20251028Response to Petitions for Reconsideration.pdf

IQAHOPOWER.
MEGAN GOICOECHEA ALLEN RECEIVED
Corporate Counsel OCTOBER 28, 2025
mgoicoecheaallen(cDidahopower.com IDAHO PUBLIC
UTILITIES COMMISSION
October 28, 2025
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
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
Dear Commission Secretary:
Attached for electronic filing is Idaho Power Company's Answer to the City of Boise
City and Sierra Club and Vote Solar's Petition for Reconsideration in the above-entitled
matter.
If you have any questions about the attached documents, please do not hesitate
to contact me.
Sincerely,
Megan Goicoechea Allen
MGA:sg
Attachments
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 ) ANSWER TO THE CITY OF
JUNE 1, 2025 THROUGH MAY 31, 2026, IN ) BOISE CITY AND SIERRA CLUB
COMPLIANCE WITH ORDER NO. 36048. ) AND VOTE SOLAR'S PETITION
FOR RECONSIDERATION
COMES NOW, Idaho Power Company ("Idaho Power" or "Company") pursuant to
Idaho Code § 61-626 and Idaho Public Utilities Commission's ("Commission") Rule of
Procedure' 331.05, hereby submits this answer to the Petitions filed on October 21, 2025,
by the City of Boise City ("Boise City" or"City") and Sierra Club and Vote Solar's ("SC/VS")
(collectively "Petitioners") requesting reconsideration of Commission Order No. 36785.
Hereinafter cited as Procedural Rule.
IDAHO POWER COMPANY'S ANSWER TO PETITIONS FOR RECONSIDERATION - 1

The Petitions for Reconsideration should be dismissed as they fail to comply with
Procedural Rule 331, and improperly seek to reopen the previously final and conclusive
Order No. 36048 from a different docket. Further, the Commission's Order No. 36785 in
this matter is supported by substantial, competent evidence in the record, and the
Commission properly exercised and regularly pursued its authority in its determinations.
Consequently, there is no basis for reconsideration of the Commission's final
determination in Order No. 36785.
I. SCOPE OF THE CASE
1. The instant case was initiated as the Company's first annual compliance
filing to implement the Commission-approved annual Export Credit Rate ("ECR") update
method pursuant to Commission Order No. 36048 issued in Case IPC-E-23-14 ("ECR
Methodology Case").2 Building on the foundation laid in the preceding cases, that order
approved changes to the Company's on-site generation service offerings including
approval of the ECR methodology and directing 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, 2025.113 Notably, none of the Petitioners requested reconsideration of
that Order resulting in it becoming final and conclusive.
2. As in the prior customer generation-related dockets, the instant case
generated strong interest from certain members of the public, many of whom may not
have been aware of the regulatory precedent and/or the role that stakeholder feedback
2 In the Matter of Idaho Power Company's Application for Authority 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 Methodology, Case No. IPC-E-23-14, Order No. 36048 (Dec. 29,
2023).
3 Id., at 7.
IDAHO POWER COMPANY'S ANSWER TO PETITIONS FOR RECONSIDERATION - 2

played in previously developing the ECR methodology.
3. As a result, the Company endeavored to educate stakeholders and clarify
that it was not making a new proposal in this case but merely seeking to implement the
annual ECR update as directed by the Commission 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.4
4. With the Commission having previously established the method for
calculating the ECR, including specifying the inputs and methods for updating the various
components, the scope of this case was limited to whether the Company had properly
applied the Commission-approved formula.
5. On September 30, 2025, the Commission issued Order No. 36785, which,
in pertinent part, acknowledged that the Company's filing complied with the Commission-
approved annual ECR update method outlined in Order No. 36048. Notwithstanding such
compliance, in recognition that this inaugural update — particularly when coupled with
unrelated rate changes that have occurred in other dockets impacting all customers —
results in varying customer bill impacts, with some on-site generation customers subject
to relatively large bill increases, the Commission found it reasonable to implement certain
4 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 ANSWER TO PETITIONS FOR RECONSIDERATION - 3

mitigation measures.
6. Responding to those comments raising issues that have already been
addressed by the Commission or were otherwise outside the scope of this compliance
filing docket, the Commission emphasized that it had previously "provided a
comprehensive review of each component of the ECR calculation in its decision, seeking
`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."15
7. While it is impossible to expect that all interested parties will agree with the
balance the Commission struck, it was the result of a careful and thorough review of the
issues and consideration of competing interests that occurred throughout a years-long,
multi-phase collaborative process to modernize an outdated service offering, including
modifying the compensation structure for on-site generators to more accurately measure,
record, and value their excess energy exported to the Company. Having conducted this
comprehensive review and formulating the ECR through a thorough data-driven,
collaborative, and thoughtful process, the Commission established ECR Methodology
should provide the framework for valuing excess energy for on-site generators for the
foreseeable future; in the absence of dramatically changed and unforeseen
circumstances, there should not be a need to repeat this process for some time to come.
II. BACKGROUND
8. The extensive history of the Company's net metering service offering
demonstrates an on-going and incremental effort by the Company to establish a
5 Order No. 36785 at 23 (citing Case No. IPC-E-23-14, Order No. 36048 at 6).
IDAHO POWER COMPANY'S ANSWER TO PETITIONS FOR RECONSIDERATION -4

