20240426IPC Answer.pdf

POWER®
An IDACORP Company
RECEIVED
MEGAN GOICOECHEA ALLEN Friday, April 26, 2024 3:02PM
Corporate Counsel IDAHO PUBLIC
mgoicoecheaallen(a)idahopower.com UTILITIES COMMISSION
April 26, 2024
Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Boulevard
Building 8, Suite 201-A
Boise, Idaho 83714
Re: Case No. IPC-E-24-13
Lydia Ferguison v. Idaho Power Company
Dear Commission Secretary:
Attached for electronic filing please find Idaho Power Company's Answer to be filed in
the above referenced case. If you have any questions about the attached documents,
please do not hesitate to contact me.
Sincerely,
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Megan Goicoechea Allen
MGA:cd
Enclosures
P.O.Box 70(83707)
1221 W.Idaho St.
Boise,ID 83702

MEGAN GOICOECHEA ALLEN (ISB No. 7623)
LISA D. NORDSTROM (ISB No. 5733)
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
mgoicoecheaallenCa�,idahopower.com
InordstromCa)_idahopower.com
Attorneys for Idaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
Lydia Ferguison )
Case No. IPC-E-24-13
Complainant, )
IDAHO POWER COMPANY'S
vs. ) ANSWER
Idaho Power Company, )
Respondent. )
COMES NOW, Idaho Power Company ("Respondent", "Idaho Power" or
"Company"), and pursuant to Procedural Rule 57, now answers the Summons of the
Idaho Public Utilities Commission ("Commission") dated April 5, 2024, concerning the
formal Complaint ("Complaint") of Lydia Ferguison ("Complainant" or "Ms. Ferguison").
While the Complainant does not expressly state the relief she seeks from the
Commission, she presumably seeks relief from Idaho Power's application of the criteria
established by the Commission for legacy status, or grandfathering, for residential
customers with on-site generation. While the Company is sympathetic to Ms. Ferguison's
IDAHO POWER COMPANY'S ANSWER- 1

circumstances, it does not believe it can unilaterally take action under existing Idaho law
that is different than that currently permitted by Commission's orders and the Company's
Commission-approved tariff. Idaho Power lacks the authority to grant an exception to the
requirements for legacy treatment established by the Commission and set forth in the
Company's tariff, and so defers to the Commission to determine whether it believes the
facts presented in this case justify granting relief from the grandfathering criteria.
I. FACTUAL AND REGULATORY BACKGROUND
Legacy Net Metering Systems
1. Through a series of successive offerings over the last forty years, Idaho
Power has provided retail customers the ability to generate their own electricity to offset
all or a portion of their energy usage and has allowed for the export of excess generation
to Idaho Power's grid.' Currently, customers who install on-site generation can
interconnect an exporting system under the terms of Schedule 6, Residential Service On-
Site Generation ("Schedule 6"), Schedule 8, Small General Service On-Site Generation
("Schedule 8"), or Schedule 84, which is the tariff schedule for the Company's
commercial, industrial, and irrigation ("C&I") customers to take net metering service. The
Company's efforts to have the Commission review and modify outdated net metering
offerings to better align with actual circumstances resulted in a series of on-site
' See, e.g., In the Matter of the Application of Idaho Power Company for Approval of Revised Rates to be
Paid for Power and Energy Sold to Idaho Power Pursuant to Section 210 of the Public Utility Regulatory
Policies Act of 1978, Case No. U-1006-200; In the Matter of the Application of Idaho Power Company for
An Order Revising the Rates, Terms and Conditions Under Which Idaho Power Purchases Non-Firm
Energy from Qualifying Facilities, Case No. IPC-E-95-15; In the Matter of the Application of Idaho Power
Company for Approval of a New Schedule 84—Net Metering Tariff, Case No. I PC-E-01-39; In the Matter
Idaho Power Company's Application for Authority to Modify Its Net Metering Service and to Increase the
Generation Capacity Limit, Case No. IPC-E-12-27 (Jul. 3, 2013). In the Matter of Idaho Power Company's
Application for Authority to Establish New Schedules for Residential and Small General Service
Customers with On-Site Generation, Case No. IPC-E-17-13 (May 9, 2018).
IDAHO POWER COMPANY'S ANSWER- 2

