20231003IPC to Vote Solar 1-19.pdf

MEGAN GOICOECHEA ALLEN
Corporate Counsel
[e-mail]

October 3, 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 Vote Solar’s
First Production Request in the above-entitled matter.

Due to the collectively voluminous confidential and non-confidential information
provided in response to data requests in this case, the Company is posting the
attachments to these requests to the secure FTP site to allow parties to view the
requested information remotely unless otherwise noted in the response. Because certain
attachments contain confidential information, the FTP site is divided between confidential
and non-confidential information.

The login information for the non-confidential portion of the FTP site was provided
to all parties that have intervened and the login information for the confidential portion of
the FTP site was provided to the parties that execute the Protective Agreement in this
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
2023 OCTOBER 3, 2023 4:12PM
IDAHO PUBLIC
UTILITIES COMMISSION

CERTIFICATE OF ATTORNEY

ASSERTION THAT INFORMATION CONTAINED IN AN IDAHO PUBLIC UTILITIES
COMMISSION FILING IS PROTECTED FROM PUBLIC INSPECTION

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

The undersigned attorney, in accordance with Commission Rules of Procedure 67,
believes that the Attachment to Request No. 19 of Idaho Power Company’s Response to
the First Production Request of Vote Solar, dated October 3, 2023, contains information
that Idaho Power Company considers proprietary business information and a trade secret
as described in Idaho Code § 74-101, et seq., and/or § 48-801, et seq. As such, it is
protected from public disclosure and exempt from public inspection, examination, or
copying.

DATED October 3, 2023.

Megan Goicoechea Allen
Counsel for Idaho Power Company

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF VOTE
SOLAR - 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 THE FIRST
PRODUCTION REQUEST OF
VOTE SOLAR TO IDAHO POWER
COMPANY

COMES NOW, Idaho Power Company (“Idaho Power” or “Company”), and in
response to the First Production Request of Vote Solar dated September 12, 2023,
herewith submits the following information:

