20230817IPC to Staff 7-9 Supplemental.pdf

MEGAN GOICOECHEA ALLEN
Corporate Counsel
[e-mail]

August 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 Supplemental Response
to the Second Production Request of the Commission Staff 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:cd
Enclosures
RECEIVED
Thursday, August 17, 2023 3:26:54 PM
IDAHO PUBLIC
UTILITIES COMMISSION

IDAHO POWER COMPANY’S SUPPLEMENTAL RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF - 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

)
)
)
)
)
)
)
)
)
)

CASE NO. IPC-E-23-14

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

COMES NOW, Idaho Power Company (“Idaho Power” or “Company”), and in
response to the Second Production Request of the Commission Staff (“Commission” or
“Staff”) dated June 23, 2023, herewith supplements the following information:

IDAHO POWER COMPANY’S SUPPLEMENTAL RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF - 2
STAFF REQUEST FOR PRODUCTION NO. 7: Please describe and quantify the
incremental administrative burden and any IT infrastructure needed for the Company for
collecting and processing AMI data and billing at the real-time measurement interval.
Please provide supporting workpapers in excel format with formulas enabled.
SUPPLEMENTAL RESPONSE TO STAFF’S REQUEST FOR PRODUCTION
NO. 7: The Company’s billing system will be configured to implement its proposal, real-
time net billing, effective January 1, 2024.
The response to this Request is sponsored by Matisse Weigel, ERP Applications
Senior Manager, Idaho Power Company.

IDAHO POWER COMPANY’S SUPPLEMENTAL RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF - 3
STAFF REQUEST FOR PRODUCTION NO. 8: Under an hourly net billing Export
Credit Rate ("ECR") structure, please describe and quantify the incremental
administrative burden and any IT infrastructure needed to the Company for collecting and
processing AMI data and billing at the hourly measurement interval. Please provide
supporting workpapers in excel format with formulas enabled.
SUPPLEMENTAL RESPONSE TO STAFF’S REQUEST FOR PRODUCTION
NO. 8: As noted in its initial Response to Staff’s Request for Production Nos. 7 and 8, the
scope of work necessary to configure the Company’s billing system to a real-time versus
net hourly interval is the same from the onset. However, the Company wishes to clarify
that it anticipates completing the work necessary to implement its proposed compensation
structure (real-time net billing) before its proposed effective date for changes, January 1,
2024.
If the Commission were to order that a measurement interval other than real-time
net billing be implemented, such as net hourly, additional/incremental work would then be
necessary to implement a compensation structure not currently being configured.
Specifically, implementing a net hourly compensation structure – once the system is
already being configured to implement a real-time measurement interval – will require
further development and technical changes to the Company’s billing system and the
Company’s customer portal and mobile application. Please see the Excel file labeled
“Attachment - Response to Staff’s Request No. 8” for the estimated cost of such work.
Should the Commission Order that the Company implement a net hourly
compensation structure instead of a real-time measurement interval, the Company
anticipates that the necessary implementation work could be completed no sooner than

IDAHO POWER COMPANY’S SUPPLEMENTAL RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF - 4
four months following receipt of such an order.
The response to this Request is sponsored by Matisse Weigel, ERP Applications
Senior Manager, Idaho Power Company.

IDAHO POWER COMPANY’S SUPPLEMENTAL RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF - 5
STAFF REQUEST FOR PRODUCTION NO. 9: Please describe in detail the
resolution of information available to customers with interconnected solar systems under
the Company's proposed ECR:
(a) Please provide examples of Schedule 6, Schedule 8, and Schedule 84
customer bills under the Company's proposed ECR;
(b) Please describe what usage and export level data will be available to
customers (i.e., real time, hourly usage, etc.); and
(c) Please explain if the information will be different for a customer accessing their
usage data from the Company's mobile app or online account.
SUPPLEMENTAL RESPONSE TO STAFF’S REQUEST FOR PRODUCTION
NO. 9: Please see the below responses regarding information available to customers with
on-site generation systems:
(a) Drafts of customer bills under the Company’s proposed ECR are provided in
the files labeled:
 “Attachment 1 – Response to Staff Request No. 9 – Schedule 6”
 “Attachment 2 – Response to Staff Request No. 9 – Schedule 8”
 “Attachment 3 – Response to Staff Request No. 9 – Schedule 84 large
general”
Please note that Schedule 84 irrigation customers’ bills are expected to look
similar to Schedule 84 large general secondary service customers’ bills, less
inclusion of the basic charge line item.
For comparative purposes, examples of customer bills under the existing net
energy metering compensation structure have also been provided in the files

