20220211IPC to Staff 1-34.pdf

LISA D. NORDSTROM
Lead Counsel
[e-mail]
February 11, 2022
Jan Noriyuki, Secretary
Idaho Public Utilities Commission
11331 W. Chinden Boulevard
Building 8, Suite 201-A
Boise, Idaho 83714
Re: Case No. IPC-E-21-40
Application to Expand Optional Customer Clean Energy Offerings Through
the Clean Energy Your Way Program
Dear Ms. Noriyuki:
Attached for electronic filing, pursuant to Order No. 35058, is Idaho Power Company’s
Response to First Production Request of the Commission Staff in the above entitled
matter.
If you have any questions about the attached documents, please do not hesitate to
contact me.
Sincerely,
Lisa D. Nordstrom
LDN:sg
Enclosure
RECEIVED
2022 FEB 11 PM 4:15
IDAHO PUBLIC
UTILITIES COMMISSION
IDAHO POWER COMPANY’S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 1
LISA D. NORDSTROM (ISB No. 5733)
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
[e-mail]

Attorney for Idaho Power Company

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF IDAHO POWER
COMPANY’S APPLICATION TO EXPAND
OPTIONAL CUSTOMER CLEAN
ENERGY OFFERINGS THROUGH THE
CLEAN ENERGY YOUR WAY
PROGRAM.
)
)
)
)
)
)
)

CASE NO. IPC-E-21-40

IDAHO POWER COMPANY’S
RESPONSE TO FIRST
PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO
POWER COMPANY

COMES NOW, Idaho Power Company (“Idaho Power” or “Company”), and in
response to First Production Request of the Commission Staff (“IPUC or Commission”)
dated January 21, 2022, herewith submits the following information:
IDAHO POWER COMPANY’S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 2
REQUEST FOR PRODUCTION NO. 1: Regarding the Community Solar Pilot
Program approved by Order No. 33638 in Case No. IPC-E-16-14 and subsequently
suspended by Order No. 34317, please answer the following:
a. The Community Solar Program was suspended due to insufficient enrollment.
Please describe how the Company will receive sufficient participation for the
Subscription options?
b. Please describe how the “high premium cost compared to regular rates” issue
from the Community Solar Pilot Program will be resolved in the new
Subscription and Construction options?
c. Please describe how the “concerns about the ability to achieve a return on
investment” issue from the Community Solar Pilot Program will be resolved in
the Subscription and Construction options?
RESPONSE TO REQUEST FOR PRODUCTION NO. 1:
a. Idaho Power believes it can achieve sufficient participation in the Subscription
for two primary reasons: 1) More customers are interested in or require clean
energy options than five years ago when the Community Solar Program was
developed, and 2) The cost of participation will be more attractive to
customers than it was with the Community Solar Program. While Idaho Power
has not identified a resource to support the Subscription, the cost of
renewables has fallen significantly in the past few years, and the Subscription
offering will allow economies of scale in resource selection and pricing—a 50-
megawatt (MW) resource will likely be offered at lower cost than the 500
kilowatt (kW) system proposed for the Community Solar Program. Another
IDAHO POWER COMPANY’S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 3
important distinction is that the Subscription offering will not require an up-
front investment like the Community Solar Program. The elimination of an up-
front cost removes the most significant cost barrier identified by customers in
the Community Solar surveys, as referenced in the Company’s application.
b. As noted above, the proposed Subscription offering will have a different cost
structure than the Community Solar Program. Most notably, the Subscription
will not require an up-front investment that made Community Solar financially
unappealing for many customers.
The structure of the Construction offering, and the Community Solar Program
are not comparable. In the Construction offering, customers will self-elect into
a tailored agreement with the Company. The tolerance for a price premium
will vary by individual customer and their specific Construction arrangement.
However, the Construction arrangement filing of Brisbie, LLC in IPC-E-21-42
indicates that the Construction offering is a financially workable arrangement
for large energy users.
c. Based on survey questions and responses from customers about the
challenges of the Community Solar Program, the Company believes that
“concerns about the ability to achieve a return on investment” with the
Community Solar Program were in reference to the required up-front
investment from the customer. As noted above, the Subscription offering will
not have an up-front investment. Similarly, Construction arrangements are
unlikely to involve up-front investment for resource costs for the reasons
explained in the response to Staff’s Production Request No. 34.
IDAHO POWER COMPANY’S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 4
The response to this Request is sponsored by Alison Williams, Regulatory Policy
and Strategy Advisor, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 5
REQUEST FOR PRODUCTION NO. 2: In the Application at 8, the Company
states “Idaho Power will record unsold amounts as a charge to the Company’s
Operation and Maintenance [“O&M”] expense.” Please confirm the O&M expense
would be for the Clean Energy Your Way program. If not, please explain.
RESPONSE TO REQUEST FOR PRODUCTION NO. 2: Confirmed. The
Operation and Maintenance (O&M) expense would be for the Clean Energy Your Way
program – Flexible offering.
The response to this Request is sponsored by Tami White, Budget and Revenue
Manager, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 6
REQUEST FOR PRODUCTION NO. 3: The Company’s Application at 12 states
“based on customer interest, Idaho Power believes it can fully subscribe the offering as
described above with a 50-100 megawatt resource” for the Subscription option. Please
describe how the Company is determining the approximate size of 50-100 megawatt
resource based on customer interest? How will the Company determine the final size of
the resource for the Subscription option?
RESPONSE TO REQUEST FOR PRODUCTION NO. 3: The size estimate of 50
– 100 MW for the Subscription was based on conversations with Idaho Power’s
customers in the development of the proposed offering. Idaho Power has received
interest in the Subscription offering from many customers, with more than 10 customers
that would each require a solar resource of approximately 5 MW to offset their full
annual energy use. Together, these customers alone would fully subscribe a 50 MW
resource. Idaho Power also assumes that residential customers would absorb from 5 to
10 MW of the program—an amount informed by the list of customers interested in the
Community Solar Program and the Green Power Program.
The ultimate resource size for the Subscription offering will be based on a variety
of factors, including statements of interest from customers and resource economies of
scale—for example, it may be lower cost on a per-unit basis to develop a resource of
100 MW than 50 MW.
As noted in Idaho Power’s application, the Company proposes dispatching any
unsubscribed portions of energy from the Subscription resource to Idaho Power’s
system.