generation related dockets through which incremental steps have been taken toward the
ultimate goal of establishing a more sustainable offering by implementing a more
equitable pricing and compensation structure. As part of that process, the Commission
determined that it was prudent "to distinguish between existing customers and new
customers based on the customers' reasonable expectations when making significant
personal investments in on-site generation systems.112
2. In Order No. 34509 issued on December 20, 2019, the Commission
indicated that prior to that date, customers could have reasonably believed that net-
metering program fundamentals would remain the same and made decisions to invest in
on-site generation systems in reliance on that belief. With that pronouncement, however,
the Commission established a firm cut-off for the reasonableness of this assumption:
"After the issuance of this Order. . . we believe it will no longer be reasonable for a
customer to assume the net-metering program fundamentals will remain the same over
the expected payback period of their investment."3
3. Finding reasonable differences between existing and new net-metering
customers based on the uncertainty that may have existed prior to the issuance of Order
No. 34509, the Commission established criteria to define legacy treatment for existing
systems under Schedule 6 and Schedule 8.4 Legacy systems are subject to the rules in
place as of the service date of Order No. 34509, including the excess energy
compensation structure. The Commission determined that Schedule 6 and Schedule 8
2 In the Matter of the Petition of Idaho Power Company to Study the Costs, Benefits, and Compensation
of Net Excess Energy Supplied by Customer On-Site Generation, Case No. IPC-E-18-15, Order No.
34509 at 10 (Dec. 20, 2019).
3 Id.
4 See Case No. IPC-E-18-15, Order No. 34509 at 14-15 and Order No. 34546 at 8-11 (Feb. 5, 2020).
IDAHO POWER COMPANY'S ANSWER- 3

customers that qualify for legacy treatment continue to be subject to changes in
consumption rates but not to changes in the 1:1 monthly kilowatt-hour ("kWh") retail rate
compensation structure until legacy status terminates on December 20, 2045.
4. Subsequently, the Commission issued Order No. 34546 on reconsideration
in which it agreed to grandfather by system not by customer and identified four (4) criteria
to retain grandfather/legacy status of the system:
• A customer who moves into a property with a grandfathered net-metering system
gets to "inherit" the grandfathered status of the system;
• If a system is offline for more than six months, or is moved to another site, the
grandfathered status of the system is forfeited;
• To allow for the replacement of degraded or broken panels, the customer may
increase the capacity of the grandfathered system by no more than 10% of the
originally installed nameplate capacity, or 1 kW, whichever is greater; and
• Grandfathered status terminates December 20, 2045.5
5. As of March 31, 2024, there are 5,101 legacy and 12,697 non-legacy
residential systems interconnected to Idaho Power's system under Schedule 6
(Residential On-Site Generation).
Ms. Ferguison's Net Metering Service
6. Since 2017, the Complainant has taken net metering service at 995 South
Linder Road in Meridian, Idaho. The original system at that location, a 34 panel, 10.2 kW
solar photovoltaic ("PV") system, came online in June of 2017.
7. When the Commission issued Order Nos. 34509 and 34546 delineating the
parameters of legacy status and "grandfathering" existing residential systems into
5 Case No. IPC-E-18-15, Order No. 34546 at 9. See also IPUC No. 30, Tariff No. 101, Schedule 6, First
Revised Sheet 6-2.
IDAHO POWER COMPANY'S ANSWER-4