IDAHO POWER COMPANY’S SUPPLEMENTAL RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF - 6
labeled:
 “Attachment 4 – Response to Staff Request No. 9 – Schedule 6”
 “Attachment 5 – Response to Staff Request No. 9 – Schedule 8”
 “Attachment 6 – Response to Staff Request No. 9 – Schedule 84 large
general”
As bill presentment continues to be refined over the next several months, the
Company will coordinate with Consumer Affairs Staff to ensure the final
versions are compliant with the Utility Customer Relations Rules (“UCRRs”),
Contents of Bills (Rule 201).
(b) The file labeled “Attachment 7 – Response to Staff Request No. 9” has two
screenshots of data currently provided via My Account to on-site generation
customers. As illustrated in this file, existing on-site generation customers
presently have visibility to consumption and exports as they would be billed
under the Company’s proposed “real-time” measurement interval. The
Company intends to remove the “net energy” line on the Monthly Use graph as
that is representative of the existing net energy metering billing construct and
is not reflective of the more granular net billing measurement intervals being
considered as part of this case.
(c) See original response.
The response to this Request is sponsored by Grant T. Anderson, Regulatory
Consultant, Idaho Power Company.

IDAHO POWER COMPANY’S SUPPLEMENTAL RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF - 7
DATED at Boise, Idaho, this 17th day of August 2023.

MEGAN GOICOECHEA ALLEN
Attorney for Idaho Power Company

IDAHO POWER COMPANY’S SUPPLEMENTAL RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF - 8
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on the 17th day of August, 2023, I served a true and
correct copy of Idaho Power Company’s Supplemental Response to the Second
Production Request of the Commission Staff 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

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

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

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

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

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

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

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

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

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

IDAHO POWER COMPANY’S SUPPLEMENTAL RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF - 9
Lance Kaufman, Ph.D.
2623 NW Bluebell Place
Corvallis, OR 97330
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, Idaho 83703
Hand Delivered
U.S. Mail
Overnight Mail
FAX
FTP Site
X Email [e-mail]

Michael Heckler
Courtney White
Clean Energy Opportunities for Idaho
3778 Plantation River Dr., Suite 102
Boise, ID 83703

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

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

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

Jim Swier
Micron Technology, Inc.
8000 South Federal Way
Boise, Idaho 83707
Hand Delivered
U.S. Mail
Overnight Mail
FAX
FTP Site
X Email [e-mail]

IDAHO POWER COMPANY’S SUPPLEMENTAL RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF - 10
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
Hand Delivered
U.S. Mail
Overnight Mail
FAX
FTP Site
X Email [e-mail]
[e-mail]

Wil Gehl
Energy Program Manager
Boise City Dept. of Public Works
150 N. Capitol Blvd.
Boise, Idaho 83701-0500

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

Vote Solar
Abigail R. Germaine
Elam & Burke, PA
251 E. Front Street, Suite 300
PO Box 1539
Boise, ID 83701
Hand Delivered
U.S. Mail
Overnight Mail
FAX
FTP Site
X Email [e-mail]

Kate Bowman
Regulatory Director
Vote Solar
299 S. Main Street, Suite 1300
PMB 93601
Salt Lake City, UT 84111
Hand Delivered
U.S. Mail
Overnight Mail
FAX
FTP Site
X Email [e-mail]

