20230717IPC to CEO 1-7.pdf

MEGAN GOICOECHEA ALLEN
Corporate Counsel
[e-mail]

July 17, 2023

Jan Noriyuki, Secretary
Idaho Public Utilities Commission
11331 W. Chinden Boulevard
Building 8, Suite 201-A
Boise, Idaho 83714

Re: Case No. IPC-E-23-14
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

Dear Ms. Noriyuki:

Attached for electronic filing is Idaho Power Company’s Response to Clean Energy
Opportunities for Idaho’s First Production Request to Idaho Power Company 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
Enclosures
RECEIVED
Monday, July 17, 2023 4:15:53 PM
IDAHO PUBLIC
UTILITIES COMMISSION

IDAHO POWER COMPANY’S RESPONSE TO CLEAN ENERGY OPPORTUNITIES FOR IDAHO’S
FIRST PRODUCTION REQUEST - 1
MEGAN GOICOECHEA ALLEN (ISB No. 7623)
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]
[e-mail]

Attorneys for Idaho Power Company

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

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

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CASE NO. IPC-E-23-14

IDAHO POWER COMPANY’S
RESPONSE TO CLEAN ENERGY
OPPORTUNITIES FOR IDAHO’S
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY

COMES NOW, Idaho Power Company (“Idaho Power” or “Company”), and in
response to the First Production Request of Clean Energy Opportunities for Idaho’s
(“CEO”) dated June 26, 2023, herewith submits the following information:

IDAHO POWER COMPANY’S RESPONSE TO CLEAN ENERGY OPPORTUNITIES FOR IDAHO’S
FIRST PRODUCTION REQUEST - 2

REQUEST FOR PRODUCTION NO. 1: In 2022, what was the average cost per
kWh incurred by the Company for each 1 cent Green Power premium sold to Idaho Power
customers?
RESPONSE TO REQUEST FOR PRODUCTION NO. 1: In 2022, participants
bought 37,518,217 kilowatt-hours (“kWh”) at 1 cent per kWh through the Green Power
Program. Company-funded expenses comprised $200 in administrative costs and
$12,023 in marketing costs, for a total expense of $12,223. The average cost per Green
Power Program kWh incurred by the Company was $0.00033 per kWh.
Marketing costs have been approximately $6,000 higher in a typical year than 2022
actuals, which would have resulted in an average cost per Green Power Program kWh
incurred by the Company of approximately $0.00049 per kWh. The decrease in 2022 was
due to the pending Clean Energy Your Way filing that, if approved, would change the
name of the Green Power Program. Therefore, the Company canceled certain long lead-
time marketing campaigns to reduce the risk that these marketing materials would
become outdated and unusable.
The response to this Request is sponsored by Suzanne Smith, Senior Program
Specialist, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO CLEAN ENERGY OPPORTUNITIES FOR IDAHO’S
FIRST PRODUCTION REQUEST - 3

REQUEST FOR PRODUCTION NO. 2: In Order No. 33570 (in IPC-E-16-13), the
Commission directed the Company to submit a biennial Green Power Prudency Report,
which includes the following information (as copied from the 2022 Green Power Program
Biennial Report page 1):
In August 2016, the Commission issued Order No. 33570 approving the
Company’s requested changes. Additionally, 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
The most recent biennial Prudency report covered a period ending December 31,
2021. Please provide an update of the above information for the period covering January
2022 through December 2022, with the exception that neither the marketing summary nor
the Solar 4R Schools expenses are needed. Specifically, please provide the comparable
data presented in Tables 1 through 5 of the 2022 Green Power Prudency Report.

