20200110Petition for Reconsideration.pdf

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an lDAcoRP company
January 10,2020
VIA HAND DELIVERY
Re: Case No. IPC-E-18-15
Study of Costs, Benefits, and Compensation of Net Excess Energy Supplied
by Customer On-Site Generation
ldaho Power Company's Petition for Reconsideration and/or Clarification
Dear Ms. Hanian:
Very truly yours,
LISA D. NORDSTROM
Lead Counsel
[e-mail]
LDN:kkt
Enclosures
RECEIVED
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Lisa D. Nordstrom
Diane Hanian, Secretary
ldaho Public Utilities Commission
11331 W. Chinden Boulevard
Building 8, Suite 201-A
Boise, ldaho 83714
Enclosed for filing in the above matter please find an original and seven (7) copies
of ldaho Power Company's Petition for Reconsideration and/or Clarification in the above
matter.
lf you have any questions about the enclosed documents, please do not hesitate to
contact me.
LISA D. NORDSTROM (lSB No. 5733)
ldaho Power Company
1221 West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: (208) 388$1 17
Facsimile: [phone]
lnordstrom@idahopower. com
. :t ON
Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION TO STUDY
THE COSTS, BENEFITS, AND
COMPENSATION OF NET EXCESS
ENERGY SUPPLIED BY CUSTOMER ON-
SITE GENERATION.
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CASE NO. tPC-E-18-15
IDAHO POWER COMPANY'S
PETITION FOR
RECONSIDERATION AND/OR
CLARIFICATION
IDAHO POWER COMPANY'S PETITION FOR
RECONSIDERATION AND/OR CLARIFICATION
RECEIVEO
.'0?0 JAN l0 Pt{ lr: I I
TABLE OF CONTENTS
I. BACKGROUND 5
A. Case No. IPC-E-17-'13 5
B. Case No. IPC-E-18-15.7
II. PETITION FOR N IDERATI N I
A. The Company Respectfully Requests the Commission Reconsider its
Decision to Reject the Proposed Settlement Agreement 10
1. The Parties Comprehensively Studied the lssues as the
Commission Directed and Filed the Analysis in the Evidentiary
Record................11
a
b
d
e
ldaho Power's lnitial Study 13
14Multiparty workshops
Developing an Export Credit Rate Calculation Methodology
The Final Export Credit Rate Study......
Other Compensation Structure Elements Addressed in the
.14
.17
Study Process 18
20f. Summary of Comprehensive Study Materials in the Record
2. The Public Received Adequate Notice that This Docket Might
Result in Fundamental Changes to the Net-Metering Program.
Regardless of this Fact, the Commission's Decision to Grandfather
Existing Customers Effectively Moots this lssue 22
B. ln the Alternative, the Company Respectfully Requests the
Commission Reconsider its Directive for an Entirely New On-site
Generation Study Process, instead Allowing the Company, lnterested
Parties, and the Public to Build on Extensive Work Performed to Date....26
The Company's Proposal
a. lmplement Net Hourly Billing During this lnterim Period
.27
.27
b. lnitiate a Value of Exported Energy Docket for All Customer
Classes 30
2. Streamlined Procedures Serve the Public lnterest
3. ldaho Power's Efforts to Reduce Confusion
.31
and Protect its
Customers4. Recommended Procedures on Reconsrderation
IDAHO POWER COMPANY'S PETITION FOR
RECONSIDERATION AND/OR CLARIFICATION - i
33
35
III. PETITION FOR CLARIFICATION 35
A. Possible Exceptions to the Utility Customer Relations Rules (''UCRR'')
Definition of "Customer"36
B. Order No. 34509 Provides Notice to ALL Customer Classes that
Compensation Structure May Change 37
C. Schedule 6 and 8 Rate Structures May Be Adjusted in a Future Rate
Case 38
tv. coNcLUstoN 38
IDAHO POWER COMPANY'S PETITION FOR
RECONSIDERATION AND/OR CLARIFICATION - ii
Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION TO STUDY
THE COSTS, BENEFITS, AND
COMPENSATION OF NET EXCESS
ENERGY SUPPLIED BY CUSTOMER ON-
SITE GENERATION,
CASE NO. IPC-E-18-15
IDAHO POWER COMPANY'S
PETITION FOR
RECONSIDERATION AND/OR
CLARIFICATION
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Following a year-long effort and challenging negotiations between parties with
strongly-held views, most parties reached a compromise to resolve longstanding and
contentious issues regarding ldaho Power Company's ("ldaho Power" or "Company") on-
site generation offering for residential and small general service customers. The ldaho
Public Utilities Commission ("Commission'') rejected this multiparty settlement in Order
No.34509, dated December20,2019, issued in Case No. IPC-E-18-15. The Commission
found there was insufficient evidence in the record that the parties had performed a
comprehensive study of these issues, as called for in a previous Commission order,l and