Schedule 6 as it existed on December 20, 2019,6 Ms. Ferguison's on-site generation
system was already interconnected and was entitled to legacy status.
Ms. Ferguison's Complaint
8. On February 13, 2024, Idaho Power was contacted by a Utilities
Compliance Investigator with the Commission ("Commission Investigator") regarding an
inquiry made by Ms. Ferguison pertaining to the legacy treatment of her solar system.
The Commission Investigator advised the Company that Ms. Ferguison was being forced
to relocate as a result of the Ada County Highway District ("ACHD") acquiring her property
to facilitate nearby infrastructure improvements and that she wanted to move her solar
system to her new residence and retain legacy status. The Commission Investigator
asked the Company: "Due to an imminent domain situation by government action, in
which the customer has no choice but to move from their residence, is the Company
willing to allow the customer to retain their legacy status of their solar system as a one-
time allowance?"
9. On February 20, 2024, Idaho Power responded to Staff's question, noting
that the Company is required to follow the Commission's prior orders as well as the utility
tariffs on file with the Commission pursuant to which grandfathered status is forfeited if a
system is offline for more than six months or is moved to another site. The Company
further indicated that while Ms. Ferguison's request for relief from legacy status
requirements was understandable under the specific circumstances presented, Idaho
6 Case No. IPC-E-18-15, Order No. 34509 at 10 and 14. A legacy (i.e., grandfathered) system is defined
as either an on-site generation system interconnected with Idaho Power's system as of the service date
of Order No. 34509 or a customer with a binding financial commitment to install an on-site generation
system as of that date that proceeds to interconnect their system within one year.
IDAHO POWER COMPANY'S ANSWER- 5

Power lacked the legal authority to deviate from the Commission prescribed criteria. A
copy of the Commission's inquiry and the Company's response is included as Attachment
1 — IPC Responses to Staff.
10. Subsequently, Ms. Ferguison submitted a complaint letter to the
Commission ("Complaint") on March 18, 2024, and the Commission issued a Summons
and Formal Complaint against Idaho Power on April 5, 2024. In her Complaint, Ms.
Ferguison explained she "was told to contact the Public Utilities Commission to see if
[she] could be `grandfathered' due to the fact that [she] did not choose to move" from her
home where the system was grandfathered but was being forced to by ACHD. Ms.
Ferguison also claims that she was told that she "would need to install a battery backup
system," which she was unable to afford.
11. It is not clear who purportedly advised Ms. Ferguison that she needed to
install a battery backup system; however, the Company's Customer Generation team has
no record of any conversations with this customer with respect to these issues, and
moreover, it does not require a "battery backup." While Idaho Power has no first-hand
knowledge of the other circumstances surrounding Complainant's relocation, for
purposes of this response? it accepts Ms. Ferguison's allegation that she was forced to
sell her residence to facilitate a nearby ACHD improvement project.
II. ANSWER
12. The Complaint, which sets forth factual allegations in a narrative format
rather than specifically numbered allegations, does not indicate how the Complainant
The Company reserves the right to supplement and/or amend its Answer if additional information is
ascertained during the course of discovery or otherwise that would justify such supplement or
amendment.
IDAHO POWER COMPANY'S ANSWER- 6

believes such circumstances constitute a violation of the Commission's rules or laws, and
the failure to refer to specific provisions of statute, rule, order, notice, tariff, or other
controlling law that the Company allegedly violated is contrary to the requirements of Rule
of Procedure 54.03.8
13. In fact, even if one accepts Complainant's factual allegations as true, they
do not indicate any wrongful conduct by Idaho Power. As more fully explained below, the
Company appropriately applied the Schedule 6 tariff conditions and the Commission's
grandfathering criteria to Ms. Ferguison in this circumstance; the Company acted in good
faith and in conformity with regulatory requirements and regulatory compliance is an
affirmative defense to the Complaint.
A. Idaho Power Lacks Authority to Deviate from the Requirements for Legacy
Treatment Established by the Commission or from the On-Site Generation
Interconnection Rules Set forth in the Company's Tariff.
14. Neither the Idaho Legislature nor the Commission has authorized the
Company to exercise discretion that deviates from prior Commission's orders or the
Commission-approved tariff.
15. Idaho Power is required to follow the Commission's prior orders as well as
the utility tariff on file with the Commission. This concept, known as the "filed rate
doctrine," is a basic principle of utility regulation that a utility may only charge the approved
rates and charges it has on file with its regulatory body.
16. Together, Idaho Code § 61-313 and Idaho Code § 61-315 codify the
concepts that make up the filed rate doctrine for the State of Idaho. Idaho Code § 61-313
provides, in pertinent part, that no refund or remit of any rates or charges may be made,
8 IDAPA 31.01.01.054.03.
IDAHO POWER COMPANY'S ANSWER- 7