Christy Davenport
Legal Administrative Assistant

BEFORE THE

IDAHO PUBLIC UTILITIES COMMISSION

CASE NO. IPC-E-23-14

IDAHO POWER COMPANY

ATTACHMENT 1

RESPONSE TO STAFF REQUEST NO. 8

SEE EXCEL SPREADSHEET

BEFORE THE

IDAHO PUBLIC UTILITIES COMMISSION

CASE NO. IPC-E-23-14

IDAHO POWER COMPANY

ATTACHMENT 1

RESPONSE TO STAFF REQUEST NO. 9
Meter Number Beginning Readings Ending Readings Energy (kWh) Reading Type
12345678 Energy Used 0 2052 2052 Regular
12345678 Excess Generation 0 3720 3720 Regular
SERVICE DETAILS (Residential On-Site Generation Schedule 06)
Service Charge $5.00
Summer Energy Charge 800 kWh @ $0.086518 per kWh $69.21
Summer Energy Charge 1,200 kWh @ 0.104033 per kWh $124.84
Summer Energy Charge 52 kWh @ 0.123585 per kWh $6.43
Power Cost Adjustment $42.95
Fixed Cost Adjustment $9.03
Franchise Fee 1.50% Paid to Your City $2.41
Energy Efficiency Services $7.74
Federal Columbia River Benefits Supplied by BPA -$5.20
Off-Peak Credit 3,348 kWh @-0.0244 per kWh -$81.98
On-Peak Credit 372 kWh @-0.0314 per kWh -$11.30
Carry Forward Generation Credit -$3.31
Current Charges - Electric Service $165.82
NOTE: For an explanation of these charges, go to idahopower.com/billglossary.
To view hourly data, go to idahopower.com/myaccount.
kWh = Kilowatt-hour
Customer Generation kWh Credit Balance 0
Generation Credit Carry Forward $3.31
Generation Credit This Period: $93.28
Off-Peak $81.98
On-Peak $11.30
Generation Credit Applied This Period -$96.59
Generation Credit Remaining Balance $0.00
Residential NON-Legacy bill
during the first year, when
excess kWh credit balance can
be used until converted to ECR in
2025.
6/28/23-7/27/23 (30 days)
8/28/2023
Meter Number Beginning Readings Ending Readings Energy (kWh) Reading Type
12345678 Energy Used 0 2052 2052 Regular
12345678 Excess Generation 0 3720 3720 Regular
SERVICE DETAILS (Residential On-Site Generation Schedule 06)
Service Charge $5.00
Summer Energy Charge 800 kWh @ $0.086518 per kWh $69.21
Summer Energy Charge 1,200 kWh @ $0.104033 per kWh $124.84
Summer Energy Charge 52 kWh @ $0.123585 per kWh $6.43
Power Cost Adjustment $42.95
5 Fixed Cost Adjustment $9.03
Franchise Fee 1.50% Paid to Your City $2.41
Energy Efficiency Services $7.74
Federal Columbia River Benefits Supplied by BPA -$5.20
Off-Peak Credit 3360 kWh @-$0.0244 per kWh -$81.98
On-Peak Credit 360kWh @-$0.0314 per kWh -$11.30
Carry Forward Generation Credit -$3.31
Current Charges - Electric Service $165.82
NOTE: For an explanation of these charges, go to idahopower.com/billglossary.
To view hourly data, go to idahopower.com/myaccount.
kWh = Kilowatt-hour
Generation Credit Carry Forward $3.31
Generation Credit This Period: $93.28
Off-Peak $81.98
On-Peak $11.30
Generation Credit Applied This Period
Generation Credit Remaining Balance
-$96.59
Residential NON-Legacy after the
first year. (No kWh credit balance,
unless customer transferred kWh
credits from a Legacy system.)
7/28/2023
$0.00