IDAHO POWER COMPANY’S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 7
The response to this Request is sponsored by Alison Williams, Regulatory Policy
and Strategy Advisor, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 8
REQUEST FOR PRODUCTION NO. 4: For the proposed Clean Energy Your
Way Subscription option, please answer the following:
a. Will customers have any input for the resource selected for this option?
b. When will the Company begin signing up customers for the program?
c. At what percentage of participation and enrollments for the program would the
Company deem sufficient to operate the program?
d. Will residential customers be able to select term lengths longer than month-
to-month?
RESPONSE TO REQUEST FOR PRODUCTION NO. 4:
a. Yes. As proposed by the Company in its application, the second phase of the
two-phase filing process for the Subscription would offer customers and other
interested parties an opportunity to provide input on the resource for the
offering.
b. Idaho Power will not begin signing up customers for the Subscription offering
until it is approved by the Commission.
c. Based on expressed customers interest, the Company believes it can reach
full participation in the Subscription offering. However, the Company also
proposes dispatching any unsubscribed portions of energy to its system to
benefit all customers. The Company has not yet determined a threshold of
subscribers that would be necessary to deem the program sufficient to
operate. Such a determination will be made during the second phase of the
Subscription filing when key elements of the program, such as resource
pricing and resource size, will be known.
IDAHO POWER COMPANY’S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 9
d. Yes. Residential customers will be able to subscribe to term lengths longer
than month-to-month.
The response to this Request is sponsored by Alison Williams, Regulatory Policy
and Strategy Advisor, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 10
REQUEST FOR PRODUCTION NO. 5: The proposed Construction and
Subscription options both implement a two-phase approach with the second phase
requiring Commission approval. Why does the Company not include proposed tariff
language in its Application for the Subscription option when the Construction offering
includes tariff language in this filing? If available, please provide a copy of the proposed
Clean Energy Your Way – Subscription option Tariff.
RESPONSE TO REQUEST FOR PRODUCTION NO. 5: Under the Company’s
proposal, the Construction offering will be an active component of Tariff Schedule 62
upon Commission approval, while the Subscription offering would not become available
under this current phase of the process. The rationale for this approach is that key
components that are necessary for the Subscription-related tariff language are not
known yet—primarily, participant costs and credits. In lieu of draft tariff language, the
Company included a description of Subscription offering parameters as Exhibit 1 to Ms.
Williams direct filed testimony, describing many of the proposed components of the
Subscription. The Company expects these elements, once finalized and approved by
the Commission in a future case or a second phase of this case, will be codified within
Tariff Schedule 62.
The response to this Request is sponsored by Alison Williams, Regulatory Policy
and Strategy Advisor, Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 11
REQUEST FOR PRODUCTION NO. 6: What is the Company’s intent for
reporting on each option for the Clean Energy Your Way program?
RESPONSE TO REQUEST FOR PRODUCTION NO. 6: The Company envisions
maintaining the biennial reporting requirement for the current Green Power Program as
directed by the Commission in Order No. 33570. Under the Clean Energy Your Way –
Flexible name, the Company expects to expand reporting to include sales information
regarding the Limited Bulk Purchase Option.
For reference, in Order No. 33570 the Commission directed the Company to
submit a biennial Green Energy Prudency Report, which includes the following
information:
 Customer count under each participation option, by schedule
 Monthly RECs purchased
 Monthly revenue and expenses for Schedule 62
 Updated costs associated with re-certifying the RECs prior to retirement
 Summary of marketing activities and expenses
 Solar 4R Schools expenses
 Percentage of RECs purchased within Idaho Power's service territory
 Monthly funds transferred to the Power Cost Adjustment (PCA) from
Idaho Power-owned REC purchases