1 Order No. 34509 at 7-9 (Dec. 20, 2019)
IDAHO POWER COMPANY'S PETITION FOR
RECONSIDERATION ANDiOR CLARIFICATION - 1
LISA D. NORDSTROM (lSB No. s733)
ldaho Power Company
1221 West ldaho Street (83702)
P.O Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
lnordstrom@idahopower. com
also that members of the public had not received adequate notice this docket might result
in fundamental changes to the Company's on-site generation offering.2
Pursuant to Rules of Procedure 33, 325, and 331, et seq.,3 and ldaho Code $ 61-
626, ldaho Power petitions the Commission for reconsideration and clarification of final
Order No. 34509. The Company respectfully requests the Commission approve the
Settlement Agreement on reconsideration because evidence in the record supports that
the pa(ies did in fact conduct a comprehensive study. Having now read Order No. 34509,
the Company understands the Commission would have benefited from a narrative
presentation describing the detailed elements of this study to provide more context for
understanding and interpreting the results. ln filing this petition for reconsideration,
therefore, ldaho Power's intent is to assist the Commission's evaluation by discussing the
evidence provided in the record that supports the Settlement Agreement and, collectively,
comprises the comprehensive study requested by the Commission in Case No. IPC-E-
17-13.4
Evidence in the record also demonstrates that the public received adequate notice
regarding the potential for fundamental changes in this docket. Regardless of this fact,
the Commission's decision to grandfather existing customers effectively moots this issue.
ln the past, the Commission has made it clear to ldaho Power that it expects the
Company to timely inform the Commission of known potential problems that could
negatively impact customer rates before those problems become large and unduly
3 IDAPA 31.01.01.33; IDAPA 31.01.0 1.325; IDAPA 31.01.01.331, et seq
a ln the Matter of the Application of ldaho Power Co. for Authority to EstaDl,sh New Schedules for
Residential and Small General Service Customers with On-Site Generation, Case No. IPC-E- 17-1 3, Order
No. 34046, at22-23,31 (May 9, 2018).
IDAHO POWER COMPANY'S PETITION FOR
RECONSIDERATION AND/OR CLARIFICATION - 2
2 ld. at6
impactful.s This case complies with that guidance and presents a reasonable and fair
Settlement Agreement, that if implemented, would put in place a framework for mitigating
avoidable negative impacts to residential and small commercial customers' rates.
Rejection of the Settlement Agreement in this case not only impedes progress toward
addressing known issues with the compensation structure in the residential and small
commercial on-site generation classes, but has already stalled,6 and will likely continue
to stall, progress toward addressing similar issues in the large commercial, industrial, and
irrigation on-site generation service (Schedule 84). The Company believes the evidence
on the record supports approval of the Settlement Agreement which would result in timely
resolution of known problems, and therefore, asks the Commission to reconsider its
decision.
lf the Commission declines to reconsider its decision rejecting the Settlement
Agreement, then in the alternative, ldaho Power respectfully requests the Commission
reconsider the extensive procedures it has ordered for conducting an entirely new study
process. The Settlement Agreement is the product of a comprehensive study resulting
from a year-long collaborative process among the Company, Commission Staff ("Staff'),
and numerous intervening parties with diverse interests.T Over the course of conducting
s For example, "fl, we find it reasonable and prudent for the Company to closely monitor the net
metering service and to provide an annual appraisal of the service's status and impact on the reliability of
the Company's system. Further, we expect the Company to promptly notify us of any changes in the net
metering service that materially affect the system." Order No. 32846 at 7, Case No. IPC-E-12-27 (July 3,
2013)
6 On December 3, 2019, settlement discussions in Case No. IPC-E-19-15, ln the Matter of ldaho
Powels Application to Evaluate Schedule 84 - Net Meteing, had progressed to the point where parties
had agreed to begin drafting a settlement agreement. As direct a result of Order No. 34509, all discussions
and progress toward settlement in Case No. IPC-E-19-15 have stopped.