IDAHO POWER COMPANY’S RESPONSE TO CLEAN ENERGY OPPORTUNITIES FOR IDAHO’S
FIRST PRODUCTION REQUEST - 4

RESPONSE TO REQUEST FOR PRODUCTION NO. 2: The following information
is taken from the biennial Green Power Prudency Report and includes both the narrative
and data presented in Tables 1 through 5, updated with 2022 information.
A. Customer Count by Option and Rate Schedule
Table 1:
GP - 100% OPTION GP - BLOCK OPTION
2022 A-ID C-ID R-ID R-OR A-ID C-ID I-ID R-ID R-OR Total Participants*
January 1 40 1,815 18 2 41 2 1,861 20 3,800
February 1 39 1,823 13 2 37 5 1,810 17 3,747
March 1 44 1,997 17 2 49 5 2,001 20 4,136
April 1 50 1,908 15 2 41 4 1,892 19 3,932
May 2 45 1,977 19 2 40 5 1,925 17 4,032
June 3 56 2,034 12 2 45 3 1,949 16 4,120
July 3 52 1,985 16 2 39 4 1,864 18 3,983
August 2 52 2,205 15 2 46 5 2,048 23 4,398
September 3 54 2,101 12 2 37 2 1,884 19 4,114
October 3 52 2,146 19 2 37 4 1,944 24 4,231
November 3 49 2,239 12 2 47 4 1,986 19 4,361
December 1 53 2,186 18 2 40 4 1,940 21 4,265
R - Residential C - Commercial I - Industrial A - Agricultural
* Participant count is based on payments made during the selected month.

While monthly participation fluctuated over the last 12 months, as of December
2022, overall participation increased by 11 percent (or 434 new participants) from the
December 2021 totals disclosed in the previous biennial report.

IDAHO POWER COMPANY’S RESPONSE TO CLEAN ENERGY OPPORTUNITIES FOR IDAHO’S
FIRST PRODUCTION REQUEST - 5

B. REC Purchases and Project Sources

Table 2: REC Purchases and Costs

Month Year RECs Needed (MWh) Cost
January 2022 3,345.624 $23,753.93
February 2022 3,178.303 $22,565.95
March 2022 3,348.294 $23,772.89
April 2022 2,808.363 $19,939.38
May 2022 2,689.342 $19,094.33
June 2022 2,697.715 $19,153.78
July 2022 2,782.193 $19,753.57
August 2022 3,794.032 $26,937.63
September 2022 3,616.805 $25,679.32
October 2022 3,238.228 $22,991.42
November 2022 2,565.677 $18,216.31
December 2022 3,453.641 $24,520.85
Total 37,519 $266,379.34
37,519 RECs delivered from supplier. RECs are delivered in whole MWh.

Table 2 above shows the monthly RECs needed for the Program and applies the
REC cost ($7.10/REC) to the monthly REC need to determine the monthly cost of RECs.
A monthly general ledger report shows how much revenue was collected for the Green
Power Program. RECs are purchased based on the funds collected.
One of the Program modifications approved by Order No. 33570 included sourcing
RECs from the Northwest and giving preference to RECs from sources located closest to
or within Idaho Power’s service area, when possible. Table 3 below shows the project
sources of RECs purchased for the Program for January through December 2022.

IDAHO POWER COMPANY’S RESPONSE TO CLEAN ENERGY OPPORTUNITIES FOR IDAHO’S
FIRST PRODUCTION REQUEST - 6

Table 3: Sources of RECs Purchased for Participants

2022
Facility Name WREGIS
ID1 Certificate Serial Numbers RECs Source State IPC
Area
Grand View 2 West W5070 5070-ID-529369-1183-2885 1,703 Solar ID Yes
Grand View 5 East W5069 5069-ID-525590-1-766 766 Solar ID Yes
Grand View 5 East W5069 5069-ID-517638-1-1431 1,431 Solar ID Yes
Grand View 5 East W5069 5069-ID-509808-1-2289 2,289 Solar ID Yes
Grand View 5 East W5069 5069-ID-501781-1-2509 2,509 Solar ID Yes
Grand View 5 East W5069 5069-ID-493871-1-2802 2,802 Solar ID Yes
Rockland Wind Farm W2445 2445-ID-516927-14493-28708 14,216 Wind ID Yes
Salmon Falls Wind Park W1885 1885-ID-502786-4823-5266 444 Wind ID Yes
Salmon Falls Wind Park W1885 1885-ID-510735-1-4100 4,100 Wind ID Yes
Tumbleweed Solar LLC W6981 6981-OR-538344-242-710 469 Solar OR No
Woodline Solar, LLC W5845 5845-OR-583731-1905-2153 249 Solar OR No
Woodline Solar, LLC W5845 5845-OR-542101-1-540 540 Solar OR No
Woodline Solar, LLC W5845 5845-OR-532836-1-862 862 Solar OR No
Woodline Solar, LLC W5845 5845-OR-524336-1-1265 1,265 Solar OR No
Woodline Solar, LLC W5845 5845-OR-512555-1-1780 1,780 Solar OR No
Woodline Solar, LLC W5845 5845-OR-504857-1-2094 2,094 Solar OR No Total 37,519

