-site solar)"
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