7 While all 13 parties participated in the settlement process, nine of those pa(ies ultimately signed
the Settlement Agreement. Those parties are collectively referred to in this petition as the "Signing Parties."
IDAHO POWER COMPANY'S PETITION FOR
RECONSIDERATION AND/OR CLARIFICATION . 3
this study, the participants analyzed and ultimately resolved numerous longstanding and
contentious issues regarding the administration of ldaho Power's on-site generation
service for residential and small general service customers.s The Company appreciates
the Commission's desire for additional public involvement and review but is concerned
the prescribed process will result in largely discarding thousands of hours of careful
analysis and deliberation. lnstead, ldaho Power requests an order on reconsideration
directing the Company to (1) file a recommendation in this docket to implement net hourly
billing for new Schedule 6 and Schedule 8 customers in a manner that ensures neutral
financial impact to those customers during this interim period, and (2) initiate a public
process to explore the appropriate value to be assigned to hourly exported energy from
non-g randfathered on-site generators. This proposed process will establish a clear
delineation between grandfathered and non-g randfathered customers and will implement
a bill presentation that more accurately reflects the actual amounts of customer energy
consumption and exported customer generation. The immediate implementation of net
hourly billing for new Schedule 6 and 8 customers will also build on the extensive work
performed to date, greatly narrow the scope of issues to be explored going forward, and
send a clear signal to solar installers and future participants that future changes are likely
to occur.
Regardless of the Commission's decision on reconsideration, if it is not the
Commission's intent for its decisions in this case to hinder progress toward settlement in
6 See Comments of Commission Staff in Support of Settlement Agreement, at 3 (Nov. 6, 20'19)
("[A]ll parties to the case worked diligently to reach compromise on the long list of complicated and
sometimes contentious issues. As a result, Staff believes that the solutions reached here are sound, robust,
and will preserve the right of customers to offset their electric consumption while holding all other customers
harmless.").
IDAHO POWER COMPANY'S PETITION FOR
RECONSIDERATION AND/OR CLARIFICATION - 4
Case No. IPC-E-19-15 ("19-15 Case") for customers taking net metering service under
Schedule 84, the Company respectfully requests that the Commission issue an order
explicitly stating such and direct parties to continue negotiations toward settlement in that
case.
Lastly, while ldaho Power is not requesting reconsideration of the Commission's
decision regarding grandfathering, to assist the Company in providing the grandfathered
customers with clear expectations going forward, the Company seeks clarification
regarding grandfathering as the Commission intended for it to be implemented and
ad m inistered.
I. BACKGROUND
A. Case No. IPC-E-17-13
On July 27,2017,ldaho Power applied for authority to establish new schedules for
residential and small general service customers with on-site generation, initiating Case
No. IPC-E-17-13. ldaho Power explained that its existing retail pricing structure did not
accurately reflect the cost to serve its on-site generation customers, who require services
from the Company but also meet some of their energy needs with on-site, customer-
owned systems such as rooftop solar.
On May 9, 2018, the Commission issued Order No. 34046. The Commission found
it was "time to distinguish a class of customers that uses the grid for standard energy
import and use, from a class of customers that uses the grid to both import and export
energy."s The Commission explained that its "analysis of the history of the Company's
on-site generation service reveals an unfairness in how current and future on-site
e Order No. 34046, at 16 (May 9,2018)
IDAHO POWER COMPANY'S PETITION FOR
RECONSIDERATION AND/OR CLARIFICATION - 5
generation customers avoid fixed costs[,]" because "[t]he ability these customers have to
'net out' or net to zero their electricity use causes them to underpay their share of the
Company's fixed costs to serve customers, and this inequity will only increase as more
customers choose on-site generation."l0 Further, the Commission observed that a "bi-
directional" on-site generation customer "can push energy back to the grid whenever its
generation source and timing allows it to, with the Company having limited control over
the use and distribution of this somewhat unpredictable resource."ll This results in "load
and usage characteristics" that are unique to on-site generation customers, including
"increased volatility in demand and load factors, excess net-energy exportation in the
spring and summer, and more volatility in contributions to the Company's peak(s)." The
Commission observed that these characteristics affect "circuits, voltage management,
islanding, and load cycle adjustments," making it more difficult for ldaho Power "to
forecast resource availability and load." Based on these distinguishing class
characteristics shared by on-site generators who export to the grid, the Commrssion
granted ldaho Power's request to separate on-site generation residential customers and
small general service customers into newly-proposed Schedules 6 and 8, respectively.