For the Subscription offering, the Company believes it would be beneficial to
provide biennial reports with relevant metrics and data, such as customer count under
each subscription term and monthly revenue and expenses.
The Company does not envision a reporting requirement associated with the
Construction offering, as each Construction arrangement will be individually designed
and approved by the Commission. Further, given that each arrangement will require a
customer to be committed to a resource(s) for an extended term length, none of the
reporting requirements noted above are relevant to Construction arrangements.
IDAHO POWER COMPANY’S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 12
The response to this Request is sponsored by Alison Williams, Regulatory Policy
and Strategy Advisor, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 13
REQUEST FOR PRODUCTION NO. 7: Please describe how the Company will
account for the proposed Subscription and Construction options in the Integrated
Resource Plan.
RESPONSE TO REQUEST FOR PRODUCTION NO. 7: The dedicated
resource for the Subscription offering will only be included in the Company’s Integrated
Resource Plan (IRP) once the offering is approved by the Commission. At such a time,
the Company would model the resource as a base resource (as opposed to an optional
resource that could be selected by the AURORA model). The capacity contribution of
the resource would be determined based on the expected online date using the Electric
Load Carrying Capability (ELCC) method.
For the Construction offering, the resource(s) for individual customer
arrangements will be incorporated into the IRP once an agreement is signed between
the Company and the customer(s). Similar to the Subscription offering resource,
Construction-related resources for customers will be treated as base resource(s).
Construction resource(s) will also be modeled at no cost because the customer(s) will
have agreed to pay for the entire cost of the resource(s). The capacity value of the
resource(s) will also be identified based on expected online date of each resource using
the ELCC method. The Brisbie, LLC special contract application (IPC-E-21-42) is the
first example of Construction offering resources for a customer incorporated into the
IRP.
The response to this Request is sponsored by Alison Williams, Regulatory Policy
and Strategy Advisor, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 14
REQUEST FOR PRODUCTION NO. 8: Please answer the following about
Marketing expenses:
a. Please provide the annual estimated cost of marketing for Clean Energy Your
Way Program broken down by each option (Flexible, Subscription,
Construction).
b. Does the Company plan to cap marketing expenses for the program? If so, at
what percentage or dollar value does the Company plan to Cap expenses.
c. Does the Company plan to cap marketing expenses for each option (Flexible,
Subscription, and Construction) in the program? If so, at what percentage or
dollar value does the Company plan to Cap expenses.
d. Will the Company report marketing expenses for the entire program or
individually for each option (Flexible, Subscription, and Construction)?
RESPONSE TO REQUEST FOR PRODUCTION NO. 8:
a. Clean Energy Your Way Flexible: The Flexible offering, which is essentially a
rebrand of the Company’s current Green Power Program, will continue the same
marketing plan that exists today. The Company may use up to 15 percent of
program funds to support marketing. The annual budget for the Company’s
current Green Power Program is approximately $30,000 for marketing and
participant engagement and retention tactics.
Clean Energy Your Way Subscription: While the Subscription offering will not
be marketed until it is approved by the Commission, Idaho Power envisions an
annual marketing budget of approximately $30,000, consistent with the marketing
budget for the current Green Power Program. The Company believes it is logical
IDAHO POWER COMPANY’S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 15
to estimate a budget for the Subscription based on what has historically been
effective for the Green Power Program. Upon approval, marketing will commence
to attract interest in the program with the ultimate objective of fully subscribing
the program. Once the Subscription is full or nearly full, the need for marketing
will diminish significantly. However, a certain amount of turnover is expected in
the Subscription, as month-to-month and five-year term customers may decide
not to renew their subscriptions. The Company will continue to market the
program in a more limited fashion to account for this expected turnover.
The Company has proposed that administration and marketing for the
Subscription be included as a component of the participant charge. Due to the
nature of the upfront marketing expenses prior to the collection of administration
and marketing fees, the timing of marketing expenses and revenues collected
may not align.
Clean Energy Your Way Construction: The Construction offering is intended to
be available for customers specifically seeking a tailored clean energy option;
therefore, no incremental marketing expenses are anticipated.
b. Yes. As noted above, the Company will continue to market Clean Energy Your
Way – Flexible at the annual budgeted amount of $30,000. Similarly, the
Company envisions an annual marketing budget for the Subscription of $30,000,
which is expected to diminish as the program fills. The Construction offering is
not anticipated to have any incremental marketing expenses. In total, Idaho
Power plans to cap marketing of the entire Clean Energy Your Way program at
$60,000 annually.
IDAHO POWER COMPANY’S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 16
c. See response to part “b” above.
d. The Company will continue to report expenses for the Flexible offering as
currently prescribed for the Green Power Program Biennial Report. Reporting
aspects for the Subscription offering will be contemplated in the second phase of
the filing request, as described in Ms. Williams’s testimony on page 36, but the
Company believes it may be beneficial to provide biennial reporting on relevant
metrics, as noted in response to Staff’s Production Request No. 6. No marketing
expense reporting is anticipated for the Construction offering.
The response to this Request is sponsored by Alison Williams, Regulatory Policy
and Strategy Advisor, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 17
REQUEST FOR PRODUCTION NO. 9: For Option 3, the Large Purchase
Option for the Flexible offering in Schedule 62, please provide additional details about
this option including the following:
a. For each year from 2016-2021, please provide the number of customers
enrolled in the Green Power Program and the amount in MWh of yearly
purchases for each customer that would meet the 750 MWh or more per year
large purchase option.
b. Will customers have the immediate option of participating in this option?
c. Will customers need to nominate how many MWh per year they plan to
purchase to participate in this option?
d. Will tailored options be billed monthly, yearly, or other?
e. What type of communication will occur with the Commission for the tailored
agreements?
f. What benefits will a customer have by participating in this option versus the
Subscription offering?
RESPONSE TO REQUEST FOR PRODUCTION NO. 9:
a. From 2016 through 2021, there were three Green Power Program business
participants who met the eligibility requirements of the Large Purchase
Option. The three customers, respectively, purchased Renewable Energy
Certificates (RECs) equal to 2,298 Megawatt-hours (MWh), 1,332 MWh, and
1,306 MWh annually. However, there are fundamental differences between
business customers interested in the Green Power Program and business
customers interested in the Large Purchase Option.
IDAHO POWER COMPANY’S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 18
Customers interested in the Large Purchase Option typically want RECs at a
competitive price, without extra benefits and added costs, while participation
in the Green Power Program includes additional costs and benefits.
The Large Purchase Option was first offered following the 2016
modifications to Schedule 62; however, interest in the option remained low
until 2018. Since 2018, more than 60 business customers have sought
information on the Large Purchase Option as they seek solutions to achieve
their sustainability targets. As of February 2022, seven (7) businesses are
purchasing Idaho Power-owned RECs through this Large Purchase Option.
Company-owned RECs1 are sold out for 2022, so Idaho Power is unable to
support additional customer inquiries for large volume purchase of RECs at
this time or until the REC third-party procurement proposed by the Company
is approved by the Commission.
b. Under the current Large Purchase Option, customers who meet the eligibility
requirements can purchase any Company-owned RECs available. Once
Idaho Power has sold its REC supply, the Company is no longer able to
provide this option to customer. Should Idaho Power be approved to source
RECs from third-party REC sellers on behalf of customers, Idaho Power could
work with customers to meet their needs regardless of the availability of
Company-owned RECs.
c. Yes. In order to participate in this offering, customer’s total energy usage for
current and/or future years will be estimated. Alternatively, the customer can

1 RECs generated by Company-owned generation resources or Company-owned through contract terms
of a Power Purchase Agreement.
IDAHO POWER COMPANY’S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 19
designate another amount as long as the minimum is 750 MWh per year. The
customer will sign an agreement to purchase the agreed-upon MWh of RECs.
d. The current Large Purchase Option requires payment annually. If RECs are
for the current calendar year, payment is due upon execution of a purchase
and sale agreement. If RECs are for a future year, payment is due prior to
that commencement of that year. Other payment arrangements (quarterly,
biannually, or after the year ends) may be considered with a credit review.
Payment terms for third-party sourced RECs will be dependent on the third-
party seller’s payment requirements.
e. In 2019, Idaho Power consulted with Commission staff prior to executing the
first REC sales agreement with a business customer. As these contracts are
consistent with the Company’s REC Management Plan, the Company has not
provided subsequent agreements to Commission Staff. If desired, Idaho
Power can confidentially share agreement copies with the Commission.
f. The Clean Energy Your Way program was designed to offer a variety of clean
energy options for customers. There are a number of reasons why RECs may
be a preferred clean energy option for customers, including:
 If a customer’s energy use and REC needs are higher than estimated,
the customer may “true-up” and purchase RECs through the Flexible
offering to ensure 100 percent clean energy attributes in comparison to
the customer’s annual load requirements. Currently, a “true-up” is only
available to customers if Company-owned RECs are available.

