20250515Staff Comments.pdf

RECEIVED
May 15, 2025
ERIKA K. MELANSON IDAHO PUBLIC
DEPUTY ATTORNEY GENERAL UTILITIES COMMISSION
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 11560
Street Address for Express Mail:
11331 W CHINDEN BLVD, BLDG 8, SUITE 201-A
BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER IN THE MATTER OF )
IDAHO POWER COMPANY'S ) CASE NO. IPC-E-25-15
APPLICATION FOR ITS FIRST ANNUAL )
UPDATE TO THE EXPORT CREDIT RATE )
FOR NON-LEGACY ON-SITE GENERATION ) COMMENTS OF THE
CUSTOMERS FROM JUNE 1, 2025 ) COMMISSION STAFF
THROUGH MAY 31, 2026, IN COMPLIANCE )
WITH ORDER NO. 36048 )
COMMISSION STAFF ("STAFF") OF the Idaho Public Utilities Commission
("Commission"), by and through its Attorney of record, Erika K. Melanson, Deputy Attorney
General, submits the following comments.
BACKGROUND
On May 1, 2023, Idaho Power Company("Company") applied for Commission
authorization to implement changes to the compensation structure applicable to customer on-site
generation under schedules 6, 8, and 84 and to establish an export credit rate ("ECR"). IPC-E-
23-14. In that filing, the Company proposed a methodology for determining annual updates to
the ECR. Id. In Order No. 36048, the Commission directed the Company to update all
components of the ECR except for the seasons and hours of highest risk in an annual filing
beginning April 1, 2025.
STAFF COMMENTS 1 MAY 15, 2025

In that case, Staff commented that updating the ECR annually ensures that export rates
closely resemble market conditions, and that non—generating customers are indifferent as to
whether the Company receives its power from the Company's existing resources or from
customer generators. Id. Expenses from the ECR are subject to 100%recovery through the
Company's Power Cost Adjustment ("PCA")mechanism. Order No. 30648 at 7.
The ECR update methodology includes updates to seven major data inputs. The ELAP
Hourly Market Prices and the annual hourly exports are updated annually to reflect the most
recent year of market price, export volumes, and export timing. IPC-E-23-14. Additionally, the
methodology will routinely update the levelized cost of the avoided proxy resource, Effective
Load Carrying Capability(`ELCC"), transmission and distribution("T&D") deferrals, line
losses, and variable energy resource ("VER") integration cost components as relevant studies are
completed.Id. These inputs are used to support three major components: the avoided cost of
energy, the avoided cost of generation capacity, and the avoided cost of transmission and
distribution capacity. Id. The value of these components is distributed across the Company's
seasons and hours of highest risk to determine rates for non-summer, summer off-peak, and
summer on-peak rates.Id.
THE APPLICATION
On April 1, 2025, in compliance with Order No. 36048, the Company filed to update the
ECR for non-legacy on-site generation customers from June 1, 2025, through May 31, 2026. In
this filing the Company is proposing to update each component of the ECR. The Company's
proposed ECR is 2.45 cents per kilowatt-hour("¢/kWh") on average. This represents a roughly
40% decrease from the current average rate. A full comparison of each component of the ECR is
presented below in Table No. 1.
STAFF COMMENTS 2 MAY 15, 2025

Table No. 1: Comparison of Current and Proposed ECR
Proposed Current
Season ECR ECR
Export Profile
Volume (kWh per kW) Annual 1,362 1,465
Capacity Contribution(%) Annual 10.07% 10.12%
Export Credit Rate by Component
(cents/kWh)
Energy Summer 1.76820 5.6533 ¢
Including integration and losses Non-Summer 0.95400 4.840
Annual* 1.28520 5.15660
Generation Capacity On-Peak 11.90170 11.170
Off-Peak 0.00000 0.00000
Annual* 1.13600 1.00820
Transmission & Distribution Capacity On-Peak 0.38990 0.180
Off-Peak 0.00000 0.00000
Annual* 0.03720 0.01670
Total Summer On-Peak 14.0598 ¢ 16.99660
Summer Off-Peak 1.76820 5.65330
Non-Summer 0.95400 4.83650
Annual* 2.45850 6.18140
STAFF ANALYSIS
Staff has reviewed the Application and supporting testimony and workpapers of
Company witnesses Jared Ellsworth and Mary Alice Taylor. Additionally, Staff has verified the
proposed tariff revisions and inputs to the ECR calculation. Based on its review, Staff believes
that the Company's Application is in compliance with Order No. 36048. However, Staff
discovered several issues that the Commission should consider.
STAFF COMMENTS 3 MAY 15, 2025

