20250522Reply Comments.pdf

Mq%
-1 POWER.
MEGAN GOICOECHEA ALLEN
Corporate Counsel
mgoicoecheaallen(cDidahopower.com RECEIVED
May 22, 2025
IDAHO PUBLIC
May 22, 2025 UTILITIES COMMISSION
Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Boulevard
Building 8, Suite 201-A
Boise, Idaho 83714
Re: Case No. IPC-E-25-15
Application for Its First Annual Update to the Export Credit Rate for Non-
Legacy On-Site Generation Customers from June 1, 2025 through May 31,
2026, In Compliance with Order No. 36048
Commission Secretary:
Attached for electronic filing is Idaho Power Company's Reply Comments in the
above-entitled matter.
If you have any questions about the attached documents, please do not hesitate
to contact me.
Sincerely, n��A
Akr T i
Megan Goicoechea Allen
MGA:sg
Enclosures
P.O.Box 70(83707)
1221 W.Idaho St.
Boise,ID 83702

MEGAN GOICOECHEA ALLEN (ISB No. 7623)
DONOVAN WALKER (ISB No. 5921)
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
mgoicoecheaallen(a).idahopower.com
dwalker(a)idahopower.com
Attorneys for Idaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER )
COMPANY'S APPLICATION FOR ITS ) CASE NO. IPC-E-25-15
FIRST ANNUAL UPDATE TO THE EXPORT )
CREDIT RATE FOR NON-LEGACY ON- ) IDAHO POWER COMPANY'S
SITE GENERATION CUSTOMERS FROM ) REPLY COMMENTS
JUNE 1, 2025 THROUGH MAY 31, 2026, IN )
COMPLIANCE WITH ORDER NO. 36048. )
COMES NOW, Idaho Power Company ("Idaho Power" or "Company") in
accordance with Rule 203 of the Rules of Procedure of the Idaho Public Utilities
Commission ("Commission") and Order No. 36558, issued April 21, 2025, respectfully
submits its Reply Comments in the above-referenced case as follows.
At the outset, the Company believes it is important to clarify that the Company is
not making a new proposal in this case. Rather, the Company's filing represents an
annual cost adjustment to the reimbursement rate for excess energy generated by on-
site generators based on the Commission-approved methodology that was established in
2023, which represented the culmination of a years-long, multi-phase collaborative
process to modernize an outdated service offering including modifying the compensation
IDAHO POWER COMPANY'S REPLY COMMENTS - 1

structure for on-site generators to more accurately measure, record, and value excess
energy. Of note, no party to this case has taken the position that the Company's update
failed to follow the Commission's direction, with Staff concluding that the Company's
Application complied with Order No. 36048.1 However, in recognition that this inaugural
update results in varying customer bill impacts, with some customers subject to relatively
large bill increases, the Company has presented a one-time mitigation option for the
Commission's consideration.
Accordingly, the Company respectfully requests that the Commission issue an
order: (1) acknowledging that its filing conformed with the Commission-approved annual
Export Credit Rate ("ECR") update method outlined in Order No. 36048; (2) authorizing
Idaho Power to implement the updated ECR for non-legacy on-site generation customers
effective June 1, 2025, as directed in Order No. 36048; (3) as needed, directing the
Company to submit corrected tariff sheets reflecting the incorporation of any mitigation
measures ordered by the Commission; and (4) acknowledging the Company's
consolidation of the Distributed Energy Resource ("DER") status report into the annual ECR
update.
Idaho Power appreciates the opportunity to offer these Reply Comments and provides
the following table of contents to assist in the review of the same:
In the Matter of Idaho Power Company's Application for its First Annual Update to the Export Credit
Rate for Non-Legacy On-Site Generation Customers from June 1, 2025 Through May 31, 2026, in
Compliance with Order No. 36048, Case No. IPC-E-25-15, Staff Comments at 3 (May 15, 2025).
IDAHO POWER COMPANY'S REPLY COMMENTS -2

Table of Contents
I. INTRODUCTION...................................................................................................... 3
II. SCOPE OF THE CASE............................................................................................ 8
III. COMPONENTS OF THE ECR............................................................................... 12
A. Avoided Energy............................................................................................. 12
B. Avoided Generation Capacity........................................................................ 19
C. Transmission and Distribution Capacity........................................................ 23
IV. MITIGATION ..........................................................................................................25
V. DER REPORT........................................................................................................ 33
VI. PUBLIC COMMENTS ............................................................................................ 34
VII. CONCLUSION ....................................................................................................41
I. INTRODUCTION
1. The instant case was initiated in compliance with Commission Order No.
36048 issued in Case IPC-E-23-14 on December 29, 2023. That order approved changes
to the Company's on-site generation service offerings including, in pertinent part,
implementing, effective January 1, 2024, a seasonal and time-variant ECR with avoided
cost-based value considerations for excess energy exported to Idaho Power's system by
non-legacy customers as well as approving a methodology for determining annual
updates to the ECR.2 In authorizing changes to the Company's on-site generation
offering, the Commission emphasized that the fundamental purpose of on-site generation
is to offset a customer's own usage, that on-site generation should not create cost shifting
between generators and non-generators, and that on-site generators should be given a
fair value for their exported energy.'
2 In the Matter of Idaho Power Company's Application for Authority to Implement Changes to the
Compensation Structure Applicable to Customers On-Site Generation Under Schedules 6, 8, and 84 and
to Establish an Export Credit Rate, Case No. IPC-E-23-14, Order No. 36048 at 6 (Dec. 29, 2023).
3 Id., at 5.
IDAHO POWER COMPANY'S REPLY COMMENTS - 3

2. Notably, the methodology that was ultimately approved by the Commission
was informed and refined by feedback from Staff and the Parties in that case, which
included a number of the same Parties involved in the instant docket. In developing its
final proposal, the Company included modifications to its initially proposed ECR that were
responsive to Party feedback, ultimately seeking to pursue a structure that would enhance
understandability and transparency, while ensuring progress towards modernizing the
customer on-site generation offering. While the methodology adopted by the Commission
through Order No. 36048 incorporated elements of the Company's revised proposal in
addition to many of the proposed modifications recommended by Staff and other Parties,
other changes advocated for by various Parties were considered and declined. As noted
by the Commission:
The parties have presented differing sets of proposals related to the
Company's Application, including among other things proposals for the
measurement interval applied for measuring energy, the valuation of the
ECR, and various administrative items related to the implementation of an
avoided cost-based ECR. In this Order, the Commission has striven to
accurately assign the appropriate share of fixed costs and unquantified
benefits of on-site customer generation, and to provide a reasonable
balance between the interests of customers with on-site generation, and
customers without.4
3. Having approved the methodology for determining the ECR, as well as the
source to be relied on for each of its components in Case No. IPC-E-23-14 ("the ECR
Methodology Case"), the Commission further ordered that the Company update all
components of the ECR, except the season and hours of highest risk, in an annual filing
beginning in 2025, with a filing date of April 15 and an effective date of June 1.6
4 Id., at 5-6.
5 Id., at 7.
6 Id., at 18.
IDAHO POWER COMPANY'S REPLY COMMENTS -4

Accordingly, as directed by the Commission, on April 1, 2025, the Company filed its first
annual update of the ECR for non-legacy on-site generation customers from June 1,
2025, through May 31, 2026, using the inputs and methods prescribed by the Commission
in the ECR Methodology Case.
4. As directed by the Commission, the Company's first annual update reflects
2024 energy market prices, which were notably lower than the 2022 market prices
incorporated in the original rate that were elevated due to the impacts of the pandemic,
drought conditions, and economic changes. Future rate updates will likewise be affected
by changes, up or down, to electricity prices influenced by a range of dynamic factors not
dictated by the Company.
5. The Company understands and appreciates the intense interest in this case
and realizes that many commenters may not be aware that the ECR being implemented
in this docket is an annual update based on a methodology that was previously vetted,
informed, and refined through a collaborative and iterative process and represents the
culmination of a multi-year effort to have the Commission review and modify the outdated
net metering offerings to better align with the actual circumstances.'
6. The regulatory history reflects a longstanding recognition that the simplified
compensation structure that was established in 2002, which credited excess on-site
The situation and issues confronting the Commission are not dissimilar to those that have, are, or will be
faced by numerous state regulatory commissions nationwide. The NC Clean Energy Technology Center's
("NCCETC") annual review noted that in 2024, nearly every state in the country considered solar policy or
rate design changes. NCCETC, The 50 States of Solar. States Continue to Move Away From Traditional
Net Metering, While Fixed Charge Increases Rebound in 2024, Jan. 23, 2025 [Press release] ("During
2024, we continued to see states move away from traditional net metering and toward alternative
compensation structures, like net billing, for distributed generation . . . The focus of these changes has
been on netting intervals and export credit rates . . ."). Available at:
https://nccleantech.ncsu.edu/2025/01/23/the-50-states-of-solar-states-continue-moves-away-from-
traditional-net-metering-while-fixed-charge-increases-rebound-in-2024/
IDAHO POWER COMPANY'S REPLY COMMENTS - 5