IDAHO POWER COMPANY’S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 20
 For business customers, the minimum term length for the Subscription
offering is five (5) years. The minimum term for the Large Purchase
Option is one (1) year.
 Businesses with leased office space may not have an Idaho Power
account, even though their business is located in Idaho Power’s
service area. As a result, these types of businesses will not be eligible
for the Subscription but can participate in the Flexible offering,
assuming they meet eligibility requirements. In such instances, the
Company can provide alternative billing options outside of a standard
electric bill.
 The Subscription will have limited availability based on the size of the
resource. The Large Purchase Option can supply Idaho Power owned-
RECs or, if approved, can connect customers with third-party sellers to
fulfill their clean energy needs.
Finally, it should be noted that customers may simultaneously
participate in both the Flexible and Subscription offerings.
The response to this Request is sponsored by Theresa Drake, Customer
Relations and Energy Efficiency Senior Manager, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 21
REQUEST FOR PRODUCTION NO. 10: Schedule 62, Attachment 1, states
“participants will designate one of two billing options upon enrollment;” however, three
options are provided. Which two billing options will participants be able to participate
in?
RESPONSE TO REQUEST FOR PRODUCTION NO. 10: Staff is correct, there
are three options a customer may participate in under the Clean Energy Your Way –
Flexible option. The Company inadvertently missed the numbering change in the
proposed tariff language. Subsequent to a Commission order in this matter, the
Company will submit a compliance filing to correct the oversight and will incorporate any
other modifications as directed by the Commission.
The response to this Request is sponsored by Connie Aschenbrenner, Rate
Design Senior Manager, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 22
REQUEST FOR PRODUCTION NO. 11: Similar to Exhibit No. 2 in the Direct
Testimony of Allison Williams, please provide a mock customer bill for the Construction
option.
RESPONSE TO REQUEST FOR PRODUCTION NO. 11: The Company did not
provide a mock customer bill for the Construction option because there will not be a
standard bill format for Construction arrangements. Each Construction arrangement will
be individually negotiated and, as such, may include unique billing elements or
structure. Unlike the standard billing envisioned for the Subscription offering,
Construction arrangements are expected to be billed manually by Idaho Power’s
Finance Department, similar to the existing billing practices for Special Contracts.
The response to this Request is sponsored by Matisse Weigel, ERP Applications
Senior Manager, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 23
REQUEST FOR PRODUCTION NO. 12: Similar to Exhibit No. 2 in the Direct
Testimony of Allison Williams, please provide a mock customer bill for a tailored
agreement for Option 3: Large Purchase Option under the Flexible option.
RESPONSE TO REQUEST FOR PRODUCTION NO. 12: As discussed in the
Company’s response to Staff Request No. 9d, the current Large Purchase Option
requires payment annually and is billed manually by Idaho Power’s Finance
Department. If RECs purchased are for the current calendar year, payment is due upon
execution of a purchase and sale agreement.
The response to this Request is sponsored by Matisse Weigel, ERP Applications
Senior Manager, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 24
REQUEST FOR PRODUCTION NO. 13: In the Direct Testimony of Allison
Williams, page 50 states “each construction arrangement will include a no-harm
revenue requirement analysis to ensure that non-participants are held harmless.” When
does the Company plan to conduct this analysis and how often will it occur? Will the
Company do the same analysis for the Subscription option?
RESPONSE TO REQUEST FOR PRODUCTION NO. 13: The Company will
conduct a single no-harm analysis of each Construction arrangement as part of the filing
for approval of that arrangement with the Commission.
For the Subscription, the Company proposes to include a single no-harm
analysis to accompany the Company’s second filing related to the Subscription to
demonstrate that the identified resource for the offering will hold harmless non-
subscribers.
The response to this Request is sponsored by Alison Williams, Regulatory Policy
and Strategy Advisor, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 25
REQUEST FOR PRODUCTION NO. 14: Please provide all notes and
workpapers used in development of proposed updates to Schedule 62 in Excel format,
with formulae intact.
RESPONSE TO REQUEST FOR PRODUCTION NO. 14: The guiding structure
of the updates to Schedule 62 were presented to Commission Staff at a workshop on
July 7, 2021. The presentation is provided as an attachment to this response.
The response to this Request is sponsored by Alison Williams, Regulatory Policy
and Strategy Advisor, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 26
REQUEST FOR PRODUCTION NO. 15: Does Jackpot Solar qualify for the
proposed Clean Energy Your Way Subscription option or the proposed Clean Energy
Your Way Construction option?
RESPONSE TO REQUEST FOR PRODUCTION NO. 15: No. Prospective
participants in the Subscription and Construction offerings are seeking “additionality” or
“net new” resources to meet their clean energy objectives. The Company has included
the Jackpot Solar resource in its Integrated Resource Plan since 2019. While not yet
constructed, Jackpot Solar does not meet the definition of a “net new” resource, and
thus will not meet the needs of Idaho Power customers who have expressed a desire
for expanded clean energy offerings.
The response to this Request is sponsored by Alison Williams, Regulatory Policy
and Strategy Advisor, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 27
REQUEST FOR PRODUCTION NO. 16: Are there resources that are
immediately available for the proposed Clean Energy Your Way Subscription option
and/or proposed Clean Energy Your Way Construction option. If so, please provide a
list
RESPONSE TO REQUEST FOR PRODUCTION NO. 16: For both the
Subscription and Construction offerings, the Company may consider projects that bid
into Idaho Power’s recent Requests for Proposals. The Company may also consider
projects in any future RFPs as options for the Subscription and Construction offerings.
The response to this Request is sponsored by Alison Williams, Regulatory Policy
and Strategy Advisor, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 28
REQUEST FOR PRODUCTION NO. 17: If no resources are immediately
available for proposed Schedule 62, please provide a timeline of when such resources
that qualify will be determined.
RESPONSE TO REQUEST FOR PRODUCTION NO. 17: Please see the
Company’s response to Staff’s Production Request No. 16.
The response to this Request is sponsored by Alison Williams, Regulatory Policy
and Strategy Advisor, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 29
REQUEST FOR PRODUCTION NO. 18: What is the upfront cost to customers
for the proposed Clean Energy Your Way Subscription option and the proposed Clean
Energy Your Way Construction option?
RESPONSE TO REQUEST FOR PRODUCTION NO. 18: The Company’s
proposed pricing does not include an upfront cost component to participate. One of the
main takeaways from the Idaho Community Solar Pilot Program was cost and recovery
of initial investment as barriers to participation in the program. The Company’s
proposed offering reflects stakeholder feedback on this issue.
The response to this Request is sponsored by Alison Williams, Regulatory Policy
and Strategy Advisor, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 30
REQUEST FOR PRODUCTION NO. 19: Please provide the entire accounting
treatment for the proposed Clean Energy Your Way Subscription option including, but
not limited to, deferral account numbers, expected monthly journal entries of customer
participant charges, the Company’s operating expenses of such Subscription Option,
cost to procure the resources for such Subscription option, the financing costs to the
Company to procure a resource for such Subscription Option and all other relevant
costs to maintain the proposed Schedule 62 Clean Energy Your Way Subscription
option? Please provide workpapers in Excel format to support and justify your answer.
RESPONSE TO REQUEST FOR PRODUCTION NO. 19: All costs, financial
analysis, program accounting treatment, customer charges/credits, and customer
agreements would be determined in the second filing, as these details are not possible
to establish absent a known resource. As described in the Application filed in this case,
Idaho Power envisions a two-phase process for the Clean Energy Your Way -
Subscription option. Idaho Power has filed phase one which seeks approval of the
foundational concepts of program design and structure. Upon Commission approval to
offer Clean Energy Your Way – Subscription, Idaho Power would seek a Subscription-
dedicated resource. Once a resource is identified, Idaho Power would propose specific
subscription pricing under the structure approved in phase one and return to the
Commission for approval of those program elements and associated tariff changes. The
main purpose of the first phase of review addressed in this case is to seek approval or
acknowledgement from the Commission for the general framework for a future Clean
Energy Your Way - Subscription offering.
IDAHO POWER COMPANY’S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 31
The Company is seeking this initial determination to provide a reasonable level of
assurance that once a resource is procured for the program offering, the Company can
bring a recommendation to implement the program without major unanticipated
modification or cost disallowances. To be clear, the Company is not looking for
preapproval of ratemaking or prudence, just acknowledgement that the proposed Clean
Energy Your Way - Subscription offering is reasonably pursued under the proposed
framework.
The response to this Request is sponsored by Tami White, Budget and Revenue