First, Staff s analysis suggests that the proposed ECR will result in a significant increase
to the bills of on-site generators. Staff recommends that the Commission implement a cap on
the amount of year-to-year change in the energy value component of the ECR.
Additionally, the Company proposed to update the integration cost component of the
ECR using values from the 2024 VER Study filed concurrently with this case.1 Application at
11-12. Staff recommends that the Commission decline the proposed update to the integration
cost value in this filing and utilize the currently approved value in this update.
Components of ECR Update
Avoided Energy Costs
The first component of the ECR update is the avoided cost of energy. This component
relies on ELAP market prices and hourly exports for the 2024 year, as well as avoided line loss,
and integration costs. The Company's update proposes to decrease this value from 5.6533¢/kWh
to 1.7682¢/kWh in summer months and from 4.8365¢/kWh to 0.9540 0/kWh in non-summer
months. Staff believes that the Company's proposed update to this value is consistent with Order
No. 36048.
This decrease is primarily driven by the lower ELAP prices in 2024, especially in the
spring,but also during the fall. The Company explains that during the spring, low demand and
high energy supply can create negative energy prices. Application at 10-11. This is due to large
amounts of hydro from spring runoff and more solar, in combination to lower demand for
electricity across the Pacific Northwest and the Western Interconnection. Id. Because demand is
low, this is also when the Company's system experiences the most exported power, contributing
to lower ELAP prices and thus lower export credit rates. Additionally, ELAP prices in 2022,
used to establish the current ECR, were significantly higher due to high natural gas and
electricity prices as a result of the war in Ukraine.
Contained in the Avoided Energy Cost is the value of avoided line losses. This value is
determined by line loss coefficients from the most recent line loss study as well as the ELAP
weighted-average market price. The Company is not proposing any update to the line loss
coefficients in this filing.
' Case No.IPC-E-25-07.
STAFF COMMENTS 4 MAY 15, 2025

Also, reflected in the avoided cost of energy are the integration costs. This value reflects
costs incurred by the Company to balance its system with the addition of variable resources such
as on-site renewable generation. The Company's update proposes to increase this value from
0.293¢/kWh to 0.697¢/kWh. This value comes from the Company's 2024 VER study submitted
in Case No. IPC-E-25-07 filed concurrently with the ECR update filing. Because of the
interdependence of these cases, any Commission order that affects the integration cost presented
by the 2024 VER study may change the calculation of the ECR.
As reflected in Staff s comments in the IPC-E-25-07 case, Staff has identified several
issues tied to the use of the 2024 VER study for purposes of the ECR integration cost
component. Because of these issues, Staff recommends that the Commission use the current
value of the 0.293¢/kWh in this filing. Staff has recommended, in IPC-E-25-07, that the
Company conduct another VER study within 6 months after the 2025 Integrated Resource Plan
("IRP")has been filed. This will give Staff and the Company time needed to reconcile some of
the issues so that the integration costs can be confidently used in the 2026 ECR annual update.
Should the Commission accept Staffs recommendation to mitigate year-to-year volatility
in the energy value component of the ECR, as presented below, it will also effectively limit the
amount of integration cost discounted from the avoided energy value included in the ECR.
Avoided Generation Capacity
Avoided Generation Capacity represents the value of a proxy resource that is deferred or
delayed through the capacity contributions of on-site generation. This value is applied only to
summer on-peak hours as the value is only realized when the Company's system is most in need
of additional resources. The value of the component is calculated using the value of the next
least-cost proxy resource, the ELCC of historic exports, and 2024 hourly export data. The
Company's update proposes to increase the avoided cost of generation capacity from
11.17¢/kWh to 1 L9017¢/kWh. Staff believes that the Company's proposed update to this value
is consistent with Order No. 36048.
This increase is primarily driven by increased maximum exported capacity. The
maximum exported capacity or nameplate capacity of exports in 2024 increased from 62.86 MW
to 107.13 MW. Total on-peak exports also increased from 6,255 MWh to 13,924 MWh. The
proxy resource used for this filing is a simple cycle combustion turbine identified as the least
STAFF COMMENTS 5 MAY 15, 2025