foundation for modernizing its on-site generation offering to support enhanced adoption
of renewable energy resources and advances in energy generation technology, while
simultaneously ensuring equity among all customers. Over the last several years, with
guidance from the Commission, Idaho Power has modernized the on-site generation
compensation structure through a series of customer-self generation dockets.
9. In 2019 and 2020, the Commission established criteria to define legacy
treatment for existing systems, providing a clear distinction between existing and new
customers based on the customers' reasonable expectations when they procured an on-
site generation system.6 Under this established criteria, systems qualifying for legacy
treatment continue to take service under the rules for net energy metering until legacy
status terminates, while non-legacy systems are subject to future changes to the program
fundamentals, including the compensation structure applied to excess energy.
10. The Commission also established a process to ensure any changes to the
Company's on-site generation service offering are well-reasoned and data driven,
requiring that the Company undertake a comprehensive study of the costs and benefits
of on-site generation before any changes applicable to non-legacy customer
compensation would be considered.'
11. More recently, Idaho Power initiated the multi-phase process for a
comprehensive study of the costs and benefits of on-site generation. In 2021, the study
6 In the Matter of the Application of Idaho Power Company to Study the Costs, Benefits, and
Compensation of Net Excess Energy Supplied by Customer On-Site Generation, Case No. IPC-E-18-15,
Order No. 34509 at 10 (Dec. 20, 2019); In the Matter of Idaho Power Company's Application for Authority
to Modify Schedule 84's Metering Requirement and to Grandfather Existing Customers with Two Meters,
IPC-E-20-26, Order No. 34854 at 10 (Dec. 1, 2020).
In the Matter of the Application of Idaho Power Company for Authority to Establish New Schedules for
Residential and Small General Service Customers with On-Site Generation, Case No. IPC-E-17-13,
Order No. 34046 at 22 (May 9, 2018).
IDAHO POWER COMPANY'S ANSWER TO PETITIONS FOR RECONSIDERATION - 5

design phase of the process concluded and was subsequently followed in 2022 by a study
review phase.' Ultimately, the Commission found the Company's October 2022 Value of
Distributed Energy Resource ("VODER") study complied with its previous directives and
"should serve as a basis for the Company's implementation recommendations in a
subsequent case."9
ECR Methodology Case
12. Having completed the process established by the Commission to prepare
for changes to its on-site generation offering, on May 1, 2023, Idaho Power filed Case
No. IPC-E-23-14 to establish an updated offering, proposing modifications to the
compensation structure for on-site generators with non-legacy systems that intended to
more accurately measure, record, and value excess energy.
13. In Order No. 36048, the Commission approved the Company's request to
implement, effective January 1, 2024, real-time net billing to measure and charge
customers for all kilowatt-hour ("kWh") consumed from the grid at the retail rate, and
measure and compensate customers for all kWh exported to the grid at a time-
differentiated ECR.10 The changes were approved to take effect with non-legacy
customers' January 2024 billing period.
14. Having approved the methodology for determining the ECR, as well as the
source to be relied on for each of its components, the Commission further ordered that
8 In the Matter of the Application of Idaho Power Company's Application to Initiate a Multi-Phase
Collaborative Process for the Study of Costs, Benefits, and Compensation of Net Excess Energy
Associated with Customer On-Site Generation, Case No. IPC-E-21-21; 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 for Non-Legacy Systems, Case No. IPC-E-22-22 .
s Id., Order No. 35631 at 28 (Dec. 19, 2022).
10 Order No. 36048 at 6.
IDAHO POWER COMPANY'S ANSWER TO PETITIONS FOR RECONSIDERATION - 6

the Company update all components of the ECR, except the season and hours of highest
risk in an annual filing made on April 111 with an effective date of June 1.12 In addition,
while the Commission did not find that a transition period was necessary, it did find that
gradualism for rate changes merited consideration and agreed that the Company should
forego the initial update to provide time for customers to acclimate to the new ECR billing
structure, directing the Company to file its first annual update on April 1, 2025.
ECR Update Compliance Filing
15. 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.
16. Despite the limited scope of this docket, the Commission incorporated both
a public workshop and a customer hearing, in addition to providing the opportunity for
interested persons to provide written comments on the Company's Application, to ensure
that members of the public were informed and had access to clear, transparent, and
factual information. Comments were submitted by Commission Staff ("Staff") and
intervening parties.13 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. Many of the comments submitted in this case raised issues that
were outside the scope of this compliance filing docket.
" Id., at 7.
12 Id., at 18.
13 Clean Energy Opportunities for Idaho ("CEO"), Kevin Dickey, pro se, Scott Pinizzotto, pro se, Martha
Bibb, pro se, City of Boise City, and Sierra Club &Vote Solar. Tyler Grange, pro se, petitioned to
intervene and submitted comments but was not granted intervention by the Commission.
IDAHO POWER COMPANY'S ANSWER TO PETITIONS FOR RECONSIDERATION - 7

17. In Final Order No. 36785 issued on September 30, 2025, the Commission
approved the Company's Application to update the ECR for non-legacy on-site generation
customers, subject to certain mitigation measures set forth in the Order, effective October
1, 2025, and suspended the Company's annual update requirement until 2028. The
Commission further directed the Company to update the ECR rates in its April 1, 2028,
filing in compliance with Order No. 36048. The Commission's findings were based on its
examination of the comprehensive record in this matter, including all comments submitted
by the public, intervenors, and the Company and informed by the long history of cases
dealing with on-site generation, public comments and testimony, proposals offered by all
parties, as well as the impact of outcomes from other dockets (notably recent general rate
cases).
Petitions for Reconsideration of Final Order No. 36785
18. On October 21, 2025, Boise City and SC/VS filed Petitions for
Reconsideration of Order No. 36785. For the reasons further set forth below, the
Company respectfully requests the Commission dismiss the Petitions as they fail to
comply with Procedural Rule 331, and improperly seek to reopen the previously final and
conclusive Order No. 36048 from a different docket. Further, the Commission's Order No.
36785 in this matter is supported by substantial, competent evidence in the record, and
the Commission properly exercised and regularly pursued its authority in its
determinations. Consequently, there is no basis for reconsideration of the Commission's
final determination in Order No. 36785.
IDAHO POWER COMPANY'S ANSWER TO PETITIONS FOR RECONSIDERATION - 8