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF VOTE
SOLAR - 2
VOTE SOLAR’S REQUEST FOR PRODUCTION NO. 1: Please provide Idaho
Power’s hourly total system load for every hour in the years 2018 through 2022.
Alternatively, please provide a list of the top 10% of hours during which Idaho Power
experienced the highest electricity demand, ranked by system load, for each year from
2018 through 2022.
RESPONSE TO VOTE SOLAR’S REQUEST FOR PRODUCTION NO. 1: Please
see the Excel file labeled “Attachment – Response to Vote Solar Request No. 1” for Idaho
Power’s hourly total system load for every hour in the years 2018 through 2022.
Please note that this hourly data does not incorporate the reduction of load due to
Idaho Power’s demand response programs. Due to the increased variable and energy-
limited resource penetration that has occurred on the system in recent years, Idaho Power
has shifted away from planning to the highest peak hour and instead now assesses the
highest-risk hours which are dependent on load net of renewables and battery storage
projects.
The response to this Request is sponsored by Jordan Prassinos, Load Forecast
Manager and Principal Economist, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF VOTE
SOLAR - 3
VOTE SOLAR’S REQUEST FOR PRODUCTION NO. 2: Regarding Idaho
Power’s customers with rooftop solar:
(a) Please provide the number of customers with rooftop solar who also have battery
storage, broken out by rate schedule;
(b) Please provide the total capacity of battery storage installed by customers with
rooftop solar, broken out by rate schedule.
RESPONSE TO VOTE SOLAR’S REQUEST FOR PRODUCTION NO. 2: Please
see Response to Staff’s Request for Production No. 37.
The response to this Request is sponsored by Grant T. Anderson, Regulatory
Consultant, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF VOTE
SOLAR - 4
VOTE SOLAR’S REQUEST FOR PRODUCTION NO. 3: Does Idaho Power
currently have any programs or rate schedules intended to incentivize customers with
behind-the-meter battery storage to dispatch their storage to provide energy to the grid?
If so, please describe the relevant programs or rate schedules.
RESPONSE TO VOTE SOLAR’S REQUEST FOR PRODUCTION NO. 3: Idaho
Power does not currently have any programs intended to incentivize customers with
behind-the-meter battery storage to dispatch their storage to provide energy to the grid.
The response to this Request is sponsored by Grant T. Anderson, Regulatory
Consultant, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF VOTE
SOLAR - 5
VOTE SOLAR’S REQUEST FOR PRODUCTION NO. 4: Please provide Idaho
Power’s total annual retail sales to all customers for the years 2018, 2019, 2020, 2021,
and 2022.
RESPONSE TO VOTE SOLAR’S REQUEST FOR PRODUCTION NO. 4: Idaho
Power’s total annual retail sales to all customers for the years 2018, 2019, 2020, 2021,
and 2022 are included below in megawatt-hours (“MWh”).
Year 2018 2019 2020 2021 2022
Total Annual Retail Sales (MWh) 14,587 14,537 14,828 15,406 15,822
The response to this Request is sponsored by Darren Wallace, Accounting and
Reporting Director, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF VOTE
SOLAR - 6
VOTE SOLAR’S REQUEST FOR PRODUCTION NO. 5: Has Idaho Power
completed a load forecast more recent than Appendix A: Sales & Load Forecast,
presented as part of Idaho Power’s 2021 Integrated Resource Plan? If yes, please
provide Idaho Power’s most recent forecast of future load.
RESPONSE TO VOTE SOLAR’S REQUEST FOR PRODUCTION NO. 5: Yes,
Idaho Power completed a load forecast for Appendix A: Sales & Load Forecast, presented
as part of Idaho Power’s 2023 Integrated Resource Plan filed in Case No. IPC-E-23-23.
The forecast of future load for years 2024 through 2043 has been provided in the Excel
file labeled “Attachment – Response to Vote Solar Request No. 5.”
The response to this Request is sponsored by Jordan Prassinos, Load Forecast
Manager and Principal Economist, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF VOTE
SOLAR - 7
VOTE SOLAR’S REQUEST FOR PRODUCTION NO. 6: Is Idaho Power aware of
any instances where a rooftop solar installation that met all interconnection requirements
resulted in power quality or safety issues to the grid, or required Idaho Power to complete
repair or replacement of any utility grid infrastructure? If so, please provide the date(s) of
each known instance and describe the nature of the issue(s).
RESPONSE TO VOTE SOLAR’S REQUEST FOR PRODUCTION NO. 6: Idaho
Power is aware of one instance as described. The specific case was a commercial
customer’s rooftop solar installation that damaged their meter base, causing it to melt,
which then damaged the Company’s meter. That event occurred in July 2023.
The response to this Request is sponsored by Bryan Hobson, Engineering Leader,
Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF VOTE
SOLAR - 8
VOTE SOLAR’S REQUEST FOR PRODUCTION NO. 7: Regarding the direct
testimony of Connie Aschenbrenner, filed May 1, 2023, page 9 lines 23 through 25, which
states “Company representatives continue to hear from customers who have made
investments or who are considering investments that they were unaware that the structure
could change:”
(a) In what manner has Idaho Power learned that customers are unaware that the
structure could change? For example, are customers contacting the Company?
(b) Has Idaho Power conducted any surveys of, or outreach to, non-legacy solar
customers to determine the number or percentage of customers who are aware
that their rate may change?
RESPONSE TO VOTE SOLAR’S REQUEST FOR PRODUCTION NO. 7:
(a) The Company has heard from customers that call Idaho Power that their solar
installer did not make them aware that the structure could change. Additionally, a
number of public comments in Case Nos. IPC-E-22-22 and IPC-E-23-14 claim that
they were unaware that the structure could change.
(b) The Company has not conducted surveys specifically to non-legacy customers.
However, please see the Response to Vote Solar’s Request for Production No. 8
for details on how the Company has thoroughly communicated that the net
metering structure is likely to change.
The response to this Request is sponsored by Connie G. Aschenbrenner, Rate
Design Senior Manager, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF VOTE
SOLAR - 9
VOTE SOLAR’S REQUEST FOR PRODUCTION NO. 8: Regarding the direct
testimony of Connie Aschenbrenner, filed May 1, 2023, page 36:
(a) Please provide copies of all communication materials referenced in Table 3.
(b) Does Table 3 include all communication materials the Company has sent to non-
legacy customers addressing the potential for changes to their rates?
(c) If Table 3 does not include all communication materials sent to non-legacy
customers addressing the potential for changes to their rates, please provide
copies of any materials that are not included in Table 3.
(d) Has Idaho Power provided any materials to non-legacy customers that include
information about factors the customer should consider in light of the guidance that
rates may change in the future? For example, has Idaho Power provided
recommendations about how customers may want to size their system, or orient
their system to maximize value under a new rate?
RESPONSE TO VOTE SOLAR’S REQUEST FOR PRODUCTION NO. 8: Please
see the following responses:
(a) Please see the following for communication materials referenced in Table 3:
 October 2019: The Residential Solar Energy System Disclosure Act is publicly
available.1
 December 2019: Commission Order No. 34509 is publicly available.2
 January 2020: Please see the file labeled “Attachment 1 – Response to Vote
Solar Request No. 8” for the Idaho Power Customer Generation Application.