and no contract or agreement extended except as specified by tariff and as are regularly
and uniformly extended to all corporations or persons. Similarly, Idaho Code § 61-315
codifies the concept of non-discriminatory service and prohibits a utility from giving
preferential treatment to any customer or customer class over another.
17. A customer's request to receive treatment that deviates from the tariff and/or
Commission precedent, such as Ms. Ferguison's request to maintain legacy status for a
system that has moved to another location, implicates the "filed rate doctrine" and
authorizing such would defeat this non-discriminatory policy. Idaho Power is obligated to
comply with the Commission's prior orders and Schedule 6, both of which provide that a
legacy system that is moved to a different site forfeits legacy status, and it has no authority
to unilaterally exempt one customer from this criterion regardless of the circumstances.
B. Idaho Power Correctly Applied the Requirements of Order Nos. 34509 and
34546 and the Company's Residential On-Site Generation Tariff.
18. Idaho Power affirmatively defends that it followed the Commissions'
directives in Order Nos. 34509 and 34546 and correctly advised of the Commission-
established requirements for legacy treatment relative to Ms. Ferguison's move. Idaho
Power has consistently applied these criteria for all eligible customers.'
19. Moreover, Idaho Power is required by law to follow the rules for maintaining
eligibility for legacy status set forth in Schedule 6, including forfeiting legacy status for a
system that is moved to a different site. The tariff is unequivocal, and the Company
applies it as written.
9 See, e.g., In the Matter of Randy Valley's Formal Complaint Against Idaho Power Company Concerning
Grandfathering of Ten Solar Panels, Case No. IPC-E-21-34.
IDAHO POWER COMPANY'S ANSWER- 8

C. Public Policy Considerations Complicate Extension of the Grandfather
Period for Ms. Ferguison's Solar Array.
20. While Ms. Ferguison's request for an exception to grandfathering status
eligibility requirements is understandable under the specific circumstances presented, it
raises larger public policy issues that could have an impact broader than her household.
These considerations include prejudice to similarly situated customers and the
administration/duration of any authorized exceptions.
21. As previously noted by the Company, it is concerned that granting
exceptions for certain customers may have a negative impact on other customers with
systems that lost legacy status due to circumstances that were similarly beyond their
control. Since the Commission set the criteria for systems to retain grandfather/legacy
status, a number of systems have failed to satisfy one or more of these requirements and
lost legacy status as a result. If Idaho Power were to unilaterally grant Ms. Ferguison's
requested relief, it could create a preference that runs afoul of Idaho Code § 61-315.
Because the Company does not comprehensively track information regarding systems
that have lost their grandfathering in the past, it would have no way to administer an
exception process retroactively for these customers further undermining the concept of
non-discriminatory service.
22. While the Company understands that there may be circumstances under
which the Commission finds an exception to the grandfathering rules to be fair, just, and
reasonable, that decision is within the purview of the Commission not the Company. For
example, when a customers' home and solar array were destroyed by a fire, the
Commission directed the Company to maintain legacy status for the system even though
IDAHO POWER COMPANY'S ANSWER- 9