generation at the full retail rate, overvalues exports from on-site generation and results in
cost shifting between participants and non-participants. In considering the practice of
retail rate net metering over twenty years ago, Commission Staff cautioned:
For the Commission to accept a net metering tariff where customer
generation is credited at full retail rates, it must be willing to accept the fact
that Idaho Power may not recover its full costs of providing service from net
metering customers. 8
For its part, the Commission was amenable to this valuation approach in 2002 despite
concerns that some of the costs of serving net metering customers would likely be
subsidized by other customers given the limits on participation and its mandate for future
monitoring and assessment of the new service offering as experience was gained and
conditions evolved.9
7. In fact, in the decades that followed, knowledge and circumstances have
changed dramatically — increased technological and financial feasibility of on-site
generation helped to fuel rapid growth in customers participating in net metering and
advanced metering and billing improvements made a more nuanced approach possible.
The need to modernize the on-site generation compensation structure was well
established and the Commission laid the groundwork for the same in a long series of
customer generation dockets, including establishing a process to ensure changes to the
Company's on-site generation service offering were well-reasoned and data driven,
8 In the Matter of the Application of Idaho Power Company for Approval of a New Schedule 84—Net
Metering Tariff, Case No. IPC-E-01-39, Comments of the Commission Staff at 3 (Dec. 21, 2001).
9 Id., Order No. 28951 at 11-12 (Feb. 13, 2002); In the Matter of the Application of Idaho Power Company
forAmendments to Schedule 84—Net Metering, Case No. IPC-E-02-04, Order No. 29094 at 7 (Aug. 21,
2002).
IDAHO POWER COMPANY'S REPLY COMMENTS -6

directing that any changes were to be based on a comprehensive, Commission-approved
study.10
8. As it gained experience, the Company took incremental steps to prepare for
eventually updating its on-site generation offering to be better aligned with current
circumstances, economically supportable, and fair to all customers. Throughout this
process, the Company was committed to utilizing a collaborative approach and actively
pursued public involvement as it worked to fulfil the Commission's mandate. Similarly,
Idaho Power has endeavored to ensure customers were and are fully apprised of the
potential changes, undertaking extensive efforts — including numerous direct mailings —
over the years to communicate with both customer-generators and non-participating
customers regarding the on-site generation service offering and regulatory proceedings
related to potential changes.
9. Building on the foundation laid in the preceding cases, the final step in the
progression of the Company's on-site generation service offering was the Commission's
approval of the updated offering in Final Order No. 36048 issued on December 29, 2023,
in the ECR Methodology Case, including approval of the ECR methodology and the
direction for the Company to "update all proposed components of the ECR except the
season and hours of highest risk in an annual filing beginning April 1, 2025."11 The instant
case represents the Company's first annual compliance filing pursuant to Order No.
36048.
10 See, e.g., IPUC Case No. IPC-E-17-13; IPUC Case No. IPC-E-18-15; IPUC Case No. IPC-E-20-26;
IPUC Case No. IPC-E-21-21; and IPUC Case No. IPC-E-22-22.
" Case No. IPC-E-23-14, Order No 36048 at 7.
IDAHO POWER COMPANY'S REPLY COMMENTS - 7

II. SCOPE OF THE CASE
10. With the Commission having previously established the method for
calculating the ECR, including specifying the inputs and methods for updating the various
components, the question now before the Commission is limited to whether the Company
has properly applied the Commission-approved formula.
11. The Company appreciates the Commission facilitating an interactive
process as well as the level of public and stakeholder engagement in this proceeding.
Despite the limited scope of this docket, in addition to providing the opportunity for
interested persons to provide written comments on the Company's Application, the
Commission incorporated both a public workshop and a customer hearing to ensure that
members of the public were informed and had access to clear, transparent, and factual
information. Pursuant to the Commission's scheduling order, comments have been
submitted by Commission Staff ("Staff"), Clean Energy Opportunities for Idaho ("CEO"),
Kevin Dickey, pro se, Scott Pinizzotto, pro se, Martha Bibb, pro se, City of Boise City
("Boise City"), Sierra Club and Vote Solar("SC&VS") (collectively called "Parties"). Others
who petitioned for intervention but have not yet been granted intervention also filed
Comments, this includes Tyler Grange. Additionally, there were over 850 written public
comments received as of May 15, 2025, and approximately 45 customers provided
testimony at the May 20, 2025, customer hearing.
12. As an initial matter, the Company notes that many of the comments
overlook the regulatory precedent and/or the role that stakeholder feedback played in
previously developing the ECR methodology. In other words, many of the issues raised
have already been addressed by the Commission or are otherwise outside the scope of
IDAHO POWER COMPANY'S REPLY COMMENTS - 8

this compliance filing docket.
13. For example, in the ECR Methodology Case, the Commission explicitly
considered a proposal made by Vote Solar to use a three-year historical rolling average
of market prices to mitigate severe price swings in the avoided energy value from year to
year and improve customer predictability and stability.12 Though the Commission
ultimately rejected that proposal in the ECR Methodology Case, in this compliance
docket, SC&VS again recommends use of a three-year average of energy prices to help
mitigate severe swings in the ECR value from year to year.13 In making its decision in the
ECR Methodology Case, the Commission was aware of the potential swings in year-over-
year market prices— not only did Vote Solar point that out in comments, but the previously
acknowledged 2022 Value of Distributed Energy Resources ("VODER")14 Study
contained three years of historical Energy Imbalance Market ("EIM") Load Aggregation
Point ("ELAP") prices. The Commission weighed that evidence — among hundreds of
pages of other evidence — when establishing a single-year methodology.
14. While the Company understands that many of those that have offered
comments in this docket disagree with the ECR methodology previously adopted by
Commission Order No. 36048, that order has become final and conclusive, and it is not
appropriate for Parties to now challenge, within this compliance docket, the methods for
calculating the ECR components, or to seek to deviate from the annual update process
directed by the Commission; such efforts represent an impermissible collateral attack on
12 Id., Vote Solar Comments at 16 (Oct. 12, 2023).
13 Case No. IPC-E-25-15, SC&VS Comments at 9 (May 15, 2025).
14 In the Matter of Idaho Power Company's Application to Complete the Study Review Phase of the
Comprehensive Study of Costs and Benefits of On-Site Customer Generation &for Authority to
Implement Changes to Schedules 6, 8, and 84, Case No. IPC-E-22-22, Order No. 35631 at 31 (Dec. 19,
2022).
IDAHO POWER COMPANY'S REPLY COMMENTS - 9

Order No. 36048 in violation of Idaho law. Idaho Code § 61-625 provides: "All orders and
decisions of the commission which have become final and conclusive shall not be
attacked collaterally." Final orders of the Commission should be challenged either by
petition to the Commission or appeal to the Idaho Supreme Court as provided by Idaho
Code §§ 61-626 and 61-627. "A different rule would lead to endless consideration of
matters previously presented to the Commission and confusion about the effectiveness
of Commission orders.1115
15. While it is true that the Commission, as a regulatory agency that performs
both legislative and quasi-judicial functions, is not so rigorously bound by the judicial
doctrine of stare decisis; a departure from prior decisions must be based on substantial
and competent evidence in the record and sufficient findings.16 There is simply no basis
justifying a departure from Order No. 36048 in this compliance case, and in the absence
of the same, it is not appropriate for Parties to re-raise the same issues. It would be
disingenuous for parties to suggest that events occurring between the time of the
Commission decision in the ECR Methodology Case and this first ECR update revealed
that an energy value based on a singular year of market prices results in instability based
on the record in that case, which clearly demonstrates that very issue was considered.
Vote Solar specifically argued that using a three-year historical rolling average of market
prices would help to mitigate severe price swings in the avoided energy value from year
to year and provide improved predictability and stability for customers, stating further:
It is worth noting that this evaluation of avoided energy costs relies on
market prices for electricity during 2022, when prices were unusually
elevated. The market cost of electricity is volatile and influenced by a variety
of external factors including fuel prices, extreme weather, and global
15 Utah-Idaho Sugar Co. v. Intermountain Gas Co., 100 Idaho 368, 373-374, 595 P.2d 1058 (1979).
16 Rosebud Enters., Inc. v. Idaho Pub. Utilities Comm'n, 128 Idaho 609, 618, 917 P.2d 766, 775 (1996).
IDAHO POWER COMPANY'S REPLY COMMENTS - 10

events."
In other words, the Parties have not demonstrated that, in the 18 months since the
Commission issued its decision authorizing the ECR methodology in Order No. 36048,
conditions have changed such that the method needs to be re-evaluated.
16. In addition to raising issues previously considered and rejected by the
Commission, a number of comments are outside the limited scope of this compliance
docket including proposals to adopt alternative compensation structures or for
development of a virtual power plant program. Other comments reflect a
misunderstanding of the role of the Commission and/or the purpose of the ECR. The
Commission has repeatedly emphasized that customers' ability to pay off their investment
in solar generation and impacts on the solar industry are inapposite in these dockets:
[W]e want to reiterate here that the purpose of establishing a [net energy
metering] rate is not to ensure that customers who have installed self-
generation facilities are able to recoup their investment or earn a return on
investment, it is to ensure that customers are paid fair, just, and reasonable
rates for their exports and non-self-generating customers are not
subsidizing the rates for self-generating customers.
As we cautioned many times before, tariffs are not contracts and are subject
to change. It should come as no surprise to anyone who invested in an on-
site generation solar system after December 20, 2019, that the Company
may be authorized by the Commission to change fundamental aspects of
its [net energy metering] program—including the imposition of an ECR—
which can affect the payback period for customers. Idaho Code § 48-1805
states that every solar installer must provide notice to a potential customer,
in capital letters, "with substantially the following form and content:
`LEGISLATIVE OR REGULATORY ACTION MAY AFFECT OR
ELIMINATE YOUR ABILITY TO SELL OR GET CREDIT FOR ANY
EXCESS POWER GENERATED BY THE SYSTEM AND MAY AFFECT
THE PRICE OR VALUE OF THAT POWER."' We reiterate that a `reputable
seller of onsite generation systems would not and will not represent that the
program will never change.' $
" Case No. IPC-E-23-14, Vote Solar Comments at 16.
'S Case No. IPC-E-22-22, Order No. 35631 at 28, 30 (internal citations omitted) (emphasis in original).
IDAHO POWER COMPANY'S REPLY COMMENTS - 11