1 https://legislature.idaho.gov/wp-content/uploads/sessioninfo/2019/legislation/S1182.pdf
2 In the Matter of the Petition of Idaho Power Company to Study the Costs, Benefits, and Compensation
of Net Excess Energy Supplied by Customer On-Site Generation, Case No. IPC-E-18-15, Order No.
34509 (Dec. 20, 2019).

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF VOTE
SOLAR - 10
 January 2020: Please see the file labeled “Attachment 2 – Response to Vote
Solar Request No. 8” for examples of the Company’s email communication to
prospective customers.
 February 2020: Commission Order No. 34546 is publicly available.3
 December 2020: Commission Order No. 34854 is publicly available.4
 January 2021: Commission Order No. 34892 is publicly available.5
 June 2021: Please see the file labeled “Attachment 3 – Response to Vote Solar
Request No. 8” for the bill insert.
 December 2021: Commission Order No. 35284 is publicly available.6
 June 2022: Please see the file labeled “Attachment 4 – Response to Vote Solar
Request No. 8” for the press release and bill insert.
 December 2022: Commission Order No. 35631 is publicly available.7
 January 2023: Commission Order No. 35667 is publicly available.8

3 In the Matter of the Petition of Idaho Power Company to Study the Costs, Benefits, and Compensation
of Net Excess Energy Supplied by Customer On-Site Generation, Case No. IPC-E-18-15, Order No.
34546 (Feb. 5, 2020).

4 In the Matter of the Petition of Idaho Power Company for Authority to Modify Schedule 84’s Metering
Requirement and to Grandfather Existing Customers with Two Meters, Case No. IPC-E-20-26, Order No.
34854 (Dec. 1, 2020).

5 In the Matter of the Petition of Idaho Power Company for Authority to Modify Schedule 84’s Metering
Requirement and to Grandfather Existing Customers with Two Meters, Case No. IPC-E-20-26, Order No.
34892 (Jan. 14, 2021).

6 In the Matter of the Petition of Idaho Power Company to Initiate a Multi-Phase Collaborative Process for
the Study of Costs, Benefits, and Compensation of Net Excess Energy Associated with Customers On-
Site Generation Case No. IPC-E-21-21, Order No. 35284 (Dec. 30, 2021).

7 In the Matter of the Petition of Idaho Power Company to Complete the Study Review Phase of the
Comprehensive Study of Costs and Benefits of On-Site Customer Generation & For Authority to
Implement Changes to Schedules 6, 8, and 84, Case No. IPC-E-22-22, Order No. 35631 (Dec. 19, 2022).