cost resource in the 2023 IRP. This value is not updated in this filing. In its Application, the
Company also updated the ELCC of exports to reflect a 5-year rolling average as directed in
Commission Order No. 36048. This updated component decreased from 10.12%to 10.07%.
Avoided T&D Costs
The Avoided T&D costs component reflects the value of T&D projects that the Company
was able to defer because of exports from customer generators. This value is influenced by solar
penetration, 2024 export data, and the number of deferrable projects. The value of avoided T&D
is applied to summer on-peak hours when the Company's T&D system is most strained. The
Company's update proposes to increase this value from 0.1755 0/kWh to 0.3899 0/kWh. This
increase is primarily driven by an increase in the number of deferrable projects. Staff believes
that the Company's proposed update to this value is consistent with Order No. 36048.
Customer Bill Impact
Staff believes that the onsite generation classes (Schedules 6, 8, 84)have faced an
extraordinary increase in monthly bills over the past 18 months.
Although billing increases exist for all three classes, Staff focused its analysis on
Schedule 6 because this class vastly outsizes the other two classes. Company Exhibits Nos. 6
through 9 show that there were 11,646 Schedule 6 accounts, 28 Schedule 8 accounts, and 78
Schedule 84 accounts. Because a single ECR is calculated and applied to all three classes, Staff
believes it is reasonable to analyze Schedule 6 results and assume the impacts will be similar for
Schedules 8 and 84.
Impact of the Proposed ECR
Company Exhibit No. 6 shows that the average monthly bill for Schedule 6 customers
will increase from $62.35 to $83.62 if the proposed ECR is implemented. This is an average
increase of 34%; however, the data also shows that the impact varies within the class depending
on each customer's average amount of imports as shown in Table No. 2,below.
STAFF COMMENTS 6 MAY 15, 2025

Table No. 2—Average Monthly Bill Impact of Proposed ECR Rates
Average Monthly Bill*
% from
Category Count Current Proposed Current
0<500 kWh 3,218 $ 25.30 $ 40.47 60.0%
500<900 kWh 4,629 $ 47.70 $ 67.08 40.6%
900< 1,300 kWh 2,010 $ 75.56 $ 101.21 33.9%
1,300< 1,700 kWh 916 $ 107.30 $ 138.29 28.9%
1,700 kWh+ 873 $ 199.05 $ 232.59 16.8%
All Customers 11,646 $ 62.35 $ 83.62 34.1%
*Bill calculations do not include the PCA,FCA and other riders
Customers who import the least (and presumably export the most) would experience a
bill increase of approximately 60%. Conversely, customers who import the most(and
presumably export the least) would experience a bill increase of approximately 17%. However,
individual impacts may vary widely even within these sub-groups.
Impact of Net Billing and Base Rate Increases
The same customers discussed above saw a significant rate increase when the Net Billing
went into effect on January 1, 2024. Prior to that date, these non-legacy customers were still
compensated for exports under Net Metering, which allowed one-for-one kilowatt-hour("kWh")
credits for each exported kWh. Using the same 2024 data as above,but applying the Net
Metering credit system, Staff calculated the amount each of these customers would have paid to
the Company for consumption net their exports. Assuming each customer started with zero kWh
credits in their account(a conservatively low assumption), the average customer bill would have
been $50.14. This means customer bills increased by an average of 24% in January 2024 when
the Net Billing policy went into effect.
Table No. 3 below shows the average monthly billing impact going from Net Metering to
the current Net Billing system.
STAFF COMMENTS 7 MAY 15, 2025