III. LEGAL STANDARDS
19. "Reconsideration affords parties an opportunity to bring to the
Commission's attention any matter previously determined and provides the Commission
an opportunity to rectify any mistake before the matter is appealed to the Supreme
Court."14 Idaho Code § 61-626 and Commission Rules of Procedure 331-333 set forth the
process for seeking reconsideration of a final order of the Commission, providing that
petitions for reconsideration be filed within twenty-one (21) days after a final order.
Answers to petitions for reconsideration that disagree with the petition must be filed within
seven (7) days.15 The Commission must determine whether or not it will grant
reconsideration within twenty-eight (28) days after the filing of a petition for
reconsideration; if granted, the Commission "shall specify how the matter will be
reconsidered," whether by review of the existing record, rehearing, written briefs,
interrogatories, or otherwise.16
20. The Idaho Supreme Court has recognized that the Commission has broad
discretion and appellate review of its decisions is limited. In the face of conflicting
evidence, the Court will not displace the Commission's findings of fact "even though the
Court may justifiably arrive at a different conclusion if the matter were before it de novo."11
The Commission's findings of fact are entitled to a presumption of correctness and will be
sustained unless it appears that the clear weight of the evidence is against its conclusions
or that the evidence is strong and persuasive that the Commission abused its discretion.18
14 Order No. 36082 at 1 (Feb. 12, 2024), citing Washington Water Power Co. v. Idaho Public Utilities
Comm'n, 101 Idaho 567, 617 P.2d 1242 (1980).
15 IDAPA 31.01.01.331.05.
16 Idaho Code § 61-626(2); IDAPA 31.01.01.332.
17 Rosebud Enters., Inc. v. Idaho Pub. Utilities Comm'n, 128 Idaho 609, 618, 917 P.2d 766 (1996).
18 Indus. Customers of Idaho Power v. Idaho Pub. Utilities Comm'n, 134 Idaho 285, 292, 1 P.3d 786
(2000).
IDAHO POWER COMPANY'S ANSWER TO PETITIONS FOR RECONSIDERATION - 9

The burden is on the party challenging the Commission's findings to show that they are
unsupported by substantial evidence.19 With regard to questions of law, the review on
appeal is limited to a determination of whether the Commission has regularly pursued its
authority and whether the constitutional rights of the appellant have been violated.20
21. Consistent with the purpose of reconsideration to provide the Commission
an opportunity rectify a mistake or omission, Procedural Rule 331 requires that petitions
for reconsideration contain certain information including setting forth specifically why the
petitioner contends that "the order or any issue decided in it is unreasonable, unlawful,
erroneous or not in conformity with the law." That rule further requires that petitioners
specify "the nature and quantity of evidence or argument the petitioner will offer if
reconsideration is granted."21 A petition must also state whether the petitioner requests
reconsideration by "evidentiary hearing, written briefs, comments, or
interrogatories.1122 Under Procedural Rule 332, "[g]rounds for, or issues on
reconsideration not supported by specific explanation may be dismissed."
IV. ANSWER TO PETITIONS FOR RECONSIDERATION
A. RECONSIDERATION IS NOT WARRANTED.
22. While the City and SC/VS take different approaches in their Petitions for
Reconsideration and are ostensibly couched as requests for review of Order No. 36785,
both share a common genesis: disagreement with the ECR methodology previously
adopted by Commission in Order No. 36048. However, the fact remains that Order No.
36048 is final and conclusive and it is not appropriate for Petitioners to now challenge the
19 Id.
20 Id. at 288.
21 IDAPA 31.01.01.331.01.
22 IDAPA 31.01.01.331.03.
IDAHO POWER COMPANY'S ANSWER TO PETITIONS FOR RECONSIDERATION - 10

ECR methodology, 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 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."23
23. Each of the Petitioners participated in the ECR Methodology Case, as both
the City and Vote Solar sought and were granted intervention. As noted by Vote Solar in
its Petition for Intervenor Funding filed in that case, "[I]egal counsel and expert advisors
for Vote Solar were active participants in all stages of the proceeding."24 However,
neither Vote Solar nor the other Petitioners in this case sought reconsideration of
Commission Order No. 36048 after it was issued on December 29, 2023.
24. In affording orders of the Commission a degree of finality similar to that
possessed by judgments made by a court of law'25 the legislature sought to preclude
parties from repeatedly rehashing and relitigating matters already decided in the interest
of administrative efficiency, stability, and fairness. The wisdom of this policy is especially
apparent in the instant case, which represents the culmination of a years-long, multi-
phase collaborative process that the Petitioners now suggest was in vain.
23 Utah-Idaho Sugar Co. v. Intermountain Gas Co., 100 Idaho 368, 373-374, 595 P.2d 1058 (1979).
24 Case No. IPC-E-23-14, Vote Solar's Petition for Intervenor Funding at 4 (Nov. 30, 2023).
21 See Idaho Code § 61-625.
IDAHO POWER COMPANY'S ANSWER TO PETITIONS FOR RECONSIDERATION - 11