17. Significantly, no Party in the instant docket has taken the position that the
Company's update failed to follow the Commission's direction, and in fact, Staff concluded
that the Company's Application complied with Order No. 36048.19 The Company
appreciates this recognition by Staff, and respectfully requests that the Commission
acknowledge that its filing conformed with the Commission-approved annual update
method to the Company's ECR. The Company also understands that while the proposed
ECR has been updated in compliance with previous Commission orders, the Commission
may nevertheless wish to mitigate the impact of this inaugural update, as proposed by
Staff and CEO.20
18. In these Reply Comments, the Company summarizes the Parties' positions
for each component of the ECR and Idaho Power's response. Consistent with the scope
of this proceeding, these Reply Comments do not specifically address those
recommendations or considerations set forth in comments that relate to matters outside
the purview of this docket including among others, proposals calling for an alternative
compensation structure, modifications to the ECR methodology, or that otherwise seek
to relitigate issues that were already decided in a prior case.
III. COMPONENTS OF THE ECR
A. Avoided Energy
19. The avoided energy component relies on twelve months (January 1 through
December 31) of ELAP market prices, weighted for historical customer generator exports.
Additionally, this component contains a gross up for avoided line losses and an offset for
integration costs. Avoided energy costs are distributed in alignment with the summer and
19 Case No. IPC-E-25-15, Staff Comments at 3.
21 Case No. IPC-E-25-15, Staff Comments at 8-11 and CEO Comments at 7 (May 15, 2025).
IDAHO POWER COMPANY'S REPLY COMMENTS - 12

non-summer seasons.
Energy and Avoided Line Losses:
Staff Position
20. Staff believes that the Company's proposed update to the avoided energy
component — including its determination of the weighted January 1, 2024, through
December 31, 2024, ELAP prices and line losses — is consistent with Order No. 36048.21
CEO, SC&VS, Boise City Position
21. Both CEO and SC&VS recommend the Commission update the
methodology to include multiple years of historical market prices in determining the
avoided energy component as opposed to a singular year, both noting the method as
having been presented in the 2022 VOIDER Study. More specifically, CEO recommended
using three to five years of historical market prices while SC&VS again calls for use of a
three-year average, as Vote Solar did in the ECR Methodology Case.22 Interestingly,
though CEO agreed with Staff and the Company in the ECR Methodology Case regarding
the proposed method of using a single year of ELAP market prices,23 CEO now argues
for up to five-years of average historical prices to improve stability. While CEO frames its
changed position as a "lesson learned," in comments filed in the ECR Methodology Case,
it had recognized that some commentators were critical of the proposed method for
valued avoided energy as being unstable, though it noted its belief that the Company-
proposed single-year method achieves a fair balance between accuracy and the need for
stability and transparency.
21 Case No. IPC-E-25-15, Staff Comments at 4.
22 Case No. IPC-E-25-15, CEO Comments at 4 (May 15, 2025) and SC&VS Comments at 3.
23 Case No. IPC-E-23-14, CEO Reply Comments at 3 (Nov. 2, 2023).
IDAHO POWER COMPANY'S REPLY COMMENTS - 13

22. In addition, CEO opposes charging on-site generation customers for their
exports by including negative market prices in the avoided energy calculation. CEO
recommends that in any ECR update the energy component of an export should not be
valued at less than zero at any given hour.24
23. Similar to its position in the ECR Methodology Case, Boise City
recommends the Commission direct Idaho Power to explicitly consider fuel price risk as
a factor in ECR filings and updates.25
Idaho Power Position
24. Idaho Power appreciates Staff's finding that the Company's proposed
update to the avoided energy and line losses components is consistent with Order No.
36048. As stated previously, the Company's Application in this case is a compliance filing
and it does not believe this docket is the appropriate place to make methodological
changes to the ECR. Further, the Commission already considered many of the changes
proposed by Parties in the ECR Methodology Case, including the use of multiple historical
years of market prices and inclusion of a fuel price risk adder both of which it declined to
adopt.
25. The Company maintains that using actual historical ELAP prices, weighted
for customer exports, is an appropriate method for valuing the non-firm energy provided
by customer generators as it achieves timely recognition of changing conditions on Idaho
Power's system and the broader power markets. CEO takes a position that "negative
market prices do not equate to actual costs incurred by the Company" pointing to historical
data that shows during the majority of negative price hours, the Company was not selling
24 Case No. IPC-E-25-15, CEO Comments at 5.
21 Case No. IPC-E-25-15, Boise City Comments at 4-5 (May 15, 2025).
IDAHO POWER COMPANY'S REPLY COMMENTS - 14

excess power.26 However, CEO fails to recognize that when Idaho Power is importing
power during an hour when the ELAP price is negative, Idaho Power can be paid to back
off dispatchable generation and take power from EIM. That is, allowing negative ELAP
prices in the hours for which they occur in the valuation of avoided energy is appropriate
because doing so accurately captures the opportunity cost of procuring or generating
energy at such times. To demonstrate this, the Company provides the following illustrative
example where system net power supply expense ("NPSE") is $1.0 million, ELAP market
prices for the specific hour are priced at ($10)/megawatt-hours ("MWh"), and 100 MWhs
of dispatchable generation can be backed down.
Description Amount
Beginning NPSE $1,000,000
100 MWh ELAP Market Purchase (100*($10)) ($1,000)
Ending NPSE $999,000
26. As can be seen in the above example, the Company's ability to procure
energy while being paid to do so results in a decrease to its power supply expense, a
benefit realized by all customers.
27. To illustrate the impact of "zero-ing" the negatives, assume in that same
hour the Company receives 50 MWhs of customers' exports priced at — excluding
negatives — $5/MWh. Because the Company's system must remain balanced between
electricity supply and demand, the Company is only able to procure 50 MWhs from the
EIM market and therefore is unable to fully capitalize on the negative energy price
26 Case No. IPC-E-25-15, CEO Comments at 5.
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opportunity, as was done in the first example.
Description Amount
Beginning NPSE $1,000,000
50MWh ELAP Market Purchase (50*($10)) ($500)
50MWh Customer Export Purchase (50*$5) $250
Ending NPSE $999,750
28. The scenario demonstrates that all customers are worse off, from a system
NPSE perspective, as a result of the Company having to take customers' exports during
the hour of negative ELAP market prices. This is only the case if negatives are set to zero
— if the negative prices are used to set the ECR, as was proposed in the Company's filing
and approved by the Commission in the ECR Methodology Case, other customers are
indifferent to the Company procuring through the market or from a customer generator.
The Company maintains that the inclusion of negative ELAP market prices in the hours
for which they may occur when determining each year's ECR is appropriate and
necessary to keep non-participating customers indifferent.
Integration Costs:
Staff Position
29. Staff believes that the Company's proposed update to the integration cost
component is consistent with Order No. 36048.21 However, in its comments Staff
highlights that it identified several issues tied to the use of the 2024 Variable Energy
Resources ("VER") study for the integration costs in this year's ECR update and because
2' Case No. IPC-E-25-15, Staff Comments at 4.
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the 2024 VER Study is still undergoing Commission review (Case No. IPC-E-25-07), Staff
recommends that the Commission use the current value for integration costs of 0.293
cents/kilowatt hour ("kWh") in this year's update rather than the integration costs
proposed by the Company.28
CEO and SC&VS Positions
30. CEO and SC&VS both indicate that relying on integration costs for utility
scale solar for on-site exports is inaccurate, unsupported by evidence, and/or
inappropriate.29 Accordingly, CEO recommends that no changes be made to the
integration costs for the ECR and that the Commission instead either (1) order a technical
hearing to address the concerns CEO raises if the proposed integration rates are to be
relied upon for this ECR update, or (2) make no changes in this case to the integration
charges included and direct a review to occur prior to changes in the integration costs
becoming effective in the 2026 ECR update.30 SC&VS recommend the Commission reject
Idaho Power's proposed integration costs and direct Idaho Power recalculate integration
costs using a profile appropriate for on-site generation.31
Idaho Power Position
31. The Company's proposed integration costs in this case were filed in
compliance with the Commission's directive in Order No. 36048.31 In its comments filed
in this docket, Staff points to its comments in Case No. IPC-E-25-07, where its primary
28 Id., at 5.
29 Case No. IPC-E-25-15, CEO Comments at 1 and SC&VS Comments at 3.
30 Case No. IPC-E-25-15, CEO Comments at 4.
31 Case No. IPC-E-25-15, SC&VS Comments at 3.
32 "...the Company shall file an update to Schedule 87 rates and integration costs from the 2020 VER
study for Commission approval and the Company is directed to complete an updated integration study as
soon as possible, and to file the updated study for Commission approval and inclusion for future ECR
updates." Case No. IPC-E-23-14, Order No. 36048 at 16.
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concerns in relying on the updated integration charge in this ECR update seem to be
centered around applying too high of a charge to the two non-solar customers (one wind
and one hydro33) and a recognition that the proposed integration charge under-allocates
costs to the other approximately 14 thousand solar on-site generators.34 However, Staff
fails to acknowledge the issue of applying separate ECRs based on resource type was
raised in the ECR Methodology Case, where Staff's position was: "the logic of a separate
ECR for each unique export shape will lead to multiple ECRs for each rate class and for
each exporting technology type. Multiple ECR's would reduce transparency, increase
confusion, and could lead to dissatisfaction among customers."35 The issue was raised in
the record during the ECR Methodology Case and considered by the Commission when
it established a single ECR be applied to all on-site generation exports, regardless of
customer class or resource type.
32. Contrary to Staff's position that integration costs are under-allocated
through the ECR, CEO and SC&VS both take the position that the integration costs
proposed in this docket are too high, citing unsubstantiated evidence. Through discovery
issued in the open VER Study case (Case No. IPC-E-25-07), Staff inquired to the
reasonableness and rationale of relying on utility scale data to inform integration
associated with customer-generation exports. As explained more thoroughly in its
Response to Staff's Production Request No. 7,36 Idaho Power has not represented, as
suggested by CEO, that the export profile of customer generation is like a generation
33 The customer with a wind system has a solar PV system installed behind the same meter. The other
non-solar system is a 3.6 kW hydro system that exported a total of 337 kWh during 2024; assuming 2024
usage and generation, the customer's bill would be 0.7% higher under the updated ECR.
34 In the Matter of Idaho Power Company's 2024 Variable Energy Resource Study and Proposed Update
to Schedule 87, Case No. IPC-E-25-07, Staff Comments at 6 (May 14, 2025).
3s Case No. IPC-E-23-14 Staff Reply Comments at 3 (Nov. 2, 2023).
36 Attachment 1.
IDAHO POWER COMPANY'S REPLY COMMENTS - 18