8 In the Matter of the Petition of Idaho Power Company to Complete the Study Review Phase of the
Comprehensive Study of Costs and Benefits of On-Site Customer Generation & For Authority to
Implement Changes to Schedules 6, 8, and 84, Case No. IPC-E-22-22, Order No. 35667 (Jan. 19, 2022).

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF VOTE
SOLAR - 11
(b) No, the table is only an overview and was not intended to be an exhaustive list
inclusive of all communication materials provided to customers with non-legacy
systems.
(c) In addition to the materials mentioned in Table 3, the Company also provided the
following communication materials to all customers not granted legacy status by
the Commission as well all prospective customers with pending applications for
non-legacy systems:
 July 2022: Please see the file labeled “Attachment 5 – Response to Vote Solar
Request No. 8” for a copy of the letter sent to customers with non-legacy
systems regarding Case No. IPC-E-22-22.
 May 2023: Please see the file labeled “Attachment 6 – Response to Vote Solar
Request No. 8” for a copy of the letter sent to customers with non-legacy
systems regarding Case No. IPC-E-23-14.
 General/Other Communication: Please see the file labeled “Attachment 7 –
Response to Vote Solar Request No. 8” for a copy of the email sent to
customers when the interconnection process is completed. The Company also
provides customers with information online at the Company’s website with
content found here: www.idahopower.com/customergeneration.
(d) Yes, Idaho Power provides resources to customers considering the installation of
solar on its website here: www.idahopower.com/solar. Throughout the website are
reminders that the on-site generation tariff schedules are subject to change.
Additionally, there are links to other resources to evaluate potential production
such as the National Renewable Energy Laboratory’s PV Watts®9 and information
on how customers can download their monthly or hourly energy usage through

9 https://pvwatts.nrel.gov/

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF VOTE
SOLAR - 12
Idaho Power’s MyAccount.10 Below is a summary providing an example of the
resources Idaho Power’s website provides to its customers:
 Understanding Customer Generation: This page provides general information
regarding on-site generation, grandfathering or legacy status details,
information on relevant open dockets, interconnection requirements, customer
eligibility information, and other general details.11
 Apply to Connect Your System: This page provides information for customers
that are ready to install solar panels or modify an existing on-site generation
system. This page also provides a reminder regarding potential changes to the
billing structure and compensation structure and provides a link to the Idaho
Residential Energy System Disclosure Act.12
 Beware of Misinformation and Scams: This page provides tips to help
customers spot misrepresentation and educate themselves on the solar
marketplace. Additionally, this page links to other resource pages on the
Company’s website.13
 Investing in Solar: This page highlights the expectation that the billing and
compensation structure are expected to change. There is also an illustrative
example for a residential customer comparing the current compensation
structure and payback with what the Company has proposed under real-time
net billing.14
 Pick the Right Solar Installer: This page provides tips for choosing a solar
installer and includes a link to Idaho Residential Disclosure Act.15
 Frequently Asked Questions: Idaho Power’s customer generation FAQs page
includes over 50 questions about installing on-site generation and Idaho’s
current interconnection tariffs. This page includes questions about estimating
system size, physical size of solar arrays, factors that impact production,
accessing hourly energy use data as well as information about the current rules
and relevant open dockets (e.g., Case No. IPC-E-23-14).16

10 www.idahopower.com/myaccount
11 https://www.idahopower.com/energy-environment/green-choices/solar-power-options-customer-
generation/customer-generation/
12 https://www.idahopower.com/energy-environment/green-choices/solar-power-options-customer-
generation/apply-to-connect-your-system/
13 https://www.idahopower.com/energy-environment/green-choices/solar-power-options-customer-
generation/beware-of-misinformation-and-scams/
14 https://www.idahopower.com/energy-environment/green-choices/solar-power-options-customer-
generation/investing-solar/
15 https://www.idahopower.com/energy-environment/green-choices/solar-power-options-customer-
generation/tips-for-choosing-a-solar-installer/
16 https://www.idahopower.com/energy-environment/green-choices/solar-power-options-customer-
generation/frequently-asked-questions/