ln Case No. IPC-E-17-'13, ldaho Power did not request - and the Commission did
not order - any immediate changes in ratemaking treatment for on-site generation
customers. Nevertheless, the Commission did express significant concern that ldaho
Power's customers may currently be receiving price signals regarding on-site generation
1o Order No. 34046 at 16-17
11 Order No. 34046 at 18.
IDAHO POWER COMPANY'S PETITION FOR
RECONSIDERATION AND/OR CLARIFICATION - 6
investment from the industry that are "not in the public interest."12 The Commission
observed that "incorrect price signals related to rate or rate design changes may be
trivialized[,]" notwithstanding the fact that "[r]ates change, . . , rate design evolves, and no
utility rate can be locked or considered to exist ad infinitum[,]" since "tariff rates are not
contracts."13
Therefore, the Commission directed ldaho Power to initiate a new docket to
conduct a comprehensive study of the costs and benefits of on-site generation on the
Company's system, as well as proper rates and rate design, transitional rates, and related
issues of compensation for net excess energy provided as a resource to ldaho Power.
The Commission also determined it was "time for the Company to address fixed-cost
apportionment across its system"14 and directed the Company to "file a study with the
Commission exploring fixed-cost recovery in basic charges and other rate design options
prior to its next general rate case."15
The Commission stated that "current and prospective on-site generators will be
better positioned to analyze the costs and benefits of buying, installing, and maintaining
an on-site generation system as a result of this Order."
B. Case No. IPC-E-18-15
On October 19, 2018, ldaho Power petitioned to initiate Case No. IPC-E-18-15 to
comply with the Commission's directive in Order No. 34046. The ldaho Conservation
12 Order No. 34046 at 19.
13 ld.
11 Order No. 34046 at 17. Case No. IPC-E-18-15 was opened to fulfill this directive
15 /d. at 31. Case No. IPC-E-18-16 was opened to fulfill this directive.
IDAHO POWER COMPANY'S PETITION FOR
RECONSIDERATION AND/OR CLARI FICATION . 7
League ("lCL"), ldaho lrrigation Pumpers Association, lnc. ("llPA"), ldaho Hydroelectric
Power Producers Trust ("ldaHydro"), Rocky Mountain Power, Vote Solar, the City of
Boise City ("City of Boise"), ldaho Clean Energy Association, lnc. ("|CEA'), ldaho Sierra
Club, Northwest Energy Coalition (.NWEC), Micron Technology, lnc. ("Micron"),
lndustrial Customers of ldaho Power ("lClP"), and Russel Schiermeier (collectively, "the
lntervenors") intervened as parties in this docket. Per direction from the Commission,
Staff conferred with ldaho Power and the intervenors regarding the procedural and
substantive scope of the docket.l6 ln total, the parties held one prehearing conference
and eight settlement conferences.lT During the course of this collaborative process, Staff
kept the Commission apprised with three consecutive status reports.ls The process
culminated in a Settlement Agreement filed with the Commission on October 11,2019,
thatwas signed by ldaho Power, Staff, llPA, ldaHydro, City of Boise, ldaho Sierra Club,
ICEA, lClP, and Russell Schiermeier ("the Signing Parties"). ln the Settlement
Agreement, the Signing Parties recommended net hourly billing for netting exports and
consumption within the hour, with on-site generation customers compensated for net
hourly exports at an Export Credit Rate,le The Settlement Agreement also establishes a
methodology for calculating this Export Credit Rate, to be updated biennially as part of
16 Order No. 34189 at 1 (Nov. 9, 2018).
17 Staff Decision Memo at 2 (Oct. 1 1 , 2019).
18 Staff Report (Feb. 28, 2019) ("First Staff Report"); Second Staff Report (May 28, 2019); Third
Staff Report (Aug. 28, 2019).