25. 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.26 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 Petitioners to re-raise the same issues. Given that
both Petitions raise issues that have already been explicitly considered in the ECR
Methodology Case, it would be disingenuous for the Petitioners to suggest that the ECR
methodology is ripe for review due to a change in circumstances or newly identified issues
stemming from the ECR Update Compliance Filing. For example, SC/VS note in their
Petition that several issues they previously identified with the ECR calculation "persist,"27
and all Petitioners raise volatility in the avoided energy component of the ECR as cause
for concern and urge the Commission to consider other options for determining the
avoided energy value.28 This very issue was specifically raised and considered by the
Commission in Order No. 36048 issued in the ECR Methodology Case, which was not
challenged on reconsideration by either Vote Solar or the City in that proceeding. This
issue was again raised by parties in the underlying ECR Update Compliance Filing and
is now being raised again on reconsideration.
26. Reconsideration is not an appropriate forum for raising issues outside the
scope of the underlying compliance case or for rearguing previously rejected points, and
the Petitioners' requests should be denied.
21 Rosebud Enters., Inc. v. Idaho Pub. Utilities Comm'n, 128 Idaho 609, 618, 917 P.2d 766, 775 (1996).
27 SC/VS Petition at 4 (Oct. 21, 2025).
28 SC/VS Petition at 6-7; Boise City Petition at 5-6 (Oct. 21, 2025).
IDAHO POWER COMPANY'S ANSWER TO PETITIONS FOR RECONSIDERATION - 12

B. BOISE CITY'S PETITION FOR RECONSIDERATION.
27. Boise City's Petition requests that the Commission grant reconsideration by
written briefs and comments, noting that the reconsideration request raises questions of
law and policy, not issues of fact. However, the City's Petition fails to establish that Order
No. 36785 is unreasonable, unlawful, erroneous or not in conformity
with the law. Further, it is not clear from the Petition the nature and quantity of evidence
or argument that the City would offer if reconsideration is granted. Thus, as an initial
matter, the Petition does not comply with the requirements of the Idaho Public Utilities
Commission Rules of Procedure for Petitions for Reconsideration.
28. Moreover, the City's Petition raises issues already considered by the
Commission in the underlying proceeding and in the ECR Methodology Case. As noted
in Order No. 36785, the Commission previously provided a comprehensive review of each
component — including the avoided energy — of the ECR calculation in its decision in the
ECR Methodology Case in order to accurately assign the appropriate share of fixed costs
and unquantified benefits of on-site customer generation and to strike a reasonable
balance between the interests of customers with on-site generation, and customers
without.29
29. In Final Order No. 36785, the Commission acknowledged that the
Company's 2025 ECR Annual Update filing complied with the Commission-approved
annual ECR update method, which the City does not dispute. Instead, the gravamen of
the City's Petition appears to be that the ECR update is "unfair", though it fails to offer any
objective support for that assessment. Rather, the City incorrectly infers "unfairness"
29 Order No. 36785 at 23 (citing Case No. IPC-E-23-14, Order No. 36048 at 6).
IDAHO POWER COMPANY'S ANSWER TO PETITIONS FOR RECONSIDERATION - 13

based on the fact that the Commission implemented a "mitigated" ECR. The City also
references public comments and party comments in the case that indicated "a resounding
sentiment that the compensation proposed for customer-generators does not capture the
full benefit the customer-generators provide to the grid.1130
30. Mitigation. The suggestion that the Commission's adoption of mitigation
measures in this case reflects an acknowledgment by the Commission that the proposed
ECR was unfair is unsupported.31 Within Final Order No. 36785, the Commission was
very clear that its decision to implement some mitigation in the updated ECR was
reasonable not because of some sort of deficiency in the ECR's methodology or resulting
rate being determined to be unfair, but rather because:
all customers-including non-legacy on-site generation
customers-have faced increases to their average monthly bills
over the past 18 months. The Commission recognizes that the
updates to the ECR proposed in the Company's Application
would further affect customers in Schedule 6, 8, and 84. As
demonstrated in the record, if the proposed updates to the
ECR were approved as filed, some Schedule 6 customers'
monthly bills would increase by up to 100% in a relatively short
period (factoring in the multiple changes to the ECR
compounded with the recent general rate increases).32
Moreover, as more fully set forth in Section C below, the Commission has broad
discretion in determining whether rate mitigation measures may be appropriate under
certain circumstances and it regularly pursued its authority in implementing mitigation in
this case.
30 Boise City Petition at 5.
31 Id.
32 Order No. 36785 at 24.
IDAHO POWER COMPANY'S ANSWER TO PETITIONS FOR RECONSIDERATION - 14