Manager, Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 32
REQUEST FOR PRODUCTION NO. 20: Please provide the accounting
treatment for the proposed Clean Energy Your Way Construction option including, but
not limited to, monthly journal entries of customer participant charges, Company’s
operating expenses of such Construction option, cost to procure the resources for such
Construction option, the financing costs to the Company to procure a resource for such
Construction option and all other relevant costs to maintain the proposed Schedule 62
Clean Energy Your Way Construction option? Please provide workpapers in Excel
format to support and justify your answer.
RESPONSE TO REQUEST FOR PRODUCTION NO. 20: As described in the
Application filed in this case, Idaho Power requests approval from the Commission to
offer the Construction option under a broad framework with consistent mechanics and
pricing structure. Idaho Power envisions that the rates and other charges/credits
resulting from each Construction arrangement would be approved by the Commission
on a case-by-case basis. Once a resource is identified, Idaho Power would propose
specific pricing under the terms of a Construction agreement and would seek
Commission approval of the agreement.
Brisbie, LLC is the first example of a Clean Energy Your Way – Construction
arrangement. Accounting treatment specific to that agreement is being addressed in
IPC-E-21-42.
The response to this Request is sponsored by Tami White, Budget and Revenue
Manager, Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 33
REQUEST FOR PRODUCTION NO. 21: If a waiver is granted for the Oregon
Public Utilities Commission Procurement process, what are the financial savings to
participants in the proposed Schedule 62 Clean Energy Your Way Subscription Option
and proposed Schedule 62 Clean Energy Your Way Construction Option? Please
provide workpapers in Excel format to support your answer.
RESPONSE TO REQUEST FOR PRODUCTION NO. 21: The waiver request is
intended to reduce the lengthy resource procurement process timeline that currently
exists under the Oregon Public Utilities Commission (OPUC) Resource Procurement
rules. Any savings that might be achieved from a waiver would result from reduced
administrative costs, not from the resource itself. Idaho Power will still undertake a
competitive process to identify resources for the Subscription and Construction
offerings. That process, however, will not involve all of the OPUC requirements, which
Idaho Power believes can delay the effective and efficient selection of resources.
The response to this Request is sponsored by Alison Williams, Regulatory Policy
and Strategy Advisor, Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 34
REQUEST FOR PRODUCTION NO. 22: When will customers who subscribe for
the proposed Clean Energy Your Way Subscription option know what the costs will be
to participate?
RESPONSE TO REQUEST FOR PRODUCTION NO. 22: The Company does
not plan to enroll customers in the Subscription prior to Commission approval of the
offering and the tariff. Therefore, customers will know upon enrollment in the
Subscription offering the costs and benefits of participating.
The response to this Request is sponsored by Alison Williams, Regulatory Policy
and Strategy Advisor, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 35
REQUEST FOR PRODUCTION NO. 23: Will the Company file an updated
revenue requirement for the proposed Clean Energy Your Way – Subscription option
when resource(s) are known?
RESPONSE TO REQUEST FOR PRODUCTION NO. 23: The Company has not
yet identified a resource for the Subscription offering. Upon approval of Idaho Power’s
current application, the Company will begin considering resources for the Subscription.
That resource could be procured via Power Purchase Agreement (PPA). Under this
structure, revenue requirement would not be updated, as the cost of the PPA would be
captured in the Subscription price. Should Idaho Power identify a Company-owned
resource option, then an updated revenue requirement would be provided.
The response to this Request is sponsored by Matt Larkin, Revenue
Requirement Senior Manager, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 36
REQUEST FOR PRODUCTION NO. 24: What are the expected costs to
operate the entire proposed Schedule 62 Clean Energy Your Way? Please provide
workpapers in Excel format supporting your answer.
RESPONSE TO REQUEST FOR PRODUCTION NO. 24: Idaho Power does not
anticipate additional personnel costs to operate the Clean Energy Your Way program.
Costs will be limited to the existing costs to operate the Green Power Program (the
future Clean Energy Your Way – Flexible offering) and future administrative costs—for
marketing and advertising—in the Subscription offering. Please refer to the Company’s
response to Staff’s Production Request No. 8 for a more detailed discussion of
Subscription-specific marketing costs.
The response to this Request is sponsored by Theresa Drake, Customer
Relations and Energy Efficiency Senior Manager, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 37
REQUEST FOR PRODUCTION NO. 25: How will the Company hold non-
participants harmless when Schedule 62 costs exceed revenues?
RESPONSE TO REQUEST FOR PRODUCTION NO. 25: The Green Power
Program—to become Clean Energy Your Way – Flexible—has a demonstrated track
record of program costs being covered by program participants.
For both the Subscription and Construction offerings, the Company will not put
applications for approval before the Commission unless the no-harm analysis for each
offering or individual arrangement demonstrates no unreasonable cost shift to existing
Idaho Power customers. Idaho Power does not anticipate costs exceeding revenues.
The Construction offering by design, will include all the costs of the dedicated
resource(s). The Subscription offering will be designed to cover the incremental cost of
the resource and administrative expenses. In the event there is unsubscribed energy
under the Subscription, that energy will be dispatched to the system to the benefit of all
Idaho Power’s customers and included in broader customer rates or the PCA.
The response to this Request is sponsored by Alison Williams, Regulatory Policy
and Strategy Advisor, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 38
REQUEST FOR PRODUCTION NO. 26: Please provide the accounting
treatment and impact on non-participants when Schedule 62 revenues exceed costs.
RESPONSE TO REQUEST FOR PRODUCTION NO. 26:
Flexible – Program revenues will not exceed costs because Idaho Power will not sell
RECs in advance of acquiring them.
Subscription - Please refer to Idaho Power’s response to Production Request No. 19.
Program accounting treatment would be determined in the second filing, as these
details are not possible to establish absent a known resource. Idaho Power does not
expect revenues to exceed costs because program participants will be paying the costs
of the program.
Construction - Please refer to Idaho Power’s response to Production Request No. 20.
Once a resource is identified, Idaho Power would propose specific pricing under the
terms of a construction agreement and would seek Commission approval of the
agreement. Accounting treatment would be determined at that time, as these details are
not possible to establish absent a known resource and specific customer arrangement.
Idaho Power does not expect revenues to exceed costs because Construction
customers will be paying for the full cost of resources.
The response to this Request is sponsored by Tami White, Budget and Revenue
Manager, Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 39
REQUEST FOR PRODUCTION NO. 27: Please provide the accounting
treatment and an explanation of how the Company will hold non-participants harmless
from those that participate in the proposed Clean Energy Your Way Construction
option?
RESPONSE TO REQUEST FOR PRODUCTION NO. 27: Regarding accounting
treatment, please refer to Idaho Power’s response to Production Request No. 20.
The Construction offering is designed so that non-participating customers are
held harmless. Each Construction arrangement will include a no-harm financial analysis
to demonstrate that all costs are borne by the Construction customers and do not shift
costs to non-participants.
In IPC-E-21-42, Company witness Pawel Goralski describes on pages 21-23 of
his testimony how the no-harm analysis was conducted for Brisbie, LLC, the first
proposed Clean Energy Your Way – Construction customer: “Idaho Power completed a
present-value revenue requirement analysis for two portfolios [one with Brisbie
resources and another without] and evaluated the difference in cost between the
portfolios to ensure any unreasonable cost shift to existing Idaho Power customers is
avoided.”
The response to this Request is sponsored by Tami White, Budget and Revenue
Manager, Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 40
REQUEST FOR PRODUCTION NO. 28: For the Subscription Offering, please
provide a detailed explanation through examples using assumed values for the different
components of the rate design and by using a likely proxy resource, how the Company
will ensure non-participating customers are held harmless for two scenarios: 1) the
resource is fully subscribed; and 2) the resource is not fully subscribed, requiring energy
from the resource being passed through the PCA. Please include the following for the
two scenarios.
a. The calculations for the program charge.
b. The calculation for the program credit.
c. The amounts included in the participant’s bill.
d. The items and amounts that will be passed through the PCA using the new
PCA format.
RESPONSE TO REQUEST FOR PRODUCTION NO. 28: The Company
recognizes that Staff is seeking to understand the potential costs, credits, and financial
impact on Subscription participants. Providing hypothetical calculations at this stage
would require a series of assumptions and might not yield the insight that Staff is
seeking. As a result, the Company has provided responses below consistent with its
Application for approval of the broad framework of the Subscription. Should Staff
believe that early-stage hypothetical numbers are necessary to understand the
Subscription framework, Idaho Power can work to provide such an analysis.