1e Motion to Approve Settlement Agreement and Settlement Agreement, Att. 'l at 2 (Oct. 1 1 , 2019)
IDAHO POWER COMPANY'S PETITION FOR
RECONSIDERATION AND/OR CLARIFICATION - 8
ldaho Power's lntegrated Resource Planning ("lRP") process, and a phased schedule for
implementing the Export Credit Rate over an eighlyear transition period.20
On December 20, 2019, the Commission issued Order No. 34509 "finding the
record is inadequately developed to make a determination as to whether the Settlement
Agreement is fair, just, reasonable, and in the public interest."21 The Commission's Order
also grandfathers existing customers under the rules in place as of the service date of the
Order.2z As of December 20,2019, ldaho Power has 5,010 active customers with on-
site generation taking service under Schedules 6 and 8 with 36.743 megawatts ("MW") of
generation capacity. An additional 454 applications with 4.078 MW of generating capacity
were pending completion.
II. PETITION FOR RECONSIDERATION
7o ld. at2-5.
21 Order No. 34509 at 6
22 ld. al 1O-15.
23 Washington Water Power Co. v. Kootenai Environmental Alliance,99 ldaho 875, 879, 591 P.2d
122, 126 (1979\: see also Eagle Water Company v. ldaho PUC, 130 ldaho 314,317,940P.2d 1133, 1136
(1997).
IDAHO POWER COMPANY'S PETITION FOR
RECONSIDERATION AND/OR CLARIFICATION . 9
The Commission has the authority to grant or deny reconsideration under ldaho
Code $ 61-626(2). Reconsideration provides an opportunity for any interested person to
bring to the Commission's attention any question previously determined, and thereby
affords the Commission an opportunity to rectify any mistake or omission.23 Consistent
with the purpose for reconsideration, Commission rules require a petition for
reconsideration to "set forth specifically the ground or grounds why the petitioner
contends that the order or any issue decided in the order is unreasonable, unlaMul,
erroneous or not in conformity with the law1.1"za
Order No. 34509 overlooks evidence in the record of the collaborative,
comprehensive Export Credit Rate study performed by parties at the Commission's
request, as well as substantial public notice of the study and settlement process.
Consequently, ldaho Power requests the Commission reconsider its rejection of the
Settlement Agreement or, in the alternative, its creation of a new process that does not
build upon the parties' efforts to study the issues thus far.
A. The Company Respectfully Requests the Commission Reconsider its
Decision to Reiect the Proposed Settlement Agreement.
The Commission rejected the Settlement Agreement, finding that "filing the
Settlement Agreement in the absence of a comprehensive study does not comply with
our directive to parties in Order No. 34046."25 The Commission also concluded that ''the
public was not adequately notified this docket might result in a significant change to the
Company's net-metering service structure."26 As demonstrated below, however, the
Settlement Agreement was in fact supported by a comprehensive study - initially
performed by ldaho Power, and later, revised in the collaborative process - and this
information establishes both that a comprehensive study was performed and that the
public received ample notice of the potential for significant structural changes to the net
24 IDAPA 31.01 .01.331.01. under Rule 331, the petition must also provide information regarding
"the nature and quantity of evidence or argument the petitioner will offer if reconsideration is granted[,]" rd.,
and "whether the petitioner . . . requests reconsideration by evidentiary hearing, written briefs, comments,
or interrogatories.' IDAPA 31.01 .01.331.02.
25 Order No. 34509 at 6
26 ld
IDAHO POWER COMPANY'S PETITION FOR
RECONSIDERATION AND/OR CLARIFICATION . 1O
metering service. ln light of this information, it is in the public interest to approve the
Settlement Agreement, which is the product of a comprehensive study resulting from
thousands of hours of careful and deliberative work during a year-long collaborative
process among the Company, Staff, and numerous intervening parties-
1. The Parties Comprehensively Studied the lssues as the Commission
Directed and Filed the Analysis in the Evidentiary Record.