Of the RECs purchased, all were from Idaho and Oregon, and 81 percent were
from projects within Idaho Power’s service area.
There were no Idaho Power-owned RECs purchased for the Program, therefore
no fund transfers to the PCA were required. However, outside of the Program and through
the Large Renewable Energy Purchase Option (“Large Purchase Option”), Idaho Power
sold Company-owned RECs to business customers.

1 The Western Renewable Energy Generation Information System (“WREGIS”) is an independent,
renewable energy tracking system for the region covered by the Western Electricity Coordinating Council
(“WECC”). WREGIS tracks renewable energy generation from units that register in the system by using
verifiable data and creating renewable energy certificates for this generation.

IDAHO POWER COMPANY’S RESPONSE TO CLEAN ENERGY OPPORTUNITIES FOR IDAHO’S
FIRST PRODUCTION REQUEST - 7

For reporting year 2022, seven business customers participated in the Large
Purchase Option. A total of 28,549 Idaho Power-owned RECs were purchased and
$30,317.49 from these sales was transferred to the Power Cost Adjustment (“PCA”).
C. Monthly Revenue and Expenses

Table 4 below shows the monthly revenues received from Schedule 62 and the
actual timing of Program expenses. Please note that the expenses are inclusive of the
monthly REC costs identified in Table 2, though amounts on a monthly basis will not align
with Table 2 due to timing differences between the receipt of funds and actual payments
to vendors.
Table 4: Program Revenue and Expenses by Month

2022
Monthly Revenues Monthly Expenses
January $33,456.24 January $110,679.28
February $31,783.03 February $102.60
March* $33,482.94 March $850.75
April $28,083.63 April $608.12
May $26,893.42 May $113.19
June $26,977.15 June $29,000.00
July $27,821.93 July $137,621.63
August $37,940.32 August $1,101.08
September $36,168.05 September $1,507.65
October $32,382.28 October $97.20
November $25,656.77 November $3,763.39
December $34,536.41 December $2,717.66
Total $375,182.17 Total $288,162.55

REC payments are made biannually. Payment for July through December 2021
RECs for $110,679.28 occurred in January 2022 as shown in Table 4. Payment for July
through December 2022 RECs for $138,099.09 occurred in January 2023 and will be
reflected in Table 4 in the next biennial report.

IDAHO POWER COMPANY’S RESPONSE TO CLEAN ENERGY OPPORTUNITIES FOR IDAHO’S
FIRST PRODUCTION REQUEST - 8

D. Green-e Certification Costs

As shown in Table 5 below, Green-e certification costs for 2022 totaled
$12,543.14, which included annual verification performed by an external auditor and
participant notifications to meet Green-e Energy certification requirements. The 2022
Green-e certification renewal for $16,550 was paid in 2021 and was reported as an
expense in the previous biennial report.
Participant notifications included the annual prospective product content label,
annual historical product content label, and new participant welcome letters with
information about the Program’s terms and certification. Approximately 80 percent of
participants receive email communication for the two annual notifications, which keeps
the distribution cost low.
Table 5: Green-e Certification Costs
2022
External Audit $9,000.00
Participant Notifications $3,543.14
Total $12,543.14

The response to this Request is sponsored by Suzanne Smith, Senior Program
Specialist, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO CLEAN ENERGY OPPORTUNITIES FOR IDAHO’S
FIRST PRODUCTION REQUEST - 9