IDAHO POWER COMPANY’S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 41
a. As described in Exhibit 1 of Ms. Williams testimony, the Program Charge will
include the following components:
 Resource Cost ($/kWh)
 Resource-specific Integration Charges
 Program Administration and Marketing
 Short-Term Adjustment Charge
b. The calculation of the credit has not yet been determined, but it will include an
energy and capacity component and is not to exceed the program charge.
c. The Company provided a mock customer bill as Exhibit 2 to the testimony of
Ms. Williams. The Schedule 62 – Subscription rates are in addition to all
charges under the Customer’s existing Electric Service Schedule. A
participant’s electric bill will include five new line items: (1) the name of the
program (Clean Energy Your Way – Subscription), (2) subscriber amount (in
kWh), (3) subscriber charge amount, (4) subscriber credit amount, and (5) net
cost (subscriber charge less subscriber credit).
d. The bill credits for subscribed energy, as well as any unsubscribed energy,
will be included in broader customer rates and/or the PCA mechanism.
The response to this Request is sponsored by Alison Williams, Regulatory Policy
and Strategy Advisor, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 42
REQUEST FOR PRODUCTION NO. 29: Please describe any market research
the Company has performed to determine the price range customers are willing to pay
for the Subscription offering. If a price range has been determined, please explain if
current available resources are able to meet the price range.
RESPONSE TO REQUEST FOR PRODUCTION NO. 29: In 2019, the Company
conducted a survey of customers and asked the following questions with the resulting
responses:
 Do you support Idaho Power’s clean-energy goal? 89.6%
 How much more are you willing to pay?
o 20% more: 11.5%
o 10% more: 18.9%
o 5% more: 27.7%
While this survey was originally performed as the Company developed Clean Today.
Cleaner Tomorrow.®, the results provide insight into the pricing of clean energy
programs like the Subscription offering.
In addition, over the course of the past two years, the Company has engaged in
individual conversations with customers across all classes to better understand how
pricing would influence adoption of clean energy programs like the Subscription offering.
While unofficial, it is fair to summarize that many customers – residential, commercial,
and industrial – are sensitive to pricing of proposed offerings but are also willing to pay
a premium. Pricing for the Subscription offering has not been determined because doing
so will first require identification of a resource to serve the Subscription.
IDAHO POWER COMPANY’S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 43
As described by Company witness Alison Williams in her testimony on pages 32-
33: “the Company proposes a two-phase process for the Subscription offering – an
initial phase (the current request) to offer a voluntary subscription-based program, and
the secondary phase that will launch upon approval of the first…..the Subscription
would not be available to participants until the conclusion of a separate and subsequent
proceeding addressing the resource procurement, resource cost, cost allocation, and
any other required regulatory accounting and necessary cost recovery mechanisms.”
Ms. Williams’s testimony further articulates on page 33-34: “In Phase II, and
upon Commission approval to offer Clean Energy Your Way – Subscription, Idaho
Power would seek a Subscription-dedicated resources. Resource selection would
involve determining the resource type, size, and location. Once a resource is identified,
Idaho Power would propose specific subscription pricing under the structure approved
in Phase I and return to the Commission for approval of those program elements and
associated tariff changes.”
The response to this Request is sponsored by Megan Ronk, Economic
Development & Innovation Director, Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 44
REQUEST FOR PRODUCTION NO. 30: For the Construction Offering, please
provide a detailed explanation through examples using assumed values for the different
components of the rate design and by using a likely proxy resource, how the Company
will ensure non-participating customers are held harmless. Please provide the
calculations for the following hourly situations relative to paragraph 39 of the Application
by including the calculations for the different rate components and the items and
amounts that will be passed through the PCA:
a. When the renewable resource is not generating, and the customer is
consuming energy.
b. When the renewable resource is generating, but it is generating less than the
amount the customer is consuming.
c. When the renewable resource is generating, but it is generating more than
the amount the customer is consuming.
d. When the renewable resource is generating, and the customer is not
consuming energy.
RESPONSE TO REQUEST FOR PRODUCTION NO. 30: Each Construction
arrangement will be developed individually with participating customer(s). As a result,
each Construction arrangement will differ by resource size, type, the customer’s
underlying energy requirements, and the Construction-specific charges/credits may
differ. Similarly, each Construction arrangement will have its own no-harm analysis,
meaning that the creation of one with “assumed values” may not provide meaningful
insight into the way individual no-harm analyses will be developed. For a description of
IDAHO POWER COMPANY’S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 45
the no-harm analysis approach used for Brisbie, LLC, in IPC-E-21-42, please refer to
the response to Staff’s Production Request No. 27.
Broadly, the Construction offering will follow a shared construct, as explained in
paragraph 39 of the Application. Below, the Company provides an illustration to assist in
understanding the foundational cost and credit streams of Construction arrangements.
The Company introduced this illustration previously in the Clean Energy Your Way
workshop with Staff on July 7, 2021.
Construction Arrangement Pricing Illustration