it was offline for more than six months while the customers rebuilt their residence.10 The
Commission noted that the case involved "unique and undisputed facts . . . which we
could not anticipate when we issued Order No. 34546,"11 based on which an exception
was justified. The Commission emphasized, however, that the relief granted in that case
was limited solely to the specific facts of that case and was not to be construed as
precedential in any future cases.12
23. As these types of situations demonstrate, unexpected things happen that
customers, regulators, and utilities do not anticipate, but the Company is not authorized
to grant exceptions for legacy status regardless of the circumstances. While to date the
Commission has reviewed applicability of hardship exceptions on a case by case basis,
considering that the grandfather period does not terminate until 2045, it may be
appropriate to consider whether it may be more efficacious to develop a specific exception
process for legacy status to be administered by Commission Staff for the remainder of
the grandfather period(s).13 By way of example, a potential process could entail
Commission Staff gathering the facts associated with each instance through informal
discovery with the Company, as it does today, and presenting its findings and
recommendations in a memo to the Commission. The Commission can then consider the
matter at a decision meeting and determine whether to accept Staffs recommendation or
open a case to facilitate a more formal process.
10 See In the Matter of Sara Statz Hartzheim's Formal Complaint Against Idaho Power Company, Case
No. IPC-E-22-25, Order No 35651 (Dec. 30, 2022).
11 Id. at 4.
12 Id.
13 As observed with the Master-Metering Rules for Electric Utilities (IDAPA 31.26.01) rules that set a July
1, 1980 grandfather date, such criteria are challenging to administer over multiple decades.
IDAHO POWER COMPANY'S ANSWER- 10

III. COMMUNICATIONS AND SERVICE OF PLEADINGS
24. Service of pleadings and communications with reference to this case should
be sent to the following:
Lisa D. Nordstrom Connie Aschenbrenner
Megan Goicoechea Allen Ashley Herrera
Idaho Power Company Idaho Power Company
1221 West Idaho Street (83702) 1221 West Idaho Street (83702)
P.O. Box 70 P.O. Box 70
Boise, Idaho 83707 Boise, Idaho 83707
Inordstrom(a-),idahopower.com caschenbrenner(a�.idahopower.com
mgoicoecheaallenCa)_idahopower.com aherrera(aD_idahopower.com
[e-mail]
IV. CONCLUSION
Idaho Power does not believe that there is a dispute as to the key facts or the
applicable regulatory requirements; rather, the issue is whether the facts of this case
justify an exception to the Schedule 6 tariff conditions and the Commission's
grandfathering criteria. While Idaho Power is sympathetic to the circumstances faced by
Ms. Ferguison, the Company cannot unilaterally take action under existing Idaho law that
is different than that currently permitted by Commission's orders and the Company's
Commission-approved tariff.
Idaho Power acted appropriately and in compliance with Commission precedent
and its tariff in relation to Ms. Ferguison's situation. It lacks the authority to grant an
exception to the requirements for legacy treatment established by the Commission and
set forth in the Company's tariff, and so defers to the Commission to determine whether
it believes the facts presented in this case justify granting relief to Ms. Ferguison. In
addition, the Company respectfully requests that the Commission consider establishing
an exception process for legacy status with objective exception criteria to be administered
IDAHO POWER COMPANY'S ANSWER- 11

by Staff, such as the process described above, in the event the Commission deems a
hardship exception appropriate.
DATED at Boise, Idaho, this 26t" day of April 2024.
I
MEGAN GOICOECHEA ALLEN
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S ANSWER- 12

CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 26t" day of April 2024, 1 served a true and correct
copy of Idaho Power Company's Answer upon the following named parties by the method
indicated below, and addressed to the following:
Commission Staff Hand Delivered
Adam Triplett U.S. Mail
Deputy Attorney General Overnight Mail
Idaho Public Utilities Commission FAX
11331 W. Chinden Blvd., Bldg No. 8, FTP Site
Suite 201-A (83714) X Email: adam.triplett(-)_puc.idaho.gov
PO Box 83720
Boise, ID 83720-0074
Complainant Hand Delivered
Lydia Ferguison U.S. Mail
1920 N. Oaks Hills Dr. Overnight Mail
Meridian, ID 83646 FAX
FTP Site
X Email: lferguis gmail.com
(L
Christy Davenport
Legal Administrative Assistant
IDAHO POWER COMPANY'S ANSWER- 13

BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-E-24-13
IDAHO POWER COMPANY
ATTACHMENT 1