REQUEST FOR PRODUCTION NO. 3: Among the "Energy Solutions for Your
Company" , Idaho Power offers a Large Renewable Energy Purchase option. With regard
to that program, please provide the following for the year 2022:
● Number of business customers participating, if any
● Total quantity of RECs purchased by those customers
● Average price per REC paid by customers for purchase of such RECs
● Were all of the RECs purchased by customers under the Large Renewable
Energy Purchase option already owned by Idaho Power?
● If not, what was the total cost to Idaho Power for purchase of such RECs?
● What, if any, dollar amount of proceeds from any such REC sales were
transferred to the PCA?
RESPONSE TO REQUEST FOR PRODUCTION NO. 3: Please see the below
responses regarding Idaho Power’s Large Renewable Energy Purchase option for the
year 2022:
 Number of participants: Seven
 Total quantity of RECs purchased: 28,549
 Average price per REC: $1.17
 All RECs purchased already owned by Idaho Power: Yes
 If not, what was the total cost to Idaho Power: Not applicable
 From these sales, amount transferred to PCA: $30,317
The response to this Request is sponsored by Suzanne Smith, Senior Program
Specialist, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO CLEAN ENERGY OPPORTUNITIES FOR IDAHO’S
FIRST PRODUCTION REQUEST - 10

REQUEST FOR PRODUCTION NO. 4: The table below, taken from the Prudency
reports submitted under Order No. 33570, show that the number of participants and the
quantity of RECs purchased under the Green Power program has increased dramatically
between 2017 and 2021.

During that same period, annual payments to Green-e and auditors have increased
by almost two-thirds (from $16,400 to $25,550). That increase in the amount paid for
Green-e and auditor was roughly proportional to the increases in the number of
participants and total RECs provided during the 2017 through 2021 period. With regard
to those payments:
(a) Were the amounts owed to Green-e and/or the auditors for their services in
each of those five years determined in whole or in part by the number of
participants or number of RECs retired?
(b) If yes, would the Company expect to have to make larger dollar payments to
Green-e and/or the auditors for their services if there are future increases in
the number of participants or number of RECs retired?

IDAHO POWER COMPANY’S RESPONSE TO CLEAN ENERGY OPPORTUNITIES FOR IDAHO’S
FIRST PRODUCTION REQUEST - 11

(c) Were any of those payments made to either Green-e or the auditors related to
services provided for certifying or auditing RECs sold to business customers
under the Large Renewable Energy Purchase program?
(d) If not, were there any analogous payments for certification or auditing made
under the Large Renewable Energy Purchase program?
(e) If such payments were made under the Large Renewable Energy Purchase
program, how many dollars were spent on those matters in 2022?
RESPONSE TO REQUEST FOR PRODUCTION NO. 4: Please see responses to
the questions below regarding Green-e certification costs:
(a) No. Green-e certification costs are unrelated to the number of program
participants, and there are no volumetric fees for total RECs sold through the
program. Certification costs for utility programs are determined by the utility’s
total number of customers served. The cost for the annual audit is based on
hourly rates and is primarily driven by the number of generation facilities
supplying RECs for the program. The auditor must verify many characteristics
of each facility as part of the verification process, and this takes the most time
compared to REC sales and retirement verification. Increases in Green Power
sales could cause RECs to be sourced from more renewable generation
facilities; however, that is not always the case.
(b) No. The Company does not expect Green-e certification costs to rise due to
increased Green Power Program participation or REC sales. The audit costs
may increase with the volume of RECs sold if the RECs must be sourced from
an increasing number of facilities. However, as shown in the Excel file labeled

IDAHO POWER COMPANY’S RESPONSE TO CLEAN ENERGY OPPORTUNITIES FOR IDAHO’S
FIRST PRODUCTION REQUEST - 12

“Attachment – Response to CEO Request No. 4,” more REC sales may not
correlate with more resources and greater auditor fees.
(c) No. Idaho Power-owned RECs are not Green-e certified; therefore, no
payments are made to either Green-e or the auditors, and no similar costs are
incurred for the Large Renewable Energy Purchase Program. Idaho Power
provides proof of REC retirement to the purchasers, which can be printed from
the Company’s WREGIS account.
(d) Not applicable – see response to 4(c).
(e) Not applicable – see response to 4(c).
The response to this Request is sponsored by Suzanne Smith, Senior Program
Specialist, Idaho Power Company