BEFORE THE

IDAHO PUBLIC UTILITIES COMMISSION

CASE NO. IPC-E-23-14

IDAHO POWER COMPANY

ATTACHMENT 2

RESPONSE TO STAFF REQUEST NO. 9
Meter Number Beginning Readings Ending Readings Energy (kWh) Reading Type
12345678 Energy Used 0 2002 2002 Regular
12345678 Excess Generation 0 3720 3720 Regular
SERVICE DETAILS (Small General On-Site Generation Schedule 08)
Service Charge $5.00
Summer Energy Charge 800 kWh @ $0.086518 per kWh $69.21
Summer Energy Charge 1,200 kWh @ 0.104033 per kWh $124.84
Summer Energy Charge 2 kWh @ 0.123585 per kWh $0.25
Power Cost Adjustment $41.90
Fixed Cost Adjustment $8.81
Franchise Fee 1.50% Paid to Your City $2.32
Energy Efficiency Services $7.74
Federal Columbia River Benefits Supplied by BPA -$5.07
Off-Peak Credit 3,348 kWh @-0.0244 per kWh -$81.98
On-Peak Credit 372 kWh @-0.0314 per kWh -$11.30
Carry Forward Generation Credit -$3.31
Current Charges - Electric Service $158.41
NOTE: For an explanation of these charges, go to idahopower.com/billglossary.
To view hourly data, go to idahopower.com/myaccount.
kWh = Kilowatt-hour
Customer Generation kWh Credit Balance 0
Generation Credit Carry Forward $3.31
Generation Credit This Period: $93.28
Off-Peak $81.98
On-Peak $11.30
Generation Credit Applied This Period -$96.59
Generation Credit Remaining Balance $0.00
Small General NON-Legacy bill
during the first year, when
excess kWh credit balance can
be used until converted to ECR
in 2025.
6/28/23-7/27/23 (30 days)
8/28/2023

Meter Number Beginning Readings Ending Readings Energy (kWh) Reading Type
12345678 Energy Used 0 2002 2002 Regular
12345678 Excess Generation 0 3720 3720 Regular

SERVICE DETAILS (Small General On-Site Generation Schedule 08)
Service Charge $5.00
Summer Energy Charge 800 kWh @ $0.086518 per kWh $69.21
Summer Energy Charge 1,200 kWh @ $0.104033 per kWh $124.84
Summer Energy Charge 2 kWh @ $0.123585 per kWh $0.25
Power Cost Adjustment $41.90
Fixed Cost Adjustment $8.81
Franchise Fee 1.50% Paid to Your City $2.32
Energy Efficiency Services $7.74
Federal Columbia River Benefits Supplied by BPA -$5.07
Off-Peak Credit 3,348 kWh @-$0.0244 per kWh -$81.98
On-Peak Credit 372 kwh @-$0.0314 per kWh -$11.30
Carry Forward Generation Credit -$3.31
Current Charges - Electric Service $158.41
NOTE: For an explanation of these charges, go to idahopower.com/billglossary.
To view hourly data, go to idahopower.com/myaccount.
kWh = Kilowatt-hour
Generation Credit Carry Forward $3.31
Generation Credit This Period: $93.28
Off-Peak $81.98
On-Peak $11.30
Generation Credit Applied This Period - $96.59
Generation Credit Remaining Balance $0.00
Small General NON-Legacy after
the first year. (No kWh credit
balance, unless customer
transferred kWh credits from a
Legacy system.)
5/28/23-6/27/23 (30 days)
7/28/2023

BEFORE THE

IDAHO PUBLIC UTILITIES COMMISSION

CASE NO. IPC-E-23-14

IDAHO POWER COMPANY

ATTACHMENT 3

RESPONSE TO STAFF REQUEST NO. 9

Meter Number
Line
Description Beginning Readings Ending Readings (kWh) Energy Used (kWh) Billing kW
Basic Load
Capacity Reading Type
12345678 Energy Used 0 3481 3481 102 157 Regular
12345678 Excess
Generation 0 10720 10720 102 157 Regular

SERVICE DETAILS (Lg General 09SB Net Meter Svc Schedule 84)
Service Charge $16.00
Summer Demand Charge (0-20) 20 @ $0.00 per kW $0.00
Summer Demand Charge (Over 20) 82 @ $6.06 per kW $496.92
Basic Charge (0-20) 20 @ $0.00 per kW of BLC $0.00
Basic Charge (Over 20) 137 @ $1.03 per kW of BLC $141.11
Summer Energy Charge 2,000 kWh @ $0.105250 per kWh $210.50
Summer Energy Charge 1,481 kWh @ $0.048716 per kWh $72.15
Power Cost Adjustment $2.83
Franchise Fee 1.00% Paid to Your City $1.43
Energy Efficiency Services $25.76
Federal Columbia River Benefits Supplied by BPA -$12.59
Off- Peak Credit 9,000 kWh @ -$0.0491 per kWh -$441.90
On-Peak Credit 1,720 kWh @ -$0.204221 per kWh -$351.26
Generation Credit Applied -$3.31
Current Charges - Electric Service $157.67