Herrera, Ashley
From: Jon Kruck <[e-mail]>
Sent: Tuesday, February 20, 2024 9:21 AM
To: Herrera, Ashley
Subject: RE: [EXTERNAL] IPUC-FERGUISON, LYDIA: Consumer Contact
Follow Up Flag: Follow up
Flag Status: Flagged
KEEP IDAHO POWER SECURE! External emails may request information or contain malicious links or attachments. Verify the
sender before proceeding, and check for additional warning messages below.
Good morning Ashley,
Thank you for the email. It appears that based on your answer,this complaint will likely go to a formal complaint
to be heard by the Commissioners.
Please let me know if you have any questions or further information to provide.
Thankyou,
Jon Kruck
Utilities Compliance Investigator
Idaho Public Utilities Commission
Direct: [phone]
Toll Free 1-800-432-0369
From: Herrera,Ashley<[e-mail]>
Sent:Tuesday, February 20, 2024 9:09 AM
To:Jon Kruck<[e-mail]>
Subject: RE: [EXTERNAL] IPUC-FERGUISON, LYDIA: Consumer Contact
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.
Hi Jon,
Thank you for reaching out. In this case,the Company has advised the customer of the Commission-established criteria
for maintaining legacy status:
1) A customer who moves into a property with a grandfathered net-metering system gets to 'inherit" the
grandfathered status of the system;
2) If a system is offline for more than six months, or is moved to another site,the grandfathered status of the
system is forfeited (emphasis added);
i

3) To allow for the replacement of degraded or broken panels,the customer may increase the capacity of the
grandfathered system by no more than 10%of the originally installed nameplate capacity, or 1 kW,whichever is
greater; and
4) Grandfathered status terminates December 20, 2045.
Idaho Power is required to follow the Commission's prior orders as well as the utility tariffs on file with the Commission.
Ms. Ferguison's request for an extension of her legacy status is certainly understandable under the specific
circumstances presented, however Idaho Power lacks the legal authority to extend the grandfather period to encompass
the yet-to-be installed Solar Array Ms. Ferguison is inquiring about.
While Idaho Power does not have the legal authority to grant exceptions to its tariff, I am aware in Case No. IPC-E-22-25,
the Commission did find "granting an exception to Order No. 34546's rule that forbids a system from maintaining
grandfather status if it is off line for more than six months, for the Complainants, is fair,just, and reasonable. Based on
the unique and undisputed facts in this case which we could not anticipate when we issued Order No. 34546.The relief
requested and granted in this case is limited solely to the facts in this case.The decision to grant the Complainants relief
shall not be construed as precedential in any future cases before this Commission."
In its order issued in that case,the Commission weighed the evidence specific to that situation to determine whether an
exception to the legacy treatment would be reasonable, however, did not go so far as to authorize a process for granting
exceptions.
Please let me know if you and/or the customer have any additional questions.
Regards,
Ashley Herrera
REGULATORY ANALYST
Idaho Power I Regulatory Affairs
Office 208-388-2656 1 Mobile [phone]
[e-mail]
From:Jon Kruck<[e-mail]>
Sent:Tuesday, February 13, 2024 3:19 PM
To: Martinez, Michael <[e-mail]>; Herrera,Ashley<[e-mail]>
Subject: RE: [EXTERNAL] IPUC-FERGUISON, LYDIA: Consumer Contact
Good afternoon Ashley,
was able to get in touch with the customer at 208-890-4393. Her address is 995 S. Linder Street, Meridian, Idaho
83642. Below is additional information obtained through our conversation:
"2/13/2024 2:12 pm
Called and talked with Lydia. I asked what the situation was, and Lydia replied that the county is taking her
property in an imminent domain action to construct the overpass across Interstate 84. Lydia has no say but to
accept the offer from the County and move. Lydia was told by her installer that she would be able to retain her
legacy status as she was being forced under a government action. Lydia stated that her installer talked with
someone from the Commission about it. I advised that I would look into that and I would call him. Lydia stated his
name is Stephen Witmer(208-991-7593). 1 looked at the Commission inquiries but was unable to find his name or
telephone number in our system. I advised Lydia that I would contact the Company for further information. Lydia
thanked me and the call ended.
2