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF VOTE
SOLAR - 13
 Solar Checklist: Idaho Power provides this resource to help customers
research their options, suggests information to consider, questions to ask
prospective solar installers, and other general resources.17
The response to this Request is sponsored by Connie G. Aschenbrenner, Senior
Rate Design Manager, and Patti Best, Senior Program Specialist, Idaho Power
Company.

17 https://docs.idahopower.com/pdfs/BusinessToBusiness/SolarChecklist.pdf

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF VOTE
SOLAR - 14
VOTE SOLAR’S REQUEST FOR PRODUCTION NO. 9: Regarding the direct
testimony of Grant Anderson, filed May 1, 2023, page 26, lines 12 through 15 which
states: “For residential and small general service customers, Idaho Power plans to
provide its customers access to a third-party calculator tool on Idaho Power’s website.”
(a) Does Idaho Power intend to develop the calculator itself, or through a third-party?
(b) If Idaho Power intends to engage a third-party, has that entity been selected?
(c) When does Idaho Power expect that the calculator will be operational and available
to customers?
RESPONSE TO VOTE SOLAR’S REQUEST FOR PRODUCTION NO. 9: Please
see the following responses regarding a third-party calculator tool:
(a) Idaho Power is developing the tool through a third-party.
(b) Yes, the third-party has been selected.
(c) Idaho Power plans for the calculator to be operational and available to customers
on January 1, 2024. However, to the extent that the final service offering differs
from what has been proposed in the Application, there could be delays in
implementation.
The response to this Request is sponsored by Grant T. Anderson, Regulatory
Consultant, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF VOTE
SOLAR - 15
VOTE SOLAR’S REQUEST FOR PRODUCTION NO. 10: Regarding Idaho
Power’s “Time of Day” Plan:
(a) What types of customers are eligible to participate in the Time of Day plan?
(b) How many customers are currently participating in the Time of Day plan? Please
provide the number of customers participating from each rate schedule, if
applicable.
(c) How many customers have enrolled in the Time of Day plan and subsequently
requested to return to the Residential Standard Plan?
(d) What outreach or education has Idaho Power provided to customers to help them
understand how the Time of Day Plan works?
RESPONSE TO VOTE SOLAR’S REQUEST FOR PRODUCTION NO. 10: Please
see the following responses regarding Idaho Power’s Schedule 5, Residential Service
Time-of-Day Pilot Plan (“Schedule 5”):
(a) Service under Schedule 5 is available to residential customers pursuant to the
Availability and Applicability sections of the tariff schedule.
(b) As of June 30, 2023, there were 990 customers in Idaho taking service under
Schedule 5.
(c) Since 2005, there have been 880 customers that have enrolled to take service
under Schedule 5 and subsequently requested to return to Schedule 1, Residential
Service Standard Plan.
(d) The Company provides information on its website here for customers regarding
the Time-of-Day Plan: https://www.idahopower.com/accounts-service/understand-
your-bill/pricing/idaho-pricing/time-day-plan/. Customers can see an estimate of