ln Order No. 34046, the Commission directed the Company to ''initiate a docket to
comprehensively study the costs and benefits of on-site generation on ldaho Power's
system, as well as proper rates and rate design, transitional rates, and related issues of
compensation for net excess energy provided as a resource to the Company."27 ln
compliance with this directive, ldaho Power petitioned the Commission to initiate Case
No. IPC-E-18-1 5 and conducted an initial comprehensive study addressing on-site
generation ("lnitial Study"). This lnitial Study served as the foundation for analysis and
input from other parties over the course of eight separate workshops. Through this
collaborative process involving 13 parties, ldaho Power agreed to make certain revisions
to the lnitial Study, and ultimately, nine different parties with diverse interests reached
agreement on (1) an acceptable methodology for evaluating costs and benefits to ldaho
Power's system from on-site generation, and (2) an appropriate compensation structure
for excess generation. These modifications were incorporated into a final study that
supports the value-based compensation terms in the Settlement Agreement ("Export
Credit Rate Study"). As described below, both the lnitial Study and the revised
components comprising the Export Credit Rate Study were filed with the Commission in
this docket and form part of the record for reconsideration. These studies, together with
27 Order No. 34046 at 31
IDAHO POWER COMPANY'S PETITION FOR
REGONSIDERATION AND/OR CLARIFICATION - 11
the compensation structure provisions documented in the Settlement Agreement itself,
fulfill the Commission's directive in Order No. 34046.
Having read Order No. 34509, ldaho Power acknowledges the benefit of hindsight
that a narrative presentation and a careful roadmap describing all of the elements of these
studies would have provided more context for the Commission and members of the public
who did not participate directly in the settlement process to understand and interpret the
results. The Company therefore supplies the following description to serve as the
foundation for a finding on reconsideration that the Signing Parties did in fact produce a
comprehensive study in fulfillment of the direction provided by the Commission in Order
No. 34046 and, thus, that the recommendations in the Settlement Agreement are
adequately supported and can be approved.
The information requested by the Commission in directing a comprehensive study
in Order No.34046 essentially falls into three main categories: (1)system impacts (that
is, costs and benefits); (2) rates and rate design; and (3) a compensation structure for
excess generation.2s The Settlement Agreement, the lnitial Study, and the Export Credit
Rate Study that were collectively filed in this docket address the first and third categories,
28 Order No. 34046 at 31. See a/so d at 22 (finding that "[a]ll parties to this case substantially
agreed there should be more analysis of how onsite generation customers are unique, including how their
usage characteristics affect costs and benefits, rates, and rate design[.]").
IDAHO POWER COMPANY'S PETITION FOR
RECONSIDERATION AND/OR CLARIFICATION . 1 2
namely, system impacts and compensation structure. The second category, proper rates
and rate design, is being addressed separately in Case No. IPC-E-18-16.2e
a. ldaho Power's lnitia! Study
The lnitial Study provided by ldaho Power addresses both system impacts and
compensation structure and consists of the following components:
A coslof-service study for on-site generation Schedules 6 and 8,30 which
was based on (i) a class cost-of-service study performed in the same
manner as those performed for general rate cases, and (ii) quantification of
the revenue deficiency that exists under both net monthly and net hourly
billing;31 and
A strawman proposed methodology for assigning value for net excess
energy for purposes of compensation, together with a summary of the
revenue impact associated with making this change.32
2e ln Order No. 34046, the Commission also directed the Company to "file a study with the
Commission exploring fixed-cost recovery in basic charges and other rate design options prior to its next
general rate case." Order 34046 at 31. On September 30, 2019, ldaho Power filed its Fixed Cost Report
in Case No. IPC-E-18-16, as directed, and a public comment period is currently underway. ln the Mafter
ot the Petition of ldaho Power Co. to Study Fixed Costs of Providing Electric Seruice fo Cuslomers, Case
No. IPC-E-18-16, Order No. 34466, at 2 (Oct.24,2019). The Company expects on-site generation cost-
of-service related matters and rate design to be addressed by the parties in their comments in that
proceeding, and ultimately, by the Commission upon reviewing the record in that case. ln this proceeding,
therefore, the Signing Parties determined it would be reasonable and consistent with the Commission's
intent to address issues of rate and rate design in Case No. IPC-E-18-16, because it is not practical or even
possible to consider cost of service for only one segment of customers. The exercise of developing a cos!
of-service study allocates