------------------------------
2/13/2024 2:33 pm.
Called Stephen Witmer(208-991-7593) and no answer. Left a message with my contact information and asked
that he call me back.
-----------------------------
Idaho Power:
1) Due to an imminent domain situation by government action, in which the customer has no choice but to move
from their residence, is the Company willing to allow the customer to retain their legacy status of their solar
system as a one-time allowance?
Thank you,"
---------------------------
Thankyou,
Jon Kruck
Utilities Compliance Investigator
Idaho Public Utilities Commission
Direct: [phone]
Toll Free 1-800-432-0369
From: Martinez, Michael <[e-mail]>
Sent:Tuesday, February 13, 2024 9:03 AM
To:Jon Kruck<[e-mail]>; Herrera,Ashley<[e-mail]>
Subject: FW: [EXTERNAL] IPUC-FERGUISON, LYDIA: Consumer Contact
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.
Hi Jon,
Ashley will be happy to assist you with this Customer inquiry.
Thanks everyone,
Michael A. Martinez
Customer Service Support Specialist
Idaho Power I Customer Operations and Business Development
Office 208-388-5053
idahopower.com
3

-----Original Message-----
From: [e-mail] [mai Ito:[e-mail]]
Sent: Tuesday, February 13, 2024 8:51:20 AM
To: CSC IPUC
Subject: [EXTERNAL] IPUC-FERGUISON, LYDIA: Consumer Contact
Investigator may be contacted by email: jon.kruck(a�puc.idaho.gov
IDAHO PUC/208-334-0300 voice/208-334-3762 fax
Investigator : JKRUCK Jon Kruck
Date Opened : 02/13/2024
Contact Type : INQUIRY
Contact Method : Front Desk
Service Class : RESIDENCE
Reason : 0401 - Grandfathering / Interconnection
PUC ID : 10294
Name : LYDIA FERGUISON
Business Name : FERGUISON, LYDIA
Address
City
State : ID
Zip
Phone1
Phone1 Ext
Phone2
Phone2Ext
Narrative : From: Leslie Miracle <leslie.miracle(aD_puc.idaho.gov>
Sent: Tuesday, February 13, 2024 8:33 AM
To: PUC-Consumer <PUC-Consumer(@Puc.idaho.gov>
Cc: Front <front(c).puc.idaho.gov>
Subject: Lydia Ferguison, 208-709-6099, Solar Panels
Lydia said she is being forced to move because the County is taking over her property. She has solar panels
on her home that are grandfathered in with Idaho Power. She wants her solar panels that will be moved to her
new home to keep their grandfather status. She was told to call us.
Leslie MiracleIPUC Admin Assistant
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg. 8, Ste. 201-A
P.O. Box 83720
Boise, ID 83720
Direct: [phone] 1 Fax: [phone]
leslie.miracle(aD_puc.idaho.gov
------------------------
From: Curtis Thaden <Curtis.Thaden(a-)puc.idaho.gov>
Sent: Tuesday, February 13, 2024 8:37 AM
To: Leslie Miracle <leslie.miracle(a)-puc.idaho.gov>; Chris Hecht <Chris.Hecht(ftuc.idaho.gov>; Chris McEwan
<chris.mcewan(a-)puc.idaho.gov>; Curtis Thaden <Curtis.Thaden(a�puc.idaho.gov>; Jolene Bossard
<Jolene.Bossard(a�puc.idaho.gov>; Jon Kruck <jon.kruck(a_puc.idaho.gov>
Cc: Front <front(a_puc.idaho.gov>
Subject: Jon Assigned: RE: Lydia Ferguison, 208-709-6099, Solar Panels
4

No previous.
Curtis
--------------------------
2/13/2024 8:44 am
Called Lydia at the number provided and the person on the other end stated that it was a wrong number. The
persons name was Marie. Apologized and ended the call.
------------------------
Idaho Power:
1) Do you have a customer named Lydia Ferguison?
2) If so, please provide address and contact information for the customer.
Once I contact the customer, I will be back in touch with Idaho Power.
thank you
-----------------------
IDAHO POWER LEGAL DISCLAIMER
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