Table No. 3—Average Monthly Bill Impact from Net Metering to Current ECR Rates
Average Monthly Bill*
% from
Category Count Net Meter Current Net Met.
0<500 kWh 3,218 $ 21.90 $ 25.30 15.5%
500<900 kWh 4,629 $ 36.54 $ 47.70 30.5%
900< 1,300 kWh 2,010 $ 59.85 $ 75.56 26.2%
1,300< 1,700 kWh 916 $ 85.65 $ 107.30 25.3%
1,700 kWh+ 873 $ 166.64 $ 199.05 19.5%
All Customers 11,646 $ 50.14 $ 62.35 24.4%
*Bill calculations do not include the PCA,FCA and other riders
If the two increases are combined(1. Net Metering to Net Billing; 2. Current ECR to
Company proposed ECR), the average Schedule 6 customer would experience a rate increase of
67% in just 18 months. Customers who are heavy exporters may see rate increases of more than
100%.
During this same period, two base rate increases also occurred, the first taking effect
through Case No. IPC-E-23-11 on January 1, 2024, and the second taking effect through Case
No. IPC-E-24-07 on January 1, 2025. Because these rate changes occurred for all ratepayers,
Staff attempted to exclude the effects of these increases and only focused on the effects of Net
Billing and the ECR. Therefore, for the previous two tables, Staff used the most current tariff
rates, including a $15 service charge and the current 2025 energy charges. If Staff had used the
$5 service charge and 2023 rates, Staff believes the average bill impact to Schedule 6 customers
would be approximately 75% over the past 18 months.
Mitigation Proposal
To mitigate this large increase to customer bills, Staff proposes that the amount of year-
to-year change to the ECR be capped. The net effect of this proposal is to stabilize the ECR and
provide more stable bills for onsite generators.
Proposed Mitigation Method
Rate stability is considered to be an important regulatory objective to prevent customers
from experiencing rate shock. For example, during general rate cases, the change in revenue
STAFF COMMENTS 8 MAY 15, 2025

requirement allocated to each class can be capped to keep rates from changing too much for any
given class. These caps can consist of both ceilings and floors to limit the amount of change.
Consistent with this objective, Staff proposes that the Commission apply a similar
concept to the ECR. However, because the ECR is fundamentally different than the rate spread
of a revenue requirement, the capping mechanism needs to be customized specific to how the
ECR is developed.
The ECR consists of two components: the value of avoided energy costs and the value of
avoided capacity costs. Staff proposes that the mechanism for capping ECR rates focus on
limiting the amount of year-to-year change on only the avoided energy value and not the avoided
capacity value for four reasons. First, the avoided energy value is the most significant factor in
the ECR calculation, and it contributes to all variations of the ECR—the summer and non-
summer rates, as well as the on-peak rates. Second, because the avoided energy value is tied to
the market based on one-year of historical data, it is the component that will likely have the most
year-to-year volatility since market prices are driven by weather, hydro availability, gas supply
and prices, changes in load, etc. Third, the capacity value only occurs during a few critical hours
of the summer season, thus it is only applied to on-peak exports. Limiting the capacity value
would have a negligible financial impact on most onsite generation customers, and it would
dilute the incentive for these customers to export during capacity critical hours. Fourth, the
calculation for the avoided cost of capacity already contains some level of mitigation in the 5-
year rolling average of historical ELCC values.
In summary, Staff recommends that the Commission approve a mechanism to limit the
amount of year-to-year change to the ECR by capping the amount of change in the value of the
avoided energy cost component of the ECR.
Details of the Proposal
Staffs specific proposal is to symmetrically limit the amount of change in ECR energy
value to 30% (from the current ECR energy value)both up or down. In other words, the new
ECR energy value cannot go below 70% of the current value, nor can it climb above 130% of the
current value. Staff proposes that this cap be applied separately to the Summer and Non-
Summer energy values.
STAFF COMMENTS 9 MAY 15, 2025

For example, the current summer energy value is 5.6 cents/kWh. The lowest value it can
become is 3.9 cents/kWh (5.6 x 0.7). The highest it can become is 7.3 cents/kWh (5.6 x 1.3). If
the value dropped to 3.9 cents/kWh the following year, the lowest value it can become is 2.7
cents/kWh(3.9 x 0.7).
Table No. 4 compares the various ECRs that would result this year if caps of 20, 30, and
40%were applied.
Table No. 4-Alternative ECRs if Cap is Applied
Export Credit Rate by Component(cents/kWh) Max Change current proposed 20% 30% 40%
Energy Summer 5.65330 1.76820 4.52260 3.95730 3.39200
Including integration and losses Non-Summer 4.83650 0.95400 3.86920 3.38560 2.90190
Annual* 5.15660 1.28520 4.13500 3.6181 ¢ 3.10130
Generation Capacity On-Peak 11.58620 11.90170 11.90170 11.90170 11.90170
Off-Peak 0.00000 0.00000 0.00000 0.00000 0.00000
Annual* 0.78710 1.13600 1.13600 1.13600 1.13600
Transmission&Distribution Capacity On-Peak 0.24560 0.38990 0.38990 0.38990 0.38990
Off-Peak 0.00000 0.00000 0.00000 0.00000 0.00000
Annual* 0.01670 0.03720 0.03720 0.03720 0.03720
Total Summer On-Peak 17.48500 14.05980 16.8142¢ 16.24890 15.68360
Summer Off-Peak 5.65330 1.76820 4.5226¢ 3.95730 3.3920¢
Non-Summer 4.83650 0.95400 3.86920 3.38560 2.90190
Annual* 5.96030 2.45850 5.30830 4.79140 4.27450
Table No. 5 shows the average monthly bill increase (for Schedule 6 customers) if the
energy caps of 20, 30, or 40%were applied.
Table No. 5-Average Billing Impact(Schedule 6)
Export Credit Rate by Component(cents/kWh) Max Change current proposed 20% 30% 40%
Monthly Bill Increase (from current ECR) 34.1% 8.6% 13.3% 17.9%
Staff believes that an average monthly bill increase of approximately 13% is reasonable
and therefore recommends a 30%year-to-year change limit.
Impact of Mitigation Proposal
If Staff s mitigation proposal is accepted by the Commission, it is likely that customers
consuming energy from the system would pay either a cost higher than avoided cost for the
exported energy or lower than avoided cost depending on whether the mitigated energy cost
included in the ECR is higher or lower than the avoided cost amount. Customers would no
longer be indifferent as to whether they receive energy from customers who export energy or
receive energy from the Company's system resources.
STAFF COMMENTS 10 MAY 15, 2025