In this illustration, a solar resource and basic solar shape is assumed. The white
and gray rows correspond to hours/times of the day, with the top-most gray row
representing all pre-dawn hours and the bottom gray row representing all post-sunset
hours. For both of these rows, the solar resource would not be generating and so no
output is reflected in orange for these rows. In this illustration, the red dollar signs reflect
charges, while the green dollar signs reflect credits.
IDAHO POWER COMPANY’S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 46
Staff’s specific questions are addressed below using the illustration above as the
example:
a. When the renewable resource is not generating, the customer will pay the
energy charges consistent with their tariff along with all their other standard
charges. In the illustration above, this cost stream is reflected in the middle
column “Idaho Power Energy Cost” by the red dollar sign in Row 1, Column 2.
Because a solar resource will not generate before dawn or after sunset, there
are no other charges or credits at this time. Power Supply Costs incurred by
Idaho Power to serve the customer’s load would be included as power supply
costs tracked through the PCA for customers paying tariff rates based on
embedded system costs. If customers pay a marginal energy rate for service
from Idaho Power, the collections from the customer would be recognized as
a credit to power supply costs in the PCA, thus carving out those potentially
higher, marginal power supply costs from collection through the PCA from
non-participating customers.
b. When the renewable resource is generating, but it is generating less than the
amount the customer is consuming, the customer will pay for all of the solar
output in that hour (as represented by the red dollar sign in Row 2, Column
1), as well as their energy charges for the difference between what the solar
resource can provide in that hour and their energy need in that hour (as
represented by the red dollar sign in Row 2, Column 2). PCA impacts are the
same as the response 30a for energy delivered from Idaho Power, renewable
IDAHO POWER COMPANY’S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 47
resource PPA costs would not be included in the PCA as they are paid by the
Clean Energy Your Way customer.
c. When the renewable resource is generating, but it is generating more than
the amount the customer is consuming, the customer will pay the entire
output of the solar resource in that hour (as represented by the red dollar sign
in Rows 4-6. Because the solar resource will exceed the customer’s energy
needs in these hours, the customer will not pay for energy from Idaho Power.
The customer will also be credited for the value of excess generation that
exceeds the customer’s energy needs in any hour—represented by the green
dollar signs in Rows 4-6. The value of the excess generation credited to the
customer will be a power supply cost tracked and collected through the PCA.
d. Unless a customer were to lose power or temporarily disconnect from Idaho
Power, there are no circumstances in which a Construction offering customer
(either a Schedule 19 or Special Contract customer) would not consume at
least some amount of energy to run their operations. However, in such
circumstances, the customer would still pay for the cost of solar output in any
hour the resource generates and be credited for any amount above their
consumption on an hourly basis. PCA impacts are the same as response 30c.
The response to this Request is sponsored by Alison Williams, Regulatory Policy
and Strategy Advisor, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 48
REQUEST FOR PRODUCTION NO. 31: Please fully describe the competitive
procurement process the Company envisions for the Subscription and Construction
offering resources. In the response, please indicate, for the two types of offerings, if the
Company plans to receive competitive bids, and whether the Company is targeting
resources in the form of PPAs, company-owned resources, or both. Please provide
justification for the Company’s preferred approach.
RESPONSE TO REQUEST FOR PRODUCTION NO. 31: Please refer to
responses to Staff’s Production Request Nos. 16, 23, 32, and 33, related to resource
identification, selection, and procurement.
The response to this Request is sponsored by Alison Williams, Regulatory Policy
and Strategy Advisor, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 49
REQUEST FOR PRODUCTION NO. 32: Please confirm the resources obtained
for the Subscription and Construction Offering are either Company owned or contracted
by the Company through a PPA. If not, please explain.
RESPONSE TO REQUEST FOR PRODUCTION NO. 32: Correct – the
resources for the Subscription and Construction offerings will either be Company-owned
or contracted by the Company via PPA.
The response to this Request is sponsored by Alison Williams, Regulatory Policy
and Strategy Advisor, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 50
REQUEST FOR PRODUCTION NO. 33: Please explain the risks associated
with the Company owning the generation resource versus the resource being obtained
through a PPA for the Subscription offering and Construction offering, separately.
RESPONSE TO REQUEST FOR PRODUCTION NO. 33: Idaho Power’s
resource procurement process is always focused on risk minimization. The Company
believes several risks exist associated with resources procured through a PPA,
including, but not limited to, the developer failing to meet its obligation to provide energy
and/or capacity in the contractual timeframe or at the contracted price, as well as the
risk of additional costs to customers associated with imputed debt applied to resources
not owned by the Company. Additionally, the Company has greater control of and
flexibility to manage resources it owns and operates.
Idaho Power believes resources obtained via PPA can be a preferred option in
some instances. The Company will always strive for the most reliable and cost-effective
method to serve customers and meet their clean energy needs.
Idaho Power has detailed the benefits of Company-owned resources in IPC-E-
21-41.
The response to this Request is sponsored by Alison Williams, Regulatory Policy
and Strategy Advisor, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 51
REQUEST FOR PRODUCTION NO. 34: For the Construction Offering, please
explain if funding a resource that is Company owned through Contribution in Aid of
Construction (CIAC) charged to participants is possible. Also please provide the
advantages and disadvantages of funding the capital cost of the resource through a
CIAC versus the Company recovering the capital exclusively through customer rates.
RESPONSE TO REQUEST FOR PRODUCTION NO. 34: The Company does
not consider a Contribution in Aid of Construction (CIAC) a viable option for Clean
Energy Your Way – Construction arrangements. Idaho Power would be required to
collect a tax gross-up on the CIAC, which would increase the upfront cost for the
participant. Additionally, and based on customer conversations in the development of
the Construction offering, Idaho Power does not believe that funding a resource through
a large, upfront cost will meet the needs or align with cost considerations of its largest
customers in achieving their clean energy-related goals.
The response to this Request is sponsored by Tami White, Budget and Revenue
Manager, Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 52
DATED at Boise, Idaho, this 11th day of February 2022.