31. Public Sentiment. The Company also disagrees that the comments
received in the underlying docket demonstrate that the ECR methodology is
fundamentally inequitable. While the Company understands the great interest shown in
this case and appreciates those members of the public that have chosen to participate, it
notes that they represent a small percentage of the Company's total customers,33 and
were largely offered by non-legacy on-site generation customers.34
32. The Company is accountable to the Commission and is legally obligated to
consider the collective interests of all its customers and to develop mechanisms and
proposals 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.35 Similarly, the Commission has previously and continues to maintain 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."36
33. As noted above, the City has not taken the position that the Company's
proposed update failed to conform with the Commission-established methodology but
rather seeks to change the underlying method for avoided energy based on its perception
that the previously approved method has resulted in an unfair rate in furtherance of
particular policy objectives of the City. The City did not take issue with those components
of the ECR method that positively impacted the ECR, only the avoided energy value
ss 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, which represent
roughly 0.15 percent of the Company's total customers and less than 10 percent of non-legacy
customers.
34 Case No. IPC-E-25-15, Staff Comments at 12 (May 15, 2025).
ss See Idaho Code § 61-301.
ss Case No. IPC-E-23-14, Order No. 36048 at 5.
IDAHO POWER COMPANY'S ANSWER TO PETITIONS FOR RECONSIDERATION - 15

component of the ECR, which was the most significant driver of ECR decrease in the
Company's 2025 ECR Annual Update.37 Thus, the City's concerns appear to be largely
driven by the market, not the method.
34. Regardless, the City's request for the Commission to direct the Company
to provide additional options for determining the avoided energy value is outside the
scope of the underlying docket and therefore not appropriately raised on reconsideration.
C. SIERRA CLUB AND VOTE SOLAR'S PETITION FOR RECONSIDERATION.
35. SC/VS's Petition requests reconsideration by written briefs or comments
and seeks a limited modification to Order No. 36785 that would retain the approved ECR
implemented by the Commission in that order but direct Staff to convene a stakeholder
working group to improve the ECR calculation methodology moving forward.
36. While SC/VS's Petition ostensibly attempts to identify a basis for
reconsideration as required by Procedural Rule 331, a review of Order No. 36785 and the
underlying record belies any assertion that the Commission decisions are not supported
by the record or are otherwise improper as more fully set forth below.
(1) The Commission's final Order No. 36785 is supported by substantial
evidence and should be affirmed.
37. While SC/VS do not oppose the mitigation measures adopted by the
Commission in Order No. 36785, by which it limited decreases to the energy component
of the ECR to no more than 40 percent and stabilized the ECR until 2028, they suggest
the adoption of such measures on an ad hoc basis reveals an infirmary in the
37 As noted by the Company in its Reply Comments, "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 [Power Cost Adjustment] 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 that
year."
IDAHO POWER COMPANY'S ANSWER TO PETITIONS FOR RECONSIDERATION - 16

Commission's order.38 The Petition states: "Commission orders are unlawful when the
Commission acts `arbitrarily or on an ad hoc basis."' In support of this proposition, the
Petition cites to Wash. Water Power v. Idaho Pub. Utils. Comm'n,39 though a review of
that case clarifies that the quoted language is actually part of a larger quote from an
Oregon appellate decision,40 which the Idaho Supreme Court relies on to support the
following well-established proposition: "Not only must the Commission make and enter
proper findings of fact, but it must set forth its reasoning in a rational manner.1141
38. In finding some mitigation to be reasonable to reduce the impact of all recent
rate changes, the Commission included a thorough discussion of the various mitigation
proposals recommended by the parties in Order No. 36785,42 ultimately deciding on a
hybrid approach limiting the change in the avoided energy value to be a 40 percent
decrease from the then-existing ECR's avoided energy value. "After considering the
options presented, an ECR update where the change in the avoided energy value is
limited to a 40% decrease from the current ECR's avoided energy value, applied to both
the summer and non-summer months, is reasonable." Contrary to the Petition's
contention, this approach was one of the alternative mitigation proposals outlined by
Staff.43 Additionally, the Commission determined in its discretion to suspend the annual
38 SC/VS Petition at 2-3.
39 SC/VS Petition at footnote 3.
40 "If there is to be any meaningful judicial scrutiny of the activities of an administrative agency-not for the
purpose of substituting judicial judgment for administrative judgment but for the purpose of requiring the
administrative agency to demonstrate that it has applied the criteria prescribed by statute and by its own
regulations and has not acted arbitrarily or on an ad hoc basis-we must require that its order clearly and
precisely state what it found to be the facts and fully explain why those facts lead it to the decision it
makes." Home Plate, Inc. v. OLCC, 20 Or. App. 188, 530 P.2d 862, 863 (1975).
41 Washington Water Power Co. v. Idaho Pub. Utilities Comm'n, 101 Idaho 567, 575, 617 P.2d 1242,
1250 (1980).
42 See, e.g. Staff's Mitigation Proposal at 6-8; CEO proposal at 11; Company Reply to Mitigation at 19-20.
43 Staff Comments at 10, Table Nos. 4 and 5.
IDAHO POWER COMPANY'S ANSWER TO PETITIONS FOR RECONSIDERATION - 17

update requirement until 2028. This decision was not dissimilar to the Commission
delaying the first annual update following the ECR Methodology Case. In Final Order No.
36048 issued in that case, and after considering various comments related to transitional
considerations, the Commission found a delay in the first annual update of one year was
reasonable. While SC/VS assert the Commission did not explain its rationale for a three-
year suspension of the annual update in this case, the Commission specifically cited to
public comments where many individuals stated they had not been informed that the ECR
would be subject to annual adjustments, and indicated it found "that the annual update to
the ECR as required by Order No. 36048 is difficult for non-legacy on-site generation
customers to adjust to and complicates investment decisions by potential on-site
generation customers.1144
39. Thus, a review of Order No. 36785 reveals that it sets forth ample
justification and adequate findings of fact for the mitigation measures implemented by the
Commission contrary to the assertion by SC/VS that such Order fails to explain how the
Commission came to adopt the mitigation measures selected.45
40. Moreover, the Commission's discretion to implement rate mitigation
measures to facilitate fair, just, and reasonable outcomes, although infrequently used, is
not an approach unique to this case — or for Idaho Power. In fact, it has been a practice
of this Commission to implement rate mitigation measures for annual mechanisms when
it has found the compounding effects of other circumstances warrant such mitigation.
When the Commission initially approved the Company's annual Power Cost Adjustment
("PCA") mechanism in Case No. IPC-E-92-25, it grappled with whether to implement
44 Order No. 36785 at 24.
45 SC/VS Petition at 3.
IDAHO POWER COMPANY'S ANSWER TO PETITIONS FOR RECONSIDERATION - 18