Regardless of whether the Company overpays or underpays for customer-generated
exports, all the expenses are treated the same as any other purchased power expense through the
PCA. Costs in the PCA are recovered from all customers on an equal cents per kilowatt-hour
basis including the three onsite generator classes (Schedules 6, 8, 84),
Staff estimates that its proposal to limit the ECR change to 30%would result in an
increase of about $4-5 million in ECR payments over the coming year. This amount is less than
one percent of annual net power supply expense.
Future ECR Updates
If the Commission agrees with Staff s ECR mitigation proposal, Staff also proposes that
the ECR percentage cap remain in place indefinitely, whether the energy value goes up or down.
Staff believes this cap will smooth out large energy price swings. If the weighted energy price
were to remain where it is now for several years, the ECR would eventually become equal to the
unmitigated value in two years. If the weighted energy price were to climb back up to 2022
levels, the ECR would take two to three cycles to equalize to the unmitigated value. Over time
the ECR should remain somewhere between the highest and the lowest energy values,
incrementally chasing toward the most recent energy value.
Consolidation of DER Annual Report
In its Application the Company included a Distributed Energy Resource ("DER") Status
Report. Historically, this report has been submitted as a compliance filing in Case No. IPC-E-12-
27. The Company states that it believes that submitting the DER Status Report as part of the
ECR update filing will increase transparency for the Commission, Staff, customers, and other
stakeholders. Application at 15. Staff agrees with the Company and recommends that the
Commission acknowledge the Company's intended action.
Customer Notice
The Company's customer notice was included along with its application. The notice, a
postcard, was mailed on April 8, 2025, to all non-legacy customers and customers with a
STAFF COMMENTS 11 MAY 15, 2025

customer generation application in a"pending" status as of April 1, 2025,2 providing a
reasonable opportunity to file timely comments with the Commission by the May 15, 2025,
comment deadline.
Public Workshops
On April 28, 2025, the Commission issued a press release announcing a public
workshop. The IPUC workshop was held on the evening of May 7, 2025. The workshop
was well attended with approximately 69 customers in attendance. The Company's
Application was discussed and Staff addressed customers' comments and concerns
regarding the Application and Commission procedure. Customer concerns echoed those
presented in customer comments submitted to the case record. Prior to the workshop,
202 customers (24%) requested both virtual workshops and virtual public hearings.
Customer Comments
As of May 15, 2025, 850 public comments have been filed in this case. Of the 850
customers who made comments, 751 customers (88%3) opposed the proposed changes to
the ECR. Additionally, 364 customers (43%) identified as non-legacy customers.
Although 364 customers identified themselves as non-legacy, Staff believes the
overwhelming majority of those that offered comments are non-legacy on-site generation
customers due to the nature of the Company's proposal.
Previous Orders/Studies
Some customers expressed concerns regarding grandfathering with 53 customers
(6%) stating that current non-legacy customers should be granted legacy status. There
were 40 customers (5%) who questioned the validity of the VODER study, and 42
customers (5%) who suggested that the Commission review current or do additional
z On April 1,Idaho Power will change its"application received"email to include a statement about the filing,the
proposed ECR and a link to the Company's website where additional information can be found.The message will
run between April 1 and May 31,and be replaced with a default message on June 1 ("The ECR will be updated
annually each June").
3 Percentages are in reference to the total number of customers from the most recent comment count.
STAFF COMMENTS 12 MAY 15, 2025