LISA D. NORDSTROM
Attorney for Idaho Power Company

IDAHO POWER COMPANY’S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 53
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on the 11th day of February 2022, I served a true and
correct copy of Idaho Power Company’s Response to First Production Request of the
Commission Staff to Idaho Power Company upon the following named parties by the
method indicated below, and addressed to the following:

Commission Staff
Riley Newton
Deputy Attorney General
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg No. 8,
Suite 201-A (83714)
PO Box 83720
Boise, ID 83720-0074

Hand Delivered
U.S. Mail
Overnight Mail
FAX
_____ FTP Site
X Email: [e-mail]

Industrial Customers of Idaho Power
Peter J. Richardson
Richardson Adams, PLLC
515 N. 27th Street
P.O. Box 7218
Boise, ID 83702
Hand Delivered
U.S. Mail
Overnight Mail
FAX
_____ FTP Site
X Email: [e-mail]

Dr. Don Reading
6070 Hill Road
Boise, Idaho 83703
Hand Delivered
U.S. Mail
Overnight Mail
FAX
_____ FTP Site
X Email: [e-mail]

Idaho Conservation League
Benjamin J. Otto
Emma E. Sperry
Idaho Conservation League
710 N. 6th Street
Boise, ID 83702
Hand Delivered
U.S. Mail
Overnight Mail
FAX
_____ FTP Site
X Email: [e-mail]
[e-mail]

Vicki M. Baldwin
Parsons Behle & Latimer
201 South Main Street, Suite 1800
Salt Lake City, UT 84111
Hand Delivered
U.S. Mail
Overnight Mail
FAX
_____ FTP Site
X Email: [e-mail]

IDAHO POWER COMPANY’S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY- 54
Steve W. Chriss
Director, Energy Services
Walmart, Inc.
Hand Delivered
U.S. Mail
Overnight Mail
FAX
_____ FTP Site
X Email: [e-mail]
City of Boise
Ed Jewell
Deputy City Attorney’s Office
150 N. Capitol Blvd.
P.O. Box 500
Boise, ID 83701-0500
Hand Delivered
U.S. Mail
Overnight Mail
FAX
_____ FTP Site
X Email: [e-mail]
[e-mail]
Wil Gehl
Energy Program Manager
Boise City Department of Public Works
150 N. Capitol Blvd.
P.O. Box 500
Boise, ID 83701-0500
Hand Delivered
U.S. Mail
Overnight Mail
FAX
_____ FTP Site
X Email: [e-mail]
Clean Energy Opportunities for Idaho
Kelsey Jae
Law for Conscious Leadership
920 N. Clover Dr.
Boise, ID 83703
Hand Delivered
U.S. Mail
Overnight Mail
FAX
_____ FTP Site
X Email: [e-mail]
Courtney White
Mike Heckler
Clean Energy Opportunities for Idaho
3778 Plantation River Drive, Suite 102
Boise, ID 83703
Hand Delivered
U.S. Mail
Overnight Mail
FAX
_____ FTP Site
X Email:
[e-mail]
[e-mail]
________________________________
Stacy Gust, Regulatory Administrative
Assistant

BEFORE THE

IDAHO PUBLIC UTILITIES COMMISSION

CASE NO. IPC-E-21-40

IDAHO POWER COMPANY

REQUEST NO. 14

ATTACHMENT 1
SEE ATTACHED DOCUMENT