specific rate stability mechanisms as advocated for by various parties to that case.
Ultimately, the Commission found "the most reasonable solution is, rather than now
adopting a specific rate stability mechanism, we reserve the right to examine proposed
rate changes occurring in any one year and to impose different recovery methods if the
proposed rate changes appear to seriously impair rate stability.1146 Indeed, the
Commission has — on two occasions — elected to implement mitigation as part of the
annual PCA filing.
41. As part of Order No. 29026 issued in Case No. IPC-E-02-03, the
Commission required the Company defer collection of approximately $11.5 million in
power costs attributable to the Company's small general service and irrigation customer
classes until the following 2003-2004 PCA year as a means to mitigate such customer
classes' rate increases.47 Of note, the ultimate mitigation adopted by the Commission was
not a specific recommendation raised by any one party on the record, rather, the
Commission's rationale for its novel mitigation measure focused on bill impacts to the
irrigation and small business customer classes stemming from other recent rate changes.
42. The Commission also implemented a discretionary cap for annual rate
increases of no more than 3 percent when it initially approved the Company's annual
Fixed Cost Adjustment ("FCA") mechanism.48 In assessing whether to apply the cap in
Case No. IPC-E-19-10, the Commission found it reasonable "to waive the 3% cap on FCA
46 In the Matter of the Application of Idaho Power Company for Authority to Implement a Power Cost
Adjustment Tariff for Electric Service to Customers in the State of Idaho and for Approval of New Rates
for Service Under the FMC Special Contract, IPC-E-92-25, Order No. 24806 at 14 (March 29, 1993).
41 In the Matter of the Application of Idaho Power Company for Authority to Implement a Power Cost
Adjustment(PCA) Rate for Electric Service from May 16, 2002 through May 15, 2003, IPC-E-02-03,
Order No. 29026 at 17-18 (May 13, 2002).
48 In the Matter of the Investigation of Financial Disincentives to Investment in Energy Efficiency by Idaho
Power Company, IPC-E-04-15, Order No. 30267 (March 12, 2007).
IDAHO POWER COMPANY'S ANSWER TO PETITIONS FOR RECONSIDERATION - 19

increases and approve the 3.64% increase because the rate impact will be mitigated by
other Company filings that will take effect on the same date" citing to decreases in both
the PCA and Energy Efficiency Rider that were to take effect June 1, coincident with
updated FCA rates.49 In its findings, the Commission further highlighted "[t]he 3% cap
was meant to prevent rate increases from being stacked upon each other, which is not a
concern in this case.1150 Again, the Commission found it reasonable to assess whether to
implement mitigation (or not, in this case) based on rate impacts that were occurring
outside of the case at hand, in recognition that rate mitigation should holistically consider
circumstances faced by customers.
43. The Commission most recently elected to mitigate the Company's proposed
PCA rates through Final Order No. 35804 issued in Case No. IPC-E-23-12 due to the
extraordinary circumstances at the time leading to high net power costs. The
Commission's rationale for mitigation in that case was quite similar to the rationale cited
in the instant case: "However, due to a variety of factors, including but not limited to,
general rate cases that have been filed by this and other utilities...utility customers in
Idaho have recently seen their bills for all utility services increase.1151
44. Notably, in none of these instances was the Commission's adoption of
mitigation measures a result of the proposed rates themselves being unfair or because
of a flawed underlying methodology. Instead, the Commission simply employed rate
mitigation to recognize and limit the impact that then-relevant factors would have on
49 In the Matter of the Application of Idaho Power Company for Authority to Implement Fixed Cost
Adjustment("FCA') Rates for Electric Service from June 1, 2019, through May 31, 2020, IPC-E-19-10,
Order No. 34346 at 5 (May 31, 2019).
50 Id.
51 In the Matter of the Application of Idaho Power Company for Authority to Implement Power Cost
Adjustment(PCA) Rates for Electric Service from June 1, 2023 through May 31, 2024, IPC-E-23-12,
Order No. 35804 at 8 (May 31, 2023).
IDAHO POWER COMPANY'S ANSWER TO PETITIONS FOR RECONSIDERATION -20