studies. There were 221 customers (26%) who urged further consideration of
environmental benefits.
Compensation and Economics
Concerning any change to compensation, 61 customers (7%) wanted to keep
monthly net metering (1:1)versus real time metering (ECR) and as previously stated,
751 customers (88%) opposed the proposed changes to the ECR.
Regarding the monthly billing, 108 customers (13%) cited a higher monthly overall
energy cost as a solar customer, when factoring in the cost of the installed system and the
reduction in the ECR(Case No. IPC-E-23-14). Additionally, 139 customers (16%)
highlighted the large financial investment they made in purchasing a net generation system.
There were 187 customers (22%)who objected to the recent increases in the monthly
service charge, and 184 customers (22%)who cited the impact of multiple increases in rates,
in a very short period. In addition, 186 customers (22%) said they had no other choice of a
provider because they believe that Idaho Power is a monopoly.
Additionally, there were 301 customers (37%) who felt the compensation rate was
unfair. The comments stated that they believe that Customers pay the applicable retail rate
but are not compensated at the same rate when they place electricity back onto the grid.
Some customers felt Idaho Power is profiting by paying them less than the applicable retail
rate and then reselling the electricity at the higher retail rate. Several of these customers
discussed adding batteries to their systems to save excess power for their own use.
Installers and Annual ECR
Based on the customer comments, it appears that many of the solar installers are
not providing accurate or updated information regarding the ECR. Many customers
seemed to be unaware that an annual adjustment will be made to the ECR. Customers
also claimed they were not aware of possible changes to the program at the time they
purchased and installed their systems. Several customers stated they would not have
gone forward had they known the rates would change.
STAFF COMMENTS 13 MAY 15, 2025

Company Compensation
There were 274 customers (33%) who mentioned high Company profits, Company
greed, unfair compensation and referenced Company CEO salary and Company Board
compensation.
Disincentives
There were 309 customers (36%) who felt Idaho Power is penalizing and/or discouraging
customers for generation of clean energy after specifically advocating for customers to "go green"
and install solar.
STAFF RECOMMENDATIONS
Staff recommends that the Commission issue an order:
1. Approving Staffs proposed 30%cap on the change in avoided energy costs year to year;
2. Rejecting the Company's proposed integration costs for the ECR and use the currently
approved value;
3. Approving Staff s proposed ECR update values detailed above; and
4. Acknowledging the Company's consolidation of DER status report into annual ECR
update filings.
Respectfully submitted this 15th day of May 2025.
PW�atl - Y
Erika K. Melanson
Deputy Attorney General
Technical Staff: Jason Talford
Matt Suess
Jolene Bossard
Curtis Thaden
1:\Utility\UMISC\COMMENTS\IPC-E-25-15 Comments.docx
STAFF COMMENTS 14 MAY 15, 2025

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS L DAY OF MAY 2025, SERVED
THE FOREGOING COMMENTS OF THE COMMISSION STAFF , IN CASE NO. IPC-E-
25-15, BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
MEGAN GOICOECHEA ALLEN CONNIE ASCHENBRENNER
DONOVAN E. WALKER MARY ALICE TAYLOR
IDAHO POWER COMPANY IDAHO POWER COMPANY
PO BOX 70 PO BOX 70
BOISE ID 83707-0070 BOISE ID 83707-0070
E-MAIL: E-MAIL: caschenbrennergidahopower.com
mgoicoecheaallengidahopower.com mtaylorgidahopower.com
dwalkergidahopower.com
do cketsgidahopower.com
Kevin Dickey,pro se
P.O. Box 337
Emmett, ID 83617
E-MAIL: Bellefourche0IgMail.com
Kelsey Jae Courtney White
920 N. Clover Drive Mike Heckler
Boise, ID 83703 Clean Energy Opportunities for Idaho
E-MAIL: kelsey_gkelseyjae.com 3778 Plantation River Dr., Ste. 102
Boise, ID 83703
E-MAIL:
courtneygcl eanenergyopportunities.com
mikegcleanenergyopportuniti es.com
PATRICIA JORDAN, ECRETARY
CERTIFICATE OF SERVICE