profile of utility scale solar, it has found that the total generation profile for on-site systems
is reasonably expected to be similar to utility scale solar. The Company believes relying
on the proposed integration charge in this case reasonably assigns a portion of the costs
associated with integration to on-site generation exports. To the extent future VER studies
identify methods to adjust for the under-allocation issue Staff raises, those results will
impact future ECR updates. It is important to note, this applied methodology (relying on
a study informed by utility scale data) is consistent with how integration charges were
incorporated into the current ECR. As noted in its reply comments filed in IPC-E-25-07,
the Company has agreed to work with Staff to address the issues raised in their
comments, which include several aspects expected to impact the integration costs
assigned to the ECR in future updates.37
B. Avoided Generation Capacity
33. The avoided generation capacity component relies on the value of the next
least-cost proxy resource, the Effective Load Carrying Capability ("ELCC") of historic
exports, and 2024 hourly export data. This value is only applied to summer on-peak hours
as it is only realized when the Company's system is in most need of additional resources.
Staff Position
34. Staff believes that the Company's proposed update to the generation
capacity component is consistent with Order No. 36048.38
SC&VS Position
35. SC&VS believe that Idaho Power's ELCC methodology contains errors, has
37 Case No. IPC-E-25-07, Company Reply Comments at 3 (May 21, 2025).
38 Case No. IPC-E-25-15, Staff Comments at 5.
IDAHO POWER COMPANY'S REPLY COMMENTS - 19

not been verified by Staff or other stakeholders,39 and that the Commission should
approve a different capacity contribution method that is transparent and verifiable.4o
SC&VS goes on to claim three primary flaws with the Avoided Generation component: (1)
Idaho Power manipulated the data to exclude value associated with off-peak exports, (2)
it does not accurately account for the impact of losses, and (3) the results are inconsistent
with the ELCC values reported in the Integrated Resource Plan ("IRP").41
36. SC&VS also recommend that Idaho Power issue a one-time bill credit to on-
site generation customers due to its mistake in undervaluing the ELCC in the current
ECR.42
Idaho Power Position
37. The Company appreciates Staff's comment that its proposed update to the
avoided generation capacity component is consistent with Order No. 36048.
38. The SC&VS claim that the ELCC is a method that is not transparent or
verifiable is false. The ELCC is a widely used metric with a well-established methodology
and it has been extensively documented through industry publications.43 44 Idaho Power
developed the Reliability and Capacity Assessment Tool ("RCAT") as an efficient
computing environment to calculate ELCC; the concepts behind RCAT are not new nor
developed by Idaho Power.
39. While SC&VS claim that Idaho Power manipulated the data to exclude off-
peak exports, the ELCC calculation incorporates all hours of year, including on-peak and
39 Case No. IPC-E-25-15, SC&VS Comments at 14.
40 Id., at 18.
41 Id., at 16-17.
42 Id., at 13.
43 Billinton, R. and Allan, R.N. (1996) Reliability Evaluation of Power Systems. 2nd Edition, Plenum Press,
New York.
44 Resource Adequacy in the Pacific Northwest, Energy + Environmental Economics (March, 2019).
IDAHO POWER COMPANY'S REPLY COMMENTS -20

off-peak exports as recommended by Staff and adopted by the Commission in Order No.
36048.45 In addition, the claim by SC&VS that the model does not have the resolution to
account for the impact of avoided line losses is also misleading. As recommended by
Staff and approved by the Commission in Order No. 36048, the line losses are not part
of the ELCC calculation, they are accounted for after the ELCC calculation is performed.46
40. Finally, the claim by SC&VS that the ELCC results are inconsistent with IRP
results for utility scale solar fails to recognize the significant differences between customer
exports and a utility scale solar plant. Customer exports are generally diminished during
times of need on Idaho Power's system due to higher self-consumption during those
same times (e.g., in the summer customers have their air conditioners running during the
hottest parts of a summer day). In comparison, a utility scale plant is generally expected
to produce at, or near, nameplate during the summer period. Another important difference
is that the utility scale plants use single-axis tracking to increase their generation and tend
to install significantly more solar panels compared to the size of the inverter (a higher DC
to AC ratio), whereas most customer-generator systems — particularly residential — are
affixed to a rooftop and have a DC to AC ratio of varying degrees. An illustration of the
vast difference between customer exports and utility scale solar is shown in Figure 1
below.
45 Case No. IPC-E-23-14, Order No. 36048 at 11.
46 Id.
IDAHO POWER COMPANY'S REPLY COMMENTS -21

Figure 1
of Exports % of Utility Scale PV
100%
90%
80%
70%
Q60% Single axis-tracking
x increases production
w 50% during the solar
x ramping hours
M
40%
Fix tilt
+� 30%
c
v
" 20%
v
a
10%
0%
0 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24
Hour of Day (2024 Highest Risk Day)
41. SC&VS point to ELCC values that "change erratically from year to year"
suggesting that a change in ELCC of 12.17 percent for 2023 to 3.73 percent for 2024
inserts "further volatility into the ECR.,,47 What SC&VS fail to acknowledge is that on-site
generation exports were about 1 percent of the maximum output during 2024's highest
risk day as compared to 18 percent during 2023's highest risk day, meaning the difference
in the ELCC is explained by the inconsistent output of customer exports, and is not due
to the ELCC calculation itself. Further, the Commission considered the potential for
instability in year-over-year ELCC values during the ECR Methodology Case, finding
"using a trailing 5-year average ELCC as proposed in the Company's revised proposal is
reasonable.,,48
47 Case No. IPC-E-25-15, SC&VS Comments, page 15.
48 Case No. IPC-E-23-14, Order No. 36048, page 11.
IDAHO POWER COMPANY'S REPLY COMMENTS -22

42. Finally, the Company believes that SC&VS overstates the significance of
the Company's adjustment to the ELCC values for 2021 and 2022 in this year's ECR
update, which occurred as a result of the Company conforming its calculation of the ELCC
for customer generator exports to reflect that the resource originates behind-the-meter.
Idaho Power disagrees with SC&VS's assertion that the adjustment to the ELCC values
for 2020 through 2022 demonstrates a "significant underpayment" to on-site generation
customers; notably, the Company's refinement of its ELCC calculation for customer
generator imports did not impact the 2020 ELCC value and the overall impact to 2021
and 2022 values was minimal (e.g., for residential customers the corrected value
represents approximately 1 percent of total ECR payments). Moreover, the Company
does not believe it is appropriate or necessary to issue a bill credit to customers to account
for a corrected ELCC. After considering all evidence presented in the ECR Methodology
Case, the Commission approved rates, finding them fair, effective January 1, 2024, and
the Company has applied those rates consistently to all customer exports. SC&VS's
proposal for the Company to apply a credit to customers based on a rate different than
the Commission approved tariff would violate the filed-rate doctrine, codified in Idaho
Code § 61-313, and is therefore not appropriate. As it noted in its filing, in preparation of
this year's filing the Company identified if the prior year ELCC values are not adjusted,
there will be a discrepancy between how 2023 and 2024 ELCC values were developed
related to those prior years and proposed to update the prior year's values as part of the
rolling 5-year average.
C. Transmission and Distribution Capacity
43. The avoided Transmission and Distribution ("T&D") component relies on
IDAHO POWER COMPANY'S REPLY COMMENTS -23

solar penetration, 2024 export data, and the number of deferable projects. This value is
only applied to the summer on-peak hours as that is when the Company's T&D system is
most strained.
Staff Position
44. Staff believes that the Company's proposed update to the T&D capacity
component is consistent with Order No. 36048.49
SC&VS Position
45. SC&VS believe that the method used to quantify avoided T&D costs does
not appropriately quantify the marginal value that on-site generation exports provide.50 It
asserts that Idaho Power's value for transmission is not appropriately quantified as on-
site generation resources help reduce peak load, which drives the need for new
transmission resources.51 SC&VS recommend that the Commission direct the Company
to quantify the marginal value of avoided transmission costs due to on-site generation,
citing several alternative methodologies that could be employed.52
Idaho Power Position
46. The Company appreciates Staff's comment that its proposed update to the
avoided T&D capacity component is consistent with Order No. 36048.
47. The Company reiterates that it has updated all values of the ECR in
accordance with Order No. 36048. The Commission has already considered several of
the alternative methods presented by SC&VS in comments during the ECR Methodology
Case and ultimately declined to adopt those methods.
49 Case No. IPC-E-25-15, Staff Comments at 6.
So Case No. IPC-E-25-15, SC&VS Solar Comments at 19.
51 Id.
52 Id., at 21.
IDAHO POWER COMPANY'S REPLY COMMENTS -24