NOTE: For an explanation of these charges, go to idahopower.com/billglossary.
To view hourly data, go to idahopower.com/myaccount.
kWh = Kilowatt-hour G = Exported Generation

Customer Generation kWh Credit Balance 0

Generation Credit Carry Forward $3.31
Generation Credit This Period: $793.16
Off-Peak -$441.90
On-Peak - $351.26
Generation Credit Applied This Period - $796.47
Generation Credit Remaining Balance $0.00

Meter Number
Line
Description Beginning Readings Ending Readings (kWh) Energy Used (kWh) Billing kW
Basic Load
Capacity Reading Type
12345678 Energy Used 0 3481 3481 102 157 Regular
12345678 Excess
Generation 0 10720 10720 102 157 Regular

SERVICE DETAILS (Lg General 09SB Net Meter Svc Schedule 84)
Service Charge $16.00
Summer Demand Charge (0-20) 20 @ $0.00 per kW $0.00
Summer Demand Charge (Over 20) 82 @ $6.06 per kW $496.92
Basic Charge (0-20) 20 @ $0.00 per kW of BLC $0.00
Basic Charge (Over 20) 137 @ $1.03 per kW of BLC $141.11
Summer Energy Charge 2,000 kWh @ $0.105250 per kWh $210.50
Summer Energy Charge 1,481 kWh @ $0.048716 per kWh $72.15
Power Cost Adjustment $2.83
Franchise Fee 1.00% Paid to Your City $1.43
Energy Efficiency Services $25.76
Federal Columbia River Benefits Supplied by BPA -$12.59
Off- Peak Credit 9,000 kWh @ -$0.0491 per kWh -$441.90
On-Peak Credit 1,720 kWh @ -$0.204221 per kWh -$351.26
Generation Credit Applied -$3.31
Current Charges - Electric Service $157.67

NOTE: For an explanation of these charges, go to idahopower.com/billglossary.
To view hourly data, go to idahopower.com/myaccount.
kWh = Kilowatt-hour G = Exported Generation

Generation Credit Carry Forward $3.31
Generation Credit This Period: $793.16
Off-Peak -$441.90
On-Peak - $351.26
Generation Credit Applied This Period - $796.47
Generation Credit Remaining Balance $0.00

BEFORE THE

IDAHO PUBLIC UTILITIES COMMISSION

CASE NO. IPC-E-23-14

IDAHO POWER COMPANY

ATTACHMENT 4

RESPONSE TO STAFF REQUEST NO. 9
Name
For an explanation of these charges, go to idahopower.com/billglossary.NOTE:
Name
For an explanation of these charges, go to idahopower.com/billglossary.NOTE:

BEFORE THE

IDAHO PUBLIC UTILITIES COMMISSION

CASE NO. IPC-E-23-14

IDAHO POWER COMPANY

ATTACHMENT 5

RESPONSE TO STAFF REQUEST NO. 9
Name
For an explanation of these charges, go to idahopower.com/billglossary.NOTE:
Name
For an explanation of these charges, go to idahopower.com/billglossary.NOTE:

BEFORE THE

IDAHO PUBLIC UTILITIES COMMISSION

CASE NO. IPC-E-23-14

IDAHO POWER COMPANY

ATTACHMENT 6

RESPONSE TO STAFF REQUEST NO. 9
Name
For an explanation of these charges, go to idahopower.com/billglossary.NOTE:
Name
For an explanation of these charges, go to idahopower.com/billglossary.NOTE:

BEFORE THE

IDAHO PUBLIC UTILITIES COMMISSION

CASE NO. IPC-E-23-14

IDAHO POWER COMPANY

ATTACHMENT 7

RESPONSE TO STAFF REQUEST NO. 9