customers' bills — precisely the same rational utilized by the Commission in Final Order
No. 36785 when determining mitigation of the Company's proposed ECR to be a
reasonable approach.
(2) The Record Confirms that the Company's Filing Complied with the
Commission-Approved Annual ECR Update Methodology.
45. Given that SC/VS admittedly support the mitigation measures adopted by
the Commission in Order No. 36785, their purported concerns over their alleged "ad hoc
nature" should be moot, yet they are raised in an apparent effort to transform this
compliance docket into a forum for reconsidering the underlying ECR methodology, which
is clearly outside the scope of this case. Though thinly veiled as a challenge to the
sufficiency of the evidentiary record in this case, SC/VS's Petition essentially seeks to
rehash and relitigate positions that have already been decided. After acknowledging that
some of their perceived issues with the ECR methodology were previously raised in Case
No. IPC-E-23-14, SC/VS suggest that the ECR methodology should be reevaluated in
this compliance docket because "the ECR update application proved those concerns to
be valid.1152 Petitioners' attempt to reopen the record on the establishment of the ECR
methodology in Case No. 23-14 is inappropriate and should not be allowed.
46. The Commission confirmed in Order No. 36785 that it had considered the
long history of cases dealing with on-site generation, public comments and testimony,
and proposals offered by all parties in formulating the ECR.53 It also noted that many of
the recommendations and concerns offered in this matter had previously been addressed
in Case No. IPC-E-23-14 and were outside the scope of this proceeding.54 The
ez SC/VS Petition at 4.
ss Order No. 36785 at 23.
sa Id.
IDAHO POWER COMPANY'S ANSWER TO PETITIONS FOR RECONSIDERATION - 21

Commission previously provided a comprehensive review of each component of the ECR
methodology,55 and while SC/VS may disagree with the ECR methodology previously
adopted by the Commission, such critiques were misplaced in the underlying docket and
are not appropriate for reconsideration.
47. Moreover, similar to Boise City, SC/VS mischaracterizes the Commission's
intent in implementing mitigation measures alleging that: "[b]y adopting these measures,
the Commission rightfully recognized that Idaho Power's proposal was unjust and
unreasonable and therefore required modification.1156 This statement is directly at odds
with the reasoning set forth by the Commission in Order No. 36785, and as more fully
discussed above, the Commission has periodically implemented mitigation measures in
other annual mechanism cases when a review of holistic circumstances warrants doing
so.
(3) The ECR Methodology Has Been Extensively Vetted Through a
Collaborative Process with Stakeholders.
48. Unfortunately, the case history does not support SC/VS's recommendation
that an ECR Working Group could be an effective way to "assess modification to the ECR
calculation"57 or that "the Commission can proactively avoid future ECR disputes by
addressing issues with the calculation methodology over the next two and half years."58
49. As background, on October 19, 2018, Idaho Power petitioned to initiate
Case No. IPC-E-18-15 with the very intent to study the costs, benefits, and compensation
55 Case No. IPC-E-23-14, Order No. 36048.
51 SC/VS Petition at 3.
57 SC/VS Petition at 7.
5s Id.
IDAHO POWER COMPANY'S ANSWER TO PETITIONS FOR RECONSIDERATION - 22

of net excess energy supplied by customer generation.59 Rather than submit a proposal
in the case, Idaho Power sought to comply with a previous Commission directive where
the Company was to first initiate a docket, and once intervening parties were identified,
all parties would "meet in an effort to agree on the scope of proper procedural and
substantive elements of the on-site generation docket" that would be brought to the
Commission for approval.60 Over the course of nearly a year, Idaho Power worked in good
faith with the parties to that case (Boise City, Sierra Club, and Vote Solar were all granted
intervention status, among others) to find common resolution related to the matters of
valuing excess generation, among other items.61 In total, the parties held one prehearing
conference and eight settlement conferences, over the course of which multiple detailed
proposals from several parties were shared, discussed, and refined. On October 11,
2019, the Company and the Commission Staff jointly submitted a Motion to Approve
Settlement Agreement. On December 20, 2019, the Commission issued an order
rejecting the Settlement Agreement, citing in part concerns about lack of transparency.
50. The ECR methodology that was ultimately approved by the Commission
was informed and refined by feedback from Staff and the parties in the ECR Methodology
Case, which included a number of the same parties involved in the instant docket,
including the Petitioners. In developing its final proposal submitted in the ECR
Methodology Case, the Company included modifications to its initially proposed ECR that
were responsive to party feedback, ultimately seeking to pursue a structure that would
59 In the Matter of Idaho Power Company's Application to Study the Costs, Benefits, and Compensation of
Net Excess Energy Supplied by Customer On-Site Generation, IPC-E-18-15.
so In the Matter of Idaho Power Company's Application for Authority to Establish New Schedules for
Residential and Small General Service Customers with On-Site Generation, IPC-E-17-13, Order No.
34046 at 23 (May 9, 2018).
61 Also within scope was consideration related to: compensation structure, the update frequency for the
ECR, smart inverters, and non-export options for customer generators.
IDAHO POWER COMPANY'S ANSWER TO PETITIONS FOR RECONSIDERATION -23

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.62
51. While the Petitioners may not agree with the approach adopted by the
Commission in Order No. 36785, it cannot be reasonably denied that it was the result of
a thorough, data-driven evaluation that involved careful consideration of multiple
alternative options and an interactive process with a robust level of public and stakeholder
engagement. A review of the extensive process that was directed by the Commission,
attached hereto as Attachment 1, highlights the number of opportunities for input that was
afforded to stakeholders, intervenors, and members of the public.
52. First, the process outlined by SC/VS ignores the fact that the Commission
already directed a similar — albeit much more transparent — process through Case Nos.
IPC-E-21-21 and IPC-E-22-22. Neither the Sierra Club nor Vote Solar elected to formally
participate in Case No. IPC-E-21-21, where the scope of the VOIDER Study was
established by the Commission, or Case No. IPC-E-22-22, where the Commission
acknowledged the VOIDER Study as having complied with its prior directives.
53. For these reasons, the Commission should reject the recommendation to
establish a new ECR Working Group. The regulatory history demonstrates that Idaho
Power, Staff, interested parties and the Commission have already undertaken a robust,
62 Case No. IPC-E-23-14, Order No. 36048 at 5-6.
IDAHO POWER COMPANY'S ANSWER TO PETITIONS FOR RECONSIDERATION - 24