IDAHO POWER COMPANY’S RESPONSE TO CLEAN ENERGY OPPORTUNITIES FOR IDAHO’S
FIRST PRODUCTION REQUEST - 13

REQUEST FOR PRODUCTION NO. 5: Within the reports WREGIS produces,
Idaho Power is listed as the Qualified Reporting Entity (QRE) for, among others, the
following Renewable Generation Units:
➢ Neal Hot Springs Unit #1
➢ OSPV2010
➢ OSPV 2011
➢ OSPV2013
➢ OSPV 2014
➢ Elkhorn Valley Wind Farm
● Did Idaho Power gain ownership to any of the RECs produced by any of these
renewable generation units during 2022?
● If yes, how many RECs were transferred to Idaho Power?
RESPONSE TO REQUEST FOR PRODUCTION NO. 5: Yes, Idaho Power
received Renewable Energy Credits (“RECs”) produced by the above referenced
renewable generation units during 2022. Please see the table summarizing the RECs
received for these generation units in 2022.
Generator Name
RECs Transferred to
Idaho Power in 2022
Neal Hot Springs Unit #1 178,846
OSPV2010 116
OSPV 2011 384
OSPV2013 127
OSPV 2014 99
Elkhorn Valley Wind Farm 294,788
Total 474,360
The response to this Request is sponsored by Kevin Dodson, Renewable
Compliance Analyst, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO CLEAN ENERGY OPPORTUNITIES FOR IDAHO’S
FIRST PRODUCTION REQUEST - 14

REQUEST FOR PRODUCTION NO. 6: Did Idaho Power gain ownership of any
RECs under any PURPA contracts during 2022? If yes, how many RECs were transferred
to Idaho Power?
RESPONSE TO REQUEST FOR PRODUCTION NO. 6: Yes, Idaho Power
received RECs under Public Utility Regulatory Policies Act of 1978 (“PURPA”) contracts
during 2022. Please see the table summarizing the RECs received from PURPA contracts
for 2022.
Generator Name
RECs Transferred to
Idaho Power in 2022
American Falls Solar II, LLC 21,233
merican Falls Solar, LLC 20,570
Grand View 2 West 66,673
Grand View 5 East 21,397
Hi h Mesa 1,722
ID Solar 1, LLC 47,003
Mt Home Solar 1 LLC 21,257
Murph Flat Power, LLC 18,984
Orchard Ranch Solar, LLC 22,339
Rockland Wind Farm 234,455
Simcoe Solar, LLC 23,094
Total 498,727
The response to this Request is sponsored by Kevin Dodson, Renewable
Compliance Analyst, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO CLEAN ENERGY OPPORTUNITIES FOR IDAHO’S
FIRST PRODUCTION REQUEST - 15

REQUEST FOR PRODUCTION NO. 7: In his direct testimony (see Exhibit 6, page
1), Grant Anderson shows that pretty much regardless of their level of monthly
consumption, Schedule 6 customers are expected to export roughly .5MWh/month under
a net billing export credit structure (see image below):

In her direct testimony (see Table 2, page 34) Connie Aschenbrenner shows 9,379 non-
Legacy Residential and Small General service customers in Schedules 6 and 8.
As these customers are limited to arrays of no more than 25kW, please divide them
into the following five groupings when replying to the two data requests below:
< 5kW
> 5kW but <10kW
> 10kW but < 15kW
>15kW but < 20kW
>20kW
Please provide data regarding:
● The number of such non-Legacy R&SGS customers in each of the five
nameplate grouping, and
● The average array size (in nameplate kWs) for each grouping

