20240806RE_ Follow-up.pdf

From: Aaron Pace
To: Adam Young; Nesbitt,Quentin
Cc: Stucki,Matt;Jon Kruck; Eric Young;Allen Young
Subject: RE: Follow-up
Date: Tuesday,July 16,2024 5:08:14 PM
Attachments: imaae001.Dna
imaae002.Dno
imaae003.Dna
imaae004.Dno
imaae005.Dna
Quentin,
I would like to add that AgriPower Solar has had a long-standing,good relationship with Idaho Power.
From our first installation in Idaho,we've done things by the book.We've worked well together,
helping Idaho Power achieve its own green energy objectives by helping dozens of agricultural
businesses implement renewable energy systems in areas where Idaho Power needs them the most
(my perception).
The situation the Young's projects are in right now is specifically a situation of Idaho Power's making.
The Young's invested significant money based on what customer generation told us as the installer.
Customer generation even took the time to ensure regulatory was okay with that.You've likely seen
the correspondence already. If not, I'll be happy to send it to you.We are seeking approval—based on
Idaho Power's own recommendation—of a single,additional project of less than 100kW above
current maximum peak demand.The amount of time that Idaho Power has wasted stonewalling on
this issue is bizarre to me.This should have been an open-and-shut issue. Idaho Power is in error.
Remedying that mistake by approving the project for the Young's will cost Idaho Power virtually
nothing in the short-or long-term—apart from all the time that's been wasted in addressing this
issue.
Quentin, if Idaho Power will approve this application,we can all get on with doing other things.The
delays Idaho Power has caused are also costing the Young's money.We've talked to other clients
about pump size in place of peak demand but ultimately,we went back to them and told them it was
a non-starter.The Young's, however, have invested significant money in this, based on what Idaho
Power said. Is Idaho Power going to reimburse the Young's for the financial damages they've incurred
because of Idaho Power's suggestion to us and them?
Regards,
Aaron Pace [phone]
Chief Data Officer aaron(cDaaripowersolar.com
AgriPower Solar www.agripowersolar.com
40 W Truman Ave, Salt Lake City, UT 84115

From: Adam Young<[e-mail]>
Sent:Tuesday,July 16, 2024 4:04 PM
To: Nesbitt, Quentin <[e-mail]>
Cc: Stucki, Matt<[e-mail]>;Jon Kruck<[e-mail]>; Aaron Pace
<[e-mail]>; Eric Young<[e-mail]>; Allen Young
<[e-mail]>
Subject: Re: Follow-up
Thank you Quentin.As discussed in our phone call, it is our position that Idaho Power should
honor the plain language in the Schedule 84 tariff and honor the Company's previous approvals
and assurances that a factor of 0.8 x pump HP may be used to calculate max system size. In
this discussion,the four following points are of particular importance:
1.The approved tariff is the controlling document. It clearly states that the pump HP factor may
be used to determine max system size, both for customers who do not have billing demand
data for the previous 12 months AND for customers installing a system whose size exceeds
max billing demand from the previous 12 months.
2.The fact that Idaho Power has submitted a tariff advice seeking to change the language of the
Schedule 84 tariff serves as a tacit acknowledgement that their position is inconsistent with
the language in the currently-approved tariff.
3.We did not bring the language in Section 6 of the approved tariff to the attention of the
Company; rather,the Customer Generation team brought the language to our attention and
suggested we apply it as we have done.We have email correspondence in which we sought
confirmation that the language in question applied both to new irrigation systems and existing
systems with billing demand history.We were assured that it did.We were given several other
assurances and approvals over the course of several months.
4. Based on those communications, assurances, and approvals,we have had equipment
valued at over$1.4MM delivered to our farm.That equipment is currently sitting idle on a dry
field corner.
Adam Young
On Jul 16,2024, at 3:22 PM, Nesbitt, Quentin <ONesbittCa)idahopower.com>
wrote:

Adam,
Thank you for speaking with Matt and I today, your patience and inquiries about
this particular application are appreciated. After an ongoing internal review of this
matter including the history of communications with the installer, consideration
of other recent customer generator applications, and consultation with Idaho
Public Utility Commission ("IPUC") Staff, the Company reiterates the options
previously provided with respect to application ID 21027 as set forth in email
correspondence dated June 4th and July 9th . As noted previously, the Company's
treatment of application ID 21036 was a one-time exception based on the specific
circumstances associated with that application, but all other applications for
which billing demand is available will utilize billing demand, not HP, to determine
the max system size consistent with IPUC Order No. 36048.
Quentin Nesbitt
CUSTOMER RELATIONS AND PROGRAMS MANAGER
Idaho Power I Customer Operations
Office 208-388-2519 1 Mobile [phone]
1221 W. Idaho St. I Boise, ID 1 83702
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