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF VOTE
SOLAR - 16
their bill under the Time-of-Day plan through Idaho Power’s My Account tool. The
calculator uses actual historical data and assumes a certain amount of behavioral
change to evaluate potential savings.
The response to this Request is sponsored by Grant T. Anderson, Regulatory
Consultant, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF VOTE
SOLAR - 17
VOTE SOLAR’S REQUEST FOR PRODUCTION NO. 11: Regarding Idaho
Power’s 2023 Integrated Resource Plan:
(a) On what date does the Company anticipate filing the 2023 Integrated Resource
Plan?
(b) On what date does the Company anticipate regulators will rule on the 2023
Integrated Resource Plan?
RESPONSE TO VOTE SOLAR’S REQUEST FOR PRODUCTION NO. 11: Please
see the following responses regarding Idaho Power’s 2023 Integrated Resource Plan
(“IRP”):
(a) The Company filed its 2023 IRP with the Commission on September 29, 2023, in
Case No. IPC-E-23-23.
(b) Idaho Power will not have a case schedule for the 2023 IRP until after one is set
by the Commission. However, as a point of reference, the Company filed the 2021
IRP in December 2021 and the Commission’s order acknowledging that IRP was
issued 11 months later in November 2022 (Case No. IPC-E-21-43).
The response to this Request is sponsored by Alison Williams, Regulatory Policy
and Strategy Leader, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF VOTE
SOLAR - 18
VOTE SOLAR’S REQUEST FOR PRODUCTION NO. 12: Do Idaho Power
customers currently have access to information about their own hourly energy usage? If
so, please describe what data is available to customers and how customers are able to
access their hourly energy usage data.
RESPONSE TO VOTE SOLAR’S REQUEST FOR PRODUCTION NO. 12:
Customers can view their hourly, daily, and monthly energy usage through Idaho Power’s
customer web portal called My Account. Customers can view this data when they login to
My Account and navigate to the Usage page. The My Account functionality provides a
dropdown for customers to select how to view their usage, with the following options:
 Billed Use Compared to Last Year (Monthly usage and Billing information)
 Monthly Use with Temperatures
 Monthly Use Compared to Average Use
 Daily Use
 Daily Use with Temperatures
 Hourly Use
Please see the file labeled “Attachment 1 – Response to Vote Solar Request No. 12”
for screenshots of each usage view.
The response to this Request is sponsored by Ryan Donnelly, Customer
Experience Manager, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF VOTE
SOLAR - 19
VOTE SOLAR’S REQUEST FOR PRODUCTION NO. 13: Please describe the
cost methodology and components used to calculate avoided costs in Idaho Power’s
recently filed general rate case, IPC-E-23-11, as compared to the avoided cost
methodology and components used in the export credit rate (“ECR”) and this Application.
RESPONSE TO VOTE SOLAR’S REQUEST FOR PRODUCTION NO. 13:
Avoided costs are not at issue in Case No. IPC-E-23-11.
The response to this Request is sponsored by Connie G. Aschenbrenner, Rate
Design Senior Manager, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF VOTE
SOLAR - 20
VOTE SOLAR’S REQUEST FOR PRODUCTION NO. 14: Does the cost of service
study in Idaho Power’s recently filed general rate case, IPC-E-23-11, include any
assumptions related to the value of the ECR? If so, please describe.
RESPONSE TO VOTE SOLAR’S REQUEST FOR PRODUCTION NO. 14: No.
The cost-of-service study filed in Idaho Power’s general rate case, Case No. IPC-E-23-
11, includes allocation of base-level ongoing power supply costs incurred in the 2023 test
year. There is not an expense forecast in the 2023 test year period of the general rate
case for a net billing export credit.
As described in the testimony of Company Witness Grant T. Anderson, Idaho
Power is proposing to recover the cost of ECR expense through the Power Cost
Adjustment (“PCA”).18
The response to this Request is sponsored by Paul Goralski, Regulatory
Consultant, Idaho Power Company.