inclusive, and transparent process to evaluate and implement a methodology for valuing
customer generation. The VODER Study, acknowledged by the Commission,
represented the culmination of years of stakeholder engagement and technical analysis,
and was reasonably relied upon for recommendations pursued in the ECR Methodology
Case. Reopening this process now — particularly at the request of parties who declined
to meaningfully participate in prior proceedings — would not only be redundant but risk
undermining the regulatory certainty the Commission has worked to establish. The
Commission should instead reaffirm its commitment to the current methodology and its
conclusions from Order No. 36785.
V. CONCLUSION
The Petitions for Reconsideration should be dismissed as they fail to comply with
Procedural Rule 331, and improperly seek to reopen the previously final and conclusive
Order No. 36048 from a different docket. Further, the Commission's Order No. 36785 in
this matter is supported by substantial, competent evidence in the record, and the
Commission properly exercised and regularly pursued its authority in its determinations.
Consequently, there is no basis for reconsideration of the Commission's final
determination in Order No. 36785 and reconsideration should be denied.
DATED at Boise, Idaho this 28' day of October 2025.
MEGAN GOICOECHEA ALLEN
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S ANSWER TO PETITIONS FOR RECONSIDERATION - 25

CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 28th day of October 2025, 1 served a true and
correct copy of the within and foregoing Idaho Power Company's Response to Petitions
for Reconsideration 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 and Vote Solar 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 [e-mail]
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(a)_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 ANSWER TO PETITIONS FOR RECONSIDERATION - 26

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 ANSWER TO PETITIONS FOR RECONSIDERATION - 27

Stacy Gust
Regulatory Administrative Assistant
IDAHO POWER COMPANY'S ANSWER TO PETITIONS FOR RECONSIDERATION - 28

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

mpgStakeholder Involvement ,ECR-related Outcome
IPC-E-21-21 Idaho Power's Application to Intervenors: Industrial Customers of Idaho Power, IdaHydro, Idaho Order No.35284(12/30/2021):
Initiate a Multi-Phase Process Conservation League,Idaho Clean Energy Association,Clean Energy Established the Commission's Study Framework to
for the Study of Costs, Opportunities for Idaho, Idaho Solar Owners Network,Micron Technology, be used when evaluating the costs and benefits of
Benefits,and Compensation of Inc.,City of Boise,Kiki Leslie A.Tidwell,pro se, Idaho Irrigation Pumpers on-site generation.
Net Excess Energy Associated Association,Inc.,Richard E.Kluckhohn,pro se,and Wesley A.Kluckhohn, • The Commission directed the Company to complete
with Customer On-Site pro se,ABC Power Company LLC,Idahome Solar LLC,and Comet Energy the Study Review Phase in 2022 as soon as
Generation. LLC. feasible.
Schedule
• Three rounds of Party comments;
• Two meetings among Parties(8/30/2021 and 9/22/2021)to
discuss the study framework;
• One Company-led virtual workshop(10/20/2021);
• One Staff-led virtual workshop(10/26/2021);
• One virtual customer hearing(10/28/2021).
IPC-E-22-22 Idaho Power's Application to Intervenors:Clean Energy Opportunities for Idaho, IdaHydro,Idaho Order No.35631 (12/19/2022):
Complete the Study Review Irrigation Pumpers Association, Inc.,Idaho Conservation League, Industrial Acknowledged the Company's October VOIDER
Phase of the Comprehensive Customers of Idaho Power,City of Boise, Richard E.Kluckhohn,pro se,and Study.
Study of Costs and Benefits of Wesley A.Kluckhohn,pro se,Micron Technology, Inc., Idaho Solar Owners Directed the Company to file a request to implement
On-Site Customer Generation. Network,and ABC Power Company LLC. changes to the structure and design of its on-site
generation offering.
Schedule:
• Two rounds of Party comments; Order No.35667(1/19/2023):
• One Company-led virtual workshop(8/31/2022); Dismissed a non-party Petition for Reconsideration
• Two Staff-led virtual workshops(9/6/2022 and 9/7/2022); based on the Petition not explaining why Order No.
• Three in-person customer hearings, 10/27/2022 in Pocatello, 35631 was unreasonable,unlawful,erroneous,or
11/2/2022 in Twin Falls,and 11/3/2022 in Boise. not in conformity with the law.
IPC-E-23-14 Idaho Power's Application for Intervenors: Idaho Irrigation Pumpers Association,Inc., Idaho Conservation Order No.36048(12/29/2023):
Authority to Implement League, IdaHydro,Clean Energy Opportunities for Idaho,Micron • Approved real-time Net Billing;
Changes to the Compensation Technology, Inc.,City of Boise,and Vote Solar. Established the ECR methodology;
Structure Applicable to • Ordered Idaho Power to update the ECR,except for
Customer On-Site Generation Schedule: the underlying season and hours of highest risk,in
Under Schedules 6,8,and 84 • Two rounds of Party comments; an annual filing beginning April 1,2025.
and to Establish an Export Two Staff-led virtual workshops(9/6/2023 and 9/7/2023);
Credit Rate Methodology. Two in-person customer hearings, 10/24/2023 in Boise and Order No.36082(2/12/2024):
11/8/2023 in Twin Falls. • Dismissed two non-party Petitions for
Reconsideration based on the Petitions not
explaining why Order No.36048 was unreasonable,
unlawful,erroneous,or not in conformity with the
law.