IDAHO POWER COMPANY’S RESPONSE TO CLEAN ENERGY OPPORTUNITIES FOR IDAHO’S
FIRST PRODUCTION REQUEST - 16

RESPONSE TO REQUEST FOR PRODUCTION NO. 7: The table below shows
the number of non-legacy Residential and Small General Service (“R&SGS”) customers
divided into the five groupings requested as well as the average size for each grouping.
Size Group (kW) Count Average Size (kW)
0-5 3,356 3.9
5-10 4,361 7.4
10-15 1,015 12.1
15-20 489 16.6
>20 151 23.0
Please note that as a result of combining two expansion systems into one system
size and removing three duplicates and two non-solar customer installations (one wind
and one hydro) for purposes of responding to this request, the total non-legacy R&SGS
customer count included in this response varies slightly from the total set forth in Table 2
of the Aschenbrenner Direct Testimony, though the difference is de minimis and not
material to the Company’s requests in this case.
The response to this Request is sponsored by Jordan Prassinos, Manager Load
Forecast and Principal Economist, Idaho Power Company. 

DATED at Boise, Idaho, this 17th day of July 2023.

MEGAN GOICOECHEA ALLEN
Attorney for Idaho Power Company

IDAHO POWER COMPANY’S RESPONSE TO CLEAN ENERGY OPPORTUNITIES FOR IDAHO’S
FIRST PRODUCTION REQUEST - 17

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on the 17th day of July, 2023, I served a true and correct
copy of Idaho Power Company’s Response to Clean Energy Opportunities for Idaho’s
First Production Request upon the following named parties by the method indicated
below, and addressed to the following:

Commission Staff
Chris Burdin
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

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IdaHydro
C. Tom Arkoosh
ARKOOSH LAW OFFICES
913 W. River Street, Suite 450
P.O. Box 2900
Boise, Idaho 83701

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Idaho Conservation League
Marie Kellner
Idaho Conservation League
710 North 6th Street
Boise, Idaho 83702

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Brad Heusinkveld
Idaho Conservation League
710 North 6th Street
Boise, Idaho 83702

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IDAHO POWER COMPANY’S RESPONSE TO CLEAN ENERGY OPPORTUNITIES FOR IDAHO’S
FIRST PRODUCTION REQUEST - 18

Idaho Irrigation Pumpers Association,
Inc.
Eric L. Olsen
ECHO HAWK & OLSEN, PLLC
505 Pershing Avenue, Suite 100
P.O. Box 6119
Pocatello, Idaho 83205

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Lance Kaufman, Ph.D.
2623 NW Bluebell Place
Corvallis, OR 97330
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Clean Energy Opportunities for Idaho
Kelsey Jae
Law for Conscious Leadership
920 N. Clover Dr.
Boise, Idaho 83703
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Michael Heckler
Courtney White
Clean Energy Opportunities for Idaho
3778 Plantation River Dr., Suite 102
Boise, ID 83703

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Micron Technology, Inc.
Austin Rueschhoff
Thorvald A. Nelson
Austin W. Jensen
Holland & Hart, LLP
555 Seventeenth Street, Suite 3200
Denver, Colorado 80202

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IDAHO POWER COMPANY’S RESPONSE TO CLEAN ENERGY OPPORTUNITIES FOR IDAHO’S
FIRST PRODUCTION REQUEST - 19

Jim Swier
Micron Technology, Inc.
8000 South Federal Way
Boise, Idaho 83707
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City of Boise
Darrell G. Early
Deputy City Attorney
Boise City Attorney’s Office
150 N. Capitol Blvd.
PO Box 500
Boise, Idaho 83701-0500
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Wil Gehl
Energy Program Manager
Boise City Dept. of Public Works
150 N. Capitol Blvd.
Boise, Idaho 83701-0500

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Vote Solar
Abigail R. Germaine
Elam & Burke, PA
251 E. Front Street, Suite 300
PO Box 1539
Boise, ID 83701
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Kate Bowman
Regulatory Director
Vote Solar
299 S. Main Street, Suite 1300
PMB 93601
Salt Lake City, UT 84111
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Stacy Gust, Regulatory Administrative
Assistant

BEFORE THE

IDAHO PUBLIC UTILITIES COMMISSION

CASE NO. IPC-E-23-14

IDAHO POWER COMPANY

ATTACHMENT 1

REQUEST NO. 4
SEE ATTACHED SPREADSHEET