IV. MITIGATION
Staff Position
48. Staff proposes that the amount of year-to-year change be capped to
mitigate the increase to on-site generation customer bills,53 recommending an ongoing
method to limit the change in the avoided energy component to 30 percent in either
direction. Under its proposal, the cap would be applied separately to the summer and
non-summer energy values.54 In recommending mitigation, Staff highlights that — if
mitigation is approved — customers consuming energy from Idaho Power's system would
no longer be indifferent as to whether they receive energy from on-site generation
customers or from the Company's system resources.55
CEO and Boise City Position
49. CEO suggests that any reduction to the non-summer ECR of more than 50
percent would exceed the norms of reasonableness and would conflict with the principle
of gradualism. CEO asserts that the proposed reduction in the non-summer ECR is
acutely harmful to a small set of customers, with little benefit to the average customer.56
Boise City states concerns that on-site generation customers will incur significant financial
impact as a result of the proposed ECR.51 Boise City believes that lowering the ECR is
not in the spirit of affordability and fairness and will place an unfair burden on customers
without the means to pursue battery storage.58 Boise City concludes that while the
Commission approved ECR adjustment methodologies in the past, each new proposal
53 Case No. IPC-E-25-15, Staff Comments at 8.
54 Id at 9.
55 Id., at 10.
56 Case No. IPC-E-25-15, CEO Comments at 7.
57Case No. IPC-E-25-15, Boise City Comments at 3.
58 Id., at 4.
IDAHO POWER COMPANY'S REPLY COMMENTS -25

warrants fresh evaluation.59
Idaho Power Position
50. In its order establishing the ECR methodology, the Commission
summarized three primary principles that guided its decisions: (1) the fundamental
purpose of on-site generation is to offset a customer's own usage, (2) that on-site
generation should not create cost shifting between generators and non-generators, and
(3) that on-site generators should be given a fair value to their exported energy.60
Ultimately, the Commission signaled its intent to accurately assign costs and benefits
while providing a reasonable balance between the interests of customers with on-site
generation and those without.61 The Company believes the updated rates in this case
comply with all three principles initially laid out by the Commission: (1) the updated ECR
has no impact to a customer's ability to generate and consume their own energy,
effectively reducing the amount they consume (and pay for) Idaho Power-provided
services, (2) implementing the updated ECR, as proposed, will help to ensure non-
participating customers remain indifferent to the source of their energy, whether it be from
an on-site generator's exports or another Company resource, and (3) the Commission
has recently found the approved methodology results in a fair assignment of value to on-
site generators.
51. While the Company believes its proposed update in this case is consistent
with the Commission-established methodology, it also understands the updated ECR will
result in bill impacts — while varied — to the roughly 14 thousand customers who have
59 Id., at 5.
61 Case No. IPC-E-23-14, Order No. 36048, at 5.
61 Id., at 6.
IDAHO POWER COMPANY'S REPLY COMMENTS -26

configured their systems to export to Idaho Power's grid. Idaho Power appreciates Staff's
attempt to introduce a simplified mitigation measure; however, while Staff has described
the mitigation mechanism as symmetrical, the Company does not believe the proposal as
described results in symmetry. Further, the Company is concerned that in a future period
where market prices increase, thereby positively impacting the ECR, stakeholders would
expect for the ECR to reflect that value and would be highly critical of the Company
employing a mitigation measure that restricted the value of exported energy from
customer generators. In its comments, Staff only presented a single year simplified
quantification of the cap:
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).
Staff then went on to suggest that under its proposed method:
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. [emphasis added]
52. However, this conclusion is inaccurate. In order to better evaluate Staff's
proposal, the Company developed a schedule to demonstrate how long it would take the
avoided energy component to reach the unmitigated value under Staff's proposal and a
second schedule to show how long it will take to "climb back up" if the weighted energy
price were to once again reach 2022 levels. Table 1 on the following page represents the
schedule of changes to the avoided energy component assuming the 1.7682 cents/kWh
remains consistent for a number of years with a starting point of 5.6533 cents/kWh.
IDAHO POWER COMPANY'S REPLY COMMENTS -27

Table 1
Annual Change
Starting Cap Ending in Rate
Year 1 5.6533 70% 3.9573 (1.6960)
Year 2 3.9573 70% 2.7701 (1.1872)
Year 3 2.7701 70% 1.9391 (0.8310)
Year 4 1.9391 N/A 1.7682 (0.1709)
53. Contrary to Staff's assertion that it would take two to three cycles to equalize
to the unmitigated value, the Company's analysis demonstrates that the avoided energy
rate would not reach the unmitigated value until into year 4. Table 2 represents the
schedule of changes to the avoided energy component assuming the value reaches the
1.7682 cents/kWh and then needs to ratchet back up to the 5.6533 cents/kWh.
Table 2
Annual Change
Starting Cap Ending in Rate
Year 1 1.7682 130% 2.2987 0.5305
Year 2 2.2987 130% 2.9883 0.6896
Year 3 2.9883 130% 3.8847 0.8965
Year 4 3.8847 130% 5.0502 1.1654
Year 5 5.0502 N/A 5.6533 0.6031
54. As illustrated by the Company's evaluation reflected in Tables 1 and 2, the
year-over-year changes when moving towards a lower rate result in higher step changes
in the early years, and conversely, the year-over-year changes when moving to a higher
rate result in smaller step changes in the early years. Essentially, when a proposed rate
is lower than the current rate, customer generators will experience the largest decrease
in the first year and smaller decreases in future years, where if a proposed rate is higher
than the current rate, customer generators will experience the lowest increase in the first
year and higher increases in the following years (until they near the cap). This occurs
IDAHO POWER COMPANY'S REPLY COMMENTS -28

because Staff's proposal is based on a percentage of the starting value, rather than just
a "movement towards" or "percentage of the overall change," which under either of those
approaches would result in more symmetrical treatment. Because of the asymmetry
inherent in Staff's proposed mitigation measure, the Company does not support the
mechanism as proposed.
55. Notably, the decrease in the ECR in this case is driven by many of the same
factors that prompted the Commission to adopt mitigation in the Company's 2023 Power
Cost Adjustment ("PCA"),62 including coal supply issues, high natural gas and market
prices, and low hydro generation that resulted in unusually high NPSE during 2022. While
those costs were all found to be prudently incurred, ultimately the Commission found in
that case that"due to extraordinary circumstances leading to high net power costs," it was
fair, just, and reasonable to spread the cost recovery of the PCA deferral balance equally
over two years to mitigate rate impacts on the Company's customers."63 The Commission
further explained: "This Commission is sensitive to economic conditions affecting
ratepayers throughout Idaho. We strive to balance the ratepayer's need for affordable
energy with the Company's mandate to provide reliable electric service.1164
56. In this instant case, the large decrease in the avoided energy component is
driven by the same factors that caused a large increase in power supply costs in the 2022-
2023 deferral balance —that is, the existing ECR was based on 2022 ELAP prices, which
were unusually high due to the same factors that drove an increase in Company NPSE
62 In the Matter of Idaho Power Company's Application for Authority to Implement Power Cost Adjustment
("PCA') Rates for Electric Service from June 1, 2023, Through May 31, 2024., Case No. IPC-E-23-12,
Order No. 35804 at 8 (May 31, 2023).
63 Id., at 8-9.
64 Id., at 8.
IDAHO POWER COMPANY'S REPLY COMMENTS -29

that year. The proposed update in this case relies on 2024 ELAP prices, which could be
considered more "normal," as demonstrated in Figure 3 (2021-2024 ELAP Prices)
presented on page 13 of Jared Ellsworth's Direct Filed Testimony.
57. Considering the circumstances, in the event the Commission believes it is
appropriate to implement a mitigation measure in this case, Idaho Power believes a one-
time 50 percent change limit, as proposed by CEO, would yield a more reasonable result
than Staff's proposed methodology. However, while CEO recommends the mitigation only
be applied to the non-summer months, Idaho Power believes if mitigation is adopted,
applying a 50 percent mitigation to both the summer and non-summer avoided energy
components could be appropriate. Table 3 on the following page outlines this mitigation
option for the Commission's consideration. The Unmitigated Filed ECR represents the
Company's filed rate, which reflects the Commission approved methodology from Order
No. 36048 and the Mitigated ECR reflects a downward cap of 50 percent from the existing
summer and non-summer avoided energy components.
IDAHO POWER COMPANY'S REPLY COMMENTS - 30