18 Case No. IPC-E-23-14, Anderson DI, p. 17.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF VOTE
SOLAR - 21
VOTE SOLAR’S REQUEST FOR PRODUCTION NO. 15: Is Idaho Power aware
of any other utilities that have an ECR value that is updated annually? If so, which utilities?
RESPONSE TO VOTE SOLAR’S REQUEST FOR PRODUCTION NO. 15: The
Company does not maintain a list of other utilities on-site generation service offerings.
The response to this Request is sponsored by Grant T. Anderson, Regulatory
Consultant, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF VOTE
SOLAR - 22
VOTE SOLAR’S REQUEST FOR PRODUCTION NO. 16: Is Idaho Power aware
of any other utilities that have an ECR that updates annually, and where the updated ECR
applies to both new and existing customers? If so, which utilities?
RESPONSE TO VOTE SOLAR’S REQUEST FOR PRODUCTION NO. 16: The
Company does not maintain a list of other utilities on-site generation service offerings.
The response to this Request is sponsored by Grant T. Anderson, Regulatory
Consultant, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF VOTE
SOLAR - 23
VOTE SOLAR’S REQUEST FOR PRODUCTION NO. 17: Please provide all load
research data available for Idaho Power’s non-legacy solar customers including hourly
usage data for 2021 and 2022. For each customer, please identify the rate schedule on
which the customer takes service, use a unique identifier and avoid providing any
personally identifying information. If available, please provide information on the installed
solar capacity associated with each non-legacy solar customer.
RESPONSE TO VOTE SOLAR’S REQUEST FOR PRODUCTION NO. 17: Please
see the file labeled “Attachment 1 – Response to Vote Solar Request No. 17” for the
requested data for 2021 and the file labeled “Attachment 2 – Response to Vote Solar
Request No. 17” for the requested data for 2022. The files include a unique customer
identifier, rate schedule, approved system size and both delivered/consumption and
received/exported hourly energy (kilowatt-hours). The customers represented are
currently active, non-legacy solar generation, and were active for the entirety of each
year.
Jordan Prassinos, Load Forecast Manager and Principal Economist, Idaho Power
Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF VOTE
SOLAR - 24
VOTE SOLAR’S REQUEST FOR PRODUCTION NO. 18: Please provide hourly
exports, in kilowatt-hours, for each non-legacy solar customer for all hours in 2021 and
2022. For each customer, please identify the rate schedule on which the customer takes
service, use a unique identifier and avoid providing any personally identifying information.
If available, please provide information on the installed solar capacity associated with
each non-legacy solar customer.
RESPONSE TO VOTE SOLAR’S REQUEST FOR PRODUCTION NO. 18: Please
see the response to Vote Solar’s Request for Production No. 17.
The response to this Request is sponsored by Jordan Prassinos, Load Forecast
Manager and Principal Economist, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF VOTE
SOLAR - 25
VOTE SOLAR’S REQUEST FOR PRODUCTION NO. 19: Please identify all fuel
hedging activities and expenditures (if any) by Idaho Power during each of the last ten
years. For each hedging product purchased in the last ten years, please provide the trade
date, start date, end date, price, volume, and any other information available regarding
the hedging product purchased.
RESPONSE TO VOTE SOLAR’S REQUEST FOR PRODUCTION NO. 19: Please
see the Excel file labeled “Confidential Attachment – Response to Vote Solar Request
No. 19” for a summary of all fuel hedging activities by Idaho Power for the period August
2013 to August 2023. Each tab in the attachment includes the following requested
information:
 Unique identifier
 Trade date
 Transaction type (i.e., sale or purchase)
 Start date
 End date
 Volume; power is in megawatts (“MW”) and gas is in million British thermal units
(“MMBTU”)
 Price (power is split between on peak and off-peak pricing)
The response to this Request is sponsored by Mike Marshall, Regulatory
Compliance & Risk Manager, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF VOTE
SOLAR - 26
DATED at Boise, Idaho, this 3rd day of October 2023.

MEGAN GOICOECHEA ALLEN
Attorney for Idaho Power Company

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF VOTE
SOLAR - 27
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on the 3rd day of October, 2023, I served a true and
correct copy of Idaho Power Company’s Response to the First Production Request of
Vote Solar 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 Callaway 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 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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IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF VOTE
SOLAR - 28
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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Jim Swier
Micron Technology, Inc.
8000 South Federal Way
Boise, Idaho 83707
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IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION REQUEST OF VOTE
SOLAR - 29
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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Christy Davenport
Legal Administrative Assistant