Table 3
ECR SUMMARY
Season Unmitigated Mitigated
Filed ECR ECR
Export Profile
Volume (kWh per kW) Annual 1,362 1,362
Capacity Contribution (%) Annual 10.07% 10.07%
Export Credit Rate by Component(cents/kWh)
Energy Summer 1.7682 C 2.8266 C
Including integration and losses Non-Summer 0.9540 C 2.4182 C
Annual* 1.28520 2.57830
Generation Capacity On-Peak 11.9017 C 11.9017 C
Off-Peak 0.0000 C 0.0000 C
Annual* 1.13600 1.13600
Transmission &Distribution Capacity On-Peak 0.3899 C 0.3899 C
Off-Peak 0.0000 C 0.0000 C
Annual* 0.03720 0.03720
Total Summer On-Peak 14.05980 15.11820
Summer Off-Peak 1.76820 2.82660
Non-Summer 0.95400 2.41820
Annual* 2.45850 3.75150
*Annual values provided for informational purposes only and reflect seasonal weighting for 12
months ending December 2024.
Note: Summer season is defined as June I -September 30. On-Peak hours is defined as 3pm - I Ipm,
Monday-Saturday, excluding holidays. All other Summer hours defined as Off-Peak. Non-Summer
season defined as October I -May 31.
58. Finally, the Company requests the Commission reject Staff's
recommendation to implement an ongoing mitigation mechanism as part of this case. The
Commission does not need to adopt an ongoing mechanism, as proposed by Staff, if it
decides to implement mitigation in this current case. The Commission ultimately has the
IDAHO POWER COMPANY'S REPLY COMMENTS -31

authority — as granted by the legislature — to conduct economic analyses to determine
rates that are fair, just, and reasonable. It also has the ability, just as it did in the
Company's 2023 PCA case, to consider specific circumstances in any case and to assess
whether rate mitigation is appropriate to partially shield customers from rate changes.
However, because the ECR only impacts a subset of the Company's customers and
mitigation would ultimately impact the rates of non-participating customers, the Company
believes the circumstances are distinguishable from those extraordinary circumstances
in which it found mitigation warranted in other cases.
59. As the Commission considers the reasonableness of implementing
mitigation, the Company believes it is also important to consider any mitigation measure
employed will inevitably perpetuate inaccurate price signals to customer generators. As
highlighted in written public comments and many customers' oral testimony at the May
20, 2025, customer hearing, customers made decisions based on the then-current
compensation structure and/or ECR at the time they decided to move forward with
installing systems. Some of those customers commented they did not consider future
changes to the ECR when making decisions on system sizing and configuration. Notably,
many customers have suggested they were encouraged to oversize their systems to
mitigate against future fluctuations in rates, which means a higher percentage of their
generation is subject to the ECR, rather than on-site consumption. The Company believes
updating the ECR in this case, consistent with the methodology established in the ECR
Methodology Case, is the best way to ensure customers receive an accurate price signal
to inform decision making and to ensure non-participating customers remain indifferent.
IDAHO POWER COMPANY'S REPLY COMMENTS - 32

V. DER REPORT
60. Staff and SC&VS both recommend the Commission acknowledge or
approve the Company's proposal to consolidate its reporting requirements and file
annually concurrent with future ECR update filings.65 Additionally, in its comments,
SC&VS offers two suggestions for the Company: (1) make past copies of the report
available on its website, and (2) "correct" the title of the report completed submitted on
April 1, 2025, to the "2025 DER Annual Report" instead of the "2024 Distributed Energy
Resources Annual Report." The Company appreciates both Staff and SC&VS support for
the consolidation of the reporting requirements and acknowledges the suggestions
offered by SC&VS. Idaho Power currently makes three years of past reports available on
its website, which is consistent with how it maintains other Commission-required reports
on its website (e.g., Demand-Side Management Annual Reports and Integrated Resource
Plans) and will continue to do the same for the DER Report. Finally, the Company
acknowledges the change to the nomenclature in this year's title of its DER Report;
however, going forward Idaho Power intends to name the report based on the reporting
year, rather than the month of submission. This is consistent with other calendar-year
reports, like the Demand-Side Management Annual Report — that report is submitted in
March of each year, but the data reflects the prior calendar year, so it is titled consistent
with the reporting period.66
65 Case No. IPC-E-25-15, Staff Comments at 14 and SC&VS Comments at 25.
ss Because prior DER Reports were filed on April 30, Idaho Power had supplied information through the
first quarter of the filing year and therefore named the report consistent with the filing year, however,
going forward, the report will be filed on April 1 of each year and the Company will report through the end
of the calendar year.
IDAHO POWER COMPANY'S REPLY COMMENTS - 33

VI. PUBLIC COMMENTS
61. As of May 15, 2025, over 850 written public comments have been received,
and at the May 20, 2025, Customer Hearing, approximately 45 members of the public
offered public testimony. The Company understands the great interest shown in this case
and appreciates those members of the public that have chosen to participate, which
represent roughly 0.15 percent of the Company's total customers. In comments, Staff
noted its belief that the overwhelming majority of those that offered comments are non-
legacy on-site generation customers.67 Similar to prior dockets, the members of the public
that submitted comments in this case generally disfavor the proposed ECR update, with
common concerns being the high cost they paid for their solar generation system, the
impact that the proposed changes would have on the payback period for customers
(potentially making them unwilling or unable to pay for an expensive solar system),
unawareness that the rates could change, and/or call for expanded legacy treatment for
those customer systems that were not previously granted legacy treatment under prior
Commission orders. Many of the comments express a desire for the Commission to
implement policies and frameworks that will encourage the adoption of distributed
generation.
62. Though Idaho Power is not privy to the details of the bilateral transactions
between sellers or installers of on-site generation systems and their customers, a number
of stakeholders appear to put the onus on the utility or the Commission for ensuring the
transaction is equitable and economically supportable. This, however, is not within Idaho
Power's purview. As a publicly regulated utility, Idaho Power is differently situated than a
67 Case No. IPC-E-25-15, Staff Comments at 12.
IDAHO POWER COMPANY'S REPLY COMMENTS - 34

private seller or installer; it is accountable to the Commission and legally obligated to
consider the collective interests of all its customers and to develop mechanisms based
on an economically supportable analyses that result in fair, just, and reasonable rates for
customers, rather than simply as a means to achieve particular policy goals. Similarly, the
Commission has been clear in previous orders that its objective is to ensure that
customers are paid fair, just, and reasonable rates for their exports and non-self-
generating customers are not subsidizing the rates for self-generating customers — not to
ensure that customers who have installed self-generation facilities are able to recoup their
investment or earn a return on investment.68 Moreover, the Commission has repeatedly
cautioned that tariffs are not contracts and are subject to change and has likewise
affirmed its treatment of legacy systems on numerous occasions.
63. Other comments generally focus on the benefits of on-site solar generation
that were not incorporated into the ECR methodology and many contend that the
Commission-approved methodology undervalues customer self-generation, believing the
compensation for exported energy should match the retail rates customers pay to Idaho
Power. However, the premise of these comments highlights a fundamental
misunderstanding of the difference in the transactions — retail rates reflect the costs of
making electric service available at any time of day and in the quantity needed by the
customer; retail rates are established to collect costs associated with all aspects of the
utility's system necessary to provide near round-the-clock availability. An ECR, on the
other hand, is reflective of the product delivered — generally, non-firm energy, when a
customer generator chooses to export. The ECR methodology does value the avoided
68 Case No. IPC-E-22-22, Order No. 35631 at 28.
IDAHO POWER COMPANY'S REPLY COMMENTS - 35

cost of generation and T&D capacity; however, there is no reasonable basis to suggest
that the product offered by a customer generator is the same as service provided by the
utility. Other commentors have raised a similar argument claiming on-site generation
exports are not being fairly or accurately valued by suggesting that ECR is
incommensurate with the rate paid by the Company pursuant to power purchase
agreements for generation from utility-scale renewable energy resources such as Jackpot
and Black Mesa solar. That intimation, however, is belied by a review of the average price
per kWh paid for those resources in 2024, which was approximately $0.02214 and
$0.02307 per kWh, respectively, which is consistent with what is being proposed for the
updated average annual ECR in this case. Further, some commenters have argued that
large customers like Meta and Micron have received long term contracts (e.g., 20 to 25
years) for the compensation related to their Clean Energy Your Way arrangements;
however, this is not accurate. The Commission has authorized the Company to pay the
lesser of 85 percent of a Mid-Columbia Forecast or the actual Mid-Columbia market price
for each hour of excess energy. Said another way, those rates are not set — they vary
hourly and will track market fluctuations going forward.
64. In response to those comments that suggest the Company is motivated by
financial gain in setting the ECR, it is important to note that neither Idaho Power nor its
shareholders receive any financial return on this filing; rather it is intended to ensure more
accurate valuation of exported energy to mitigate the cost shifting between customers
who choose to install on-site generation and those who do not, the latter of which
comprises the vast majority of the Company's customers. All costs associated with ECR
payments to customer generators are recovered from all customers through the
IDAHO POWER COMPANY'S REPLY COMMENTS - 36

Company's PCA mechanism.
65. Finally, a number of public comments express a general misunderstanding
or distrust of the method or the underlying procedure including criticisms of a
Commission-acknowledged study completed in 2022 — the VOIDER Study— and suggest
that there should be additional process including requests for the Commission to hold a
technical hearing. While the Company understands that many of those that have offered
comments in this docket disagree with the ECR methodology previously adopted by the
Commission, critiques of the 2022 VOIDER Study are misplaced in this docket as the ECR
update is not based on that study; rather the update is based on the outcome of a
separate case that followed the study's case — Case No. IPC-E-23-14. Moreover, as
discussed above, Order No. 36048, issued in Case No. IPC-E-23-14, has become final
and conclusive and it is not appropriate for Parties to now challenge, within this
compliance docket, the methods for calculating the ECR components, or to seek to
deviate from the annual update process directed by the Commission.
66. Furthermore, the procedural schedules in Case No. IPC-E-23-14 and the
series of on-site generation dockets that preceded it, have provided ample opportunities
for comment and participation, and public and party involvement has been robust and
instrumental throughout the underlying process. The Company has, and continues to be,
committed to clearly and transparently notifying potential and existing on-site generation
customers that on-site generation rates and program structure are subject to change. To
this end, it has undertaken extensive efforts — including numerous direct mailings — to
communicate with both customer-generators and non-participating customers regarding
the net metering service offering and regulatory proceedings related to potential changes
IDAHO POWER COMPANY'S REPLY COMMENTS - 37

including providing information on opportunities to offer input and participate in the
proceedings. Idaho Power has also continually updated its website and communication
materials to indicate pricing and compensation structure can change as a result of
regulatory approval. Table 4 on the following page summarizes the extensive efforts
undertaken by the Company to notify customers of the potential for change, information
provided to customers through Commission orders, and information required to be
provided by solar retailers:
IDAHO POWER COMPANY'S REPLY COMMENTS - 38

Table 4
Date Communication Relevant Language
October Residential Solar Energy LEGISLATIVE OR REGULATORY ACTION MAY AFFECT
2019 System Disclosure Act OR ELIMINATE YOUR ABILITY TO SELL OR GET CREDIT
requires written disclosures FOR ANY EXCESS POWER GENERATED BY THE SYSTEM
be provided by the AND MAY AFFECT THE PRICE OR VALUE OF THAT
installer/seller to consumers POWER
(Idaho Code 48-1805)
December Commission Order No.34509 "After the issuance of this Order,however,we believe it will no
2019 longer be reasonable for a customer to assume the net-metering
program fundamentals will remain the same over the expected
a back eriod of their investment."
January Idaho Power's Application for I understand that the net metering program design is subject to
2020 On-Site Generation Modified change including,but not limited to,the interval length over which
per Commission Order netting occurs, compensation for excess generation and the
interconnection requirements for on-site generation systems.
Customer must initial/sign
both disclosures on the I UNDERSTAND THAT LEGISLATIVE OR REGULATORY
application ACTION MAY AFFECT OR ELIMINATE MY ABILITY TO
SELL OR GET CREDIT FOR ANY EXCESS POWER
GENERATED BY THE SYSTEM AND MAY AFFECT THE
PRICE OR VALUE OF THAT POWER. (ID RESIDENTIAL
ENERGY SYSTEM DISCLOSURE ACT, ID CODE §§48-1801-
48-1809
January Company Email The rules for on-site generation, including compensation structure,
2020 Communications to are outlined in Schedules 6, 8, 84 and 72,which have been
Prospective On-Site approved by the Idaho Public Utilities Commission and the Oregon
Generation Customers Public Utility Commission(Commissions). Tariff schedules are
Modified to Include subject to change with approval from the Commissions. This
Additional Language means the rules in place today(including pricing, compensation
structure, excess energy value and system requirements) can change
in the future. We will notify you of any future changes to the
schedules.
February Commission Order No.34546 "We made it abundantly clear in Order No. 34509 that the program
2020 fundamentals are subject to change. It would contravene our
rationale to extend the date at which customers are eligible for
randfathered status, and we therefore decline to do so."
December Commission Order No.34854 "We find it prudent to make the determination on grandfathering
2020 existing Schedule 84 customer-generators now,rather than waiting
until a successor program is approved as many parties and
commenters suggested,because it clarifies to potential CI&I
customer-generators that the program fundamentals are undergoing
a com rehensive review and are likely to change."
IDAHO POWER COMPANY'S REPLY COMMENTS - 39

Table 4 Continued
Date Communication Relevant Language
January Commission Order No.34892 "No person, entity,business or organization should be representing
2021 that investment in and installation of solar panels under a particular
tariff will result in payback within a time certain because the rates
under the then current tariff do not become fixed at the time such an
investment is made"
June 2021 Company Press Release& Customers who install on-site generation after the dates of those
Bill Inserts Mailed to All orders(December 20,2019 for Schedule 6 and 8; December 1,
Customers 2020 for Schedule 84) are subject to future changes to
compensation structure,including how much they are compensated
for excess energy.
December Commission Order No.35284 "We urge stakeholders in the on-site generation industry to be
2021 completely transparent with potential investors. A utility's rate
schedules, including net-metering program fundamentals, are
subject to change. As such,there is no guaranteed return on
investment."
June 2022 Company Press Release& Customers who do not have legacy systems are subject to changes
Bill Inserts Mailed to All to the on-site generation compensation structure, including the
Customers value of the ECR. Customers are notified when applying for
interconnection that the value of excess energy is subject to change.
December Commission Order No.35631 "We are very concerned,though,by the number of commenters
2022 expressing worry that they will be unable to pay off their solar
panel investments if the NEM program changes...It should come as
no surprise to anyone who invested in an on-site generation solar
system after December 20,2019,that the Company may be
authorized by the Commission to change fundamental aspects of its
NEM program—including the imposition of an ECR—which can
affect the payback period for customers."
January Commission Order No.35667 "Contrary to Petitioner's implication otherwise,the Order provides
2023 that customers 'should know today that they will be getting a
reduced credit for the electricity they generate."'
May 2023 Company Letter to Current "All other systems, including the system referenced in this letter,
Non-Legacy On-Site are"non-legacy"and are subject to changes in the on-site
Generation Customers generation compensation structure,including the changes currently
being considered by the IPUC."
May 2023 Company Letter to "All other systems, including the proposed system referenced in
Customers that have a this letter, are"non-legacy"and are subject to changes in the on-
Current On-Site Generation site generation compensation structure, including the changes
Application currently being considered by the IPUC."
January Company Postcard to Non- "The ECR value will be updated annually beginning in spring of
2024 Legacy On-Site Customers 2025."
January Company Email to Customers "The ECR value will be updated annually beginning in spring of
2024 that Submit an Application 2025."
IDAHO POWER COMPANY'S REPLY COMMENTS -40

67. In what is likely the most direct communication with each prospective
customer, the Company has required every customer generation applicant to sign an
application acknowledging they understand the program fundamentals can change.
Within weeks of the Commission issuing Order No. 34509 in Case No. IPC-E-18-15, the
Company updated the affirmative acknowledgement section in its application (shown
below) to further clarify that the measurement interval and compensation for excess
energy is subject to change.
Customer Acknowledgment
The following acknowledgments must be INITIALED for Idaho Power to complete its review of this
application.
_I authorize Idaho Power to discuss my interconnection request and on-site generation project,as well
as share information about my electric usage history,with the Project Contact/Company listed above.I
further authorize such Project Contact/Company to act on my behalf to complete the necessary
documentation and requirements to interconnect my on-site generation system.(If customer does not
initial this authorization,all of Idaho Power's communications,information-sharing,and interconnection
requirements for this project must be handled directly with customer.)
_I certify that the information provided in this application is correct to the best of my knowledge.
_I understand that a return trip charge of$61 may be billed to my account each time Idaho Power
personnel are dispatched to the job site but are unable to conduct the on-site inspection for any of the
conditions described in Schedule 68.
_I understand that the net metering program design is subject to change including,but not limited
to,the interval length over which netting occurs,compensation for excess generation and the
interconnection requirements for on-site generation systems.
_I UNDERSTAND THAT LEGISLATIVE OR REGULATORY ACTION MAY AFFECT OR ELIMINATE MY ABILITY
TO SELL OR GET CREDIT FOR ANY EXCESS POWER GENERATED BY THE SYSTEM AND MAY AFFECT THE
PRICE OR VALUE OF THAT POWER. (ID RESIDENTIAL ENERGY SYSTEM DISCLOSURE ACT,ID CODE§§48-
1801-§§48-1809)
Customer printed name
Customer Signature Date
VII. CONCLUSION
68. Similar to the Company's experience in prior cases, the stakeholders and
members of the public that have chosen to comment in this docket primarily consist of
IDAHO POWER COMPANY'S REPLY COMMENTS -41

environmental advocacy groups, non-legacy on-site generation customers, and
individuals from the solar industry that largely oppose the Company's update of the ECR.
The Company understands that on-site generation involves consideration of several
important, and at times competing, public policy objectives, which may result in
stakeholders working at cross-purposes.
69. Idaho Power recognizes that several commenters ardently support on-site
generation and appreciates that some customers desire to offset their energy bills through
on-site self-generation and help reduce demand on the Company's system. These goals
are consistent with what the Commission has determined to be the fundamental purpose
of on-site generation: to provide customers the opportunity to offset usage through their
own generation. These objectives, however, cannot be achieved with a blind eye to the
cost and effects on non-participants, nor can the business or personal interests of solar
contractors and customers be pursued at the expense of non-participating customers,
which includes most of Idaho Power's customers.
70. Consistent with its mandate to conduct economic analyses to determine
rates that are fair, just and reasonable, in implementing the ECR methodology for valuing
excess energy for on-site generators in the ECR Methodology Case, the Commission
endeavored to accurately assign the appropriate share of fixed costs and unquantified
benefits of on-site customer generation, and to provide a reasonable balance between
the interests of customers with on-site generation, and customers without.
71. The Company appreciates Staff's recognition that its Application complied
with Order No. 36048. The Company is sensitive to the financial impact the updated ECR
will have on many non-legacy customer generators and is therefore amenable to
IDAHO POWER COMPANY'S REPLY COMMENTS -42

implementing a mitigation measure if the Commission determines such measure is
appropriate, though the Company believes any mitigation should be limited to this
inaugural update to ensure appropriate matching of costs and recovery and to facilitate
the overall intent of the ECR mechanism.
72. Therefore, the Company respectfully requests that the Commission issue an
order: (1) acknowledging that its filing conformed with the Commission-approved annual
ECR update method outlined in Order No. 36048; (2) authorizing Idaho Power to
implement the updated ECR for non-legacy on-site generation customers effective June
1, 2025, as directed in Order No. 36048; (3) as needed, directing the Company to submit
corrected tariff sheets reflecting the incorporation of any mitigation measures ordered by
the Commission; and (4) acknowledging the Company's consolidation of the DER status
report into the annual ECR update.
DATED at Boise, Idaho this 22nd day of May 2025.
�_%r T I
MEGAN GOICOECHEA ALLEN
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S REPLY COMMENTS -43

CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 22nd day of May 2025, 1 served a true and
correct copy of the within and foregoing IDAHO POWER COMPANY'S REPLY
COMMENTS upon the following named parties by the method indicated below, and
addressed to the following:
Commission Staff Hand Delivered
Erika K. Melanson 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 Erika.melanson(a-),puc.idaho.gov
PO Box 83720
Boise, ID 83720-0074
Sierra Club Hand Delivered
Gregory M. Adams U.S. Mail
Richardson Adams, PLLC Overnight Mail
515 N. 27th Street FAX
Boise, Idaho 83702 FTP Site
X Email greg(a-)richardsonadams.com
Kate Bowman Hand Delivered
Vote Solar U.S. Mail
299 S. Main Street, Suite 1300 PMB Overnight Mail
93601 FAX
Salt Lake City, UT 84111 FTP Site
X Email kbowman(a-votesolar.org
Rose Monahan Hand Delivered
Sierra Club U.S. Mail
2101 Webster Street, Suite 1300 Overnight Mail
Oakland, California 94612 FAX
FTP Site
X Email rose.monahan(o)-sierraclub.org
Clean Energy Opportunities of Hand Delivered
Idaho U.S. Mail
Kelsey Jae Overnight Mail
Law of Conscious Leadership FAX
920 N. Clover Dr. FTP Site
Boise, ID 83703 X Email kelsey(a)-kelseyiae.com
IDAHO POWER COMPANY'S REPLY COMMENTS -44

Courtney White Hand Delivered
Mike Heckler U.S. Mail
Clean Energy Opportunities for Idaho Overnight Mail
3778 Plantation River Drive, Suite 102 FAX
Boise, Idaho 83703 FTP Site
X Email
courtnev(a)_cleanenergyopportunities.com
mike(a)cleanenergyopportunities.com
Kevin Dickey, pro se Hand Delivered
2953 Honey Lane U.S. Mail
Emmett, ID 83617 Overnight Mail
FAX
FTP Site
X Email Bellefourche01(a_gmail.com
Scott Pinizzotto, pro se Hand Delivered
P.O. Box 6902 U.S. Mail
Ketchum, ID 83340 Overnight Mail
FAX
FTP Site
X Email s.pinizzotto(a)_gmail.com
Martha S. Bibb, pro se Hand Delivered
810 CD Olena Dr. U.S. Mail
Hailey, ID 83333 Overnight Mail
FAX
FTP Site
X Email marthasbibb(a)gmail.com
City of Boise City Hand Delivered
Jessica Harrison U.S. Mail
Deputy City Attorney Overnight Mail
P.O. Box 500 FAX
Boise, ID 83701 FTP Site
X Email
BoiseCityAttorney(a)-cityofboise.org
jharrison(a�cityofboise.org
Katie O'Neil Hand Delivered
Energy Program Manager U.S. Mail
Boise City Department of Public Overnight Mail
Works FAX
FTP Site
X Email koneil(a)cityofboise.org
IDAHO POWER COMPANY'S REPLY COMMENTS -45

Stacy Gust
Regulatory Administrative Assistant
IDAHO POWER COMPANY'S REPLY COMMENTS -46

BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-E-25-15
IDAHO POWER COMPANY
ATTACHMENT NO. 1

REQ LEST FO RPRO OUCTlO NNO .7: Page 4 of the VER study states:
[w]hile the VER integration study determ hed the cost of accom m dating additional
utility scale solar, the Com pany found that a utility scale profile is a reasonable proxy for
the shape of on-site solar generation. As such, the Com pany assesses that the
integration costs identified in its report are an appropriate input to the ECR without
modification. Please respond to the following.
a. Please explain why profile shapes are a determ ring factor for whether on-site
solar generation can be treated as utility-scale solar;
b. Please provide evidence to show utility-scale solar and on-site solar have sim iar
profile shapes;
c. Please explain why on-site wind can be treated as utility-scale wind for
determ ring integration charges and justify your answer with evidence; and
d. Please explain why the 2024 VER Study does not distinguish renewables and
renewables paired with batteries for both Q Fs and on-site generation customers,
considering the fact that the profile shapes of renewables can look different than
the profile shapes of renewables paired with batteries.
RESPO N3E TO REQ LEST FO RPRO EUCTlO NNO .7:
a. Due to how regulating reserves are held for the different VERs, requirements are
similar for resources that have sim iar profile shapes.
b. Although Idaho Power's service area spans a wide swath of Southern Idaho and
Eastern O iegon, the difference between sunrise tim es over the entire service
area is approxim etely 15 m hutes on the spring equinox suggesting that
regardless of if solar is sited on a roof or in a field, that the m orning and
IDAHO PO W EIR CO M FANY'S RESPO N3E TO THE FIRST PRO DJCTIO NREQ LEST O FTHE
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afternoon ram ps will be situ iar. Additionally, the dispersed nature of on-site solar
should be reasonably sim iar to the dispersed nature of the utility scale projects
on Idaho Power's system .For these reasons, the Com pany assum es that an on-
site generation's profile will be sim iar to utility scale and would thus require the
same regulation reserves.
The Com pany is not suggesting an export profile of all customer generation is
like a generation profile of utility scale solar. Rather, the total generation profile
for on-site system s is reasonably expected to be sim iar to utility scale solar. This
is important to note because integration costs are incurred regardless of whether
some of the generation is consumed on-site, however, in the ECR method, the
Com pany only applies the integration charge to exported energy. Because the
integration charge is developed on a per M W hbasis, this m eans that custom er
generators are under-allocated the cost of integration — that is, they are only
covering the cost of integration associated with exports, not the full integration
cost incurred. This is appropriate because the Com m$sion has previously found
the benefits and costs contained in the ECR should only be associated with an
export.
The Com pany considered whether an analysis could be structured to isolate and
only study integration associated with exports, however due to a lim itation in the
granularity of interval data available from m eters installed for retail service, the
Com pany would be unable to com plete this analysis. M cre specifically, the
integration analysis is performed on meter data from utility-scale installations,
which is available in 1-m nute increm eats — the granularity necessary for this type
IDAHO PO W EIR CO M FANY'S RESPO N3E TO THE FIRST PRO DJCTIO NREQ LEST O FTHE
CO M M$SIO NSTAFF TO IDAHO PO W F, - 16

of analysis. O nthe other hand, while the on-site generation m eters separately
measure all delivered energy from all received energy (thus enabling real-time
net billing), the increments are only available on an hourly basis, which is not
granular enough to com plete a reliable integration study lim ited to exports.
While Idaho Power does not possess the information to reliably study only on-site
generation exports, it is anticipated that if only an export shape was considered,
the volum etric integration costs would be higher than those presented in this
case and proposed for inclusion in the ECR Update (IPC-E-25-15) for the
following reasons:
• Utility-scale solar typically has axis tracking, whereas custom e--owned
generation does not. Axis tracking reduces variability in solar output.
• Utility-scale solar projects typically oversize the panel to inverter ratio,
which reduces some of the variability in output.
• Exports generally occur m cre often in system high output, low load hours
when there is a greater need for integrating resources.
For these reasons, the Com pany feels the applied methodology (which is
consistent with how integration charges were incorporated into the current ECR)
is a reasonable approxim ation for the integration costs associated with customer-
owned generation exports.
c. As described in the Response to Staff's Request for Production No. 3(b), Idaho
Power proposes to apply a solar-based integration charge to all on-site
generation given solar m ekes up all but two of non-legacy on-site generation
installations.
IDAHO PO W EIR CO M FANY'S RESPO N3E TO THE FIRST PRO EUCTIO NREQ LEST O FTHE
CO M M$SIO NSTAFF TO IDAHO PO W F, - 17

d. Renewables require the sam eam cunt of ancillary services regardless of whether
they are tied to a battery. A tied battery can provide some or all of those
reserves. In the case where the system dispatcher does not have the ability to
operate the paired system ,they will not have access to use that battery for the
reserves and will likely need to hold an am cunt near or equal to the am cunt of an
unpaired VIER generator.
O r�site generation customers are assumed to retain control of their storage.
They are not assum ed to dispatch their storage in a way that would alleviate
integration costs.
For Q Fs, the integration costs m ay be reduced or elim hated with paired storage.
The degree to which integration costs are reduced depends on the size of the
storage installation and whether the Q For the Com pany will be able to dispatch
the storage to that end. G i✓en the wide variety of possible configurations and
purposes for the storage, these details will be determ ined with each Q F.
To date, the Com pany does not have any contracts with Q Fs with paired storage.
The response to this Request is sponsored by Jared Hansen, Resource Planning
Leader, Idaho Power Company.
IDAHO PO W EIR CO M FANY'S RESPO N3E TO THE FIRST PRO EUCTIO NREQ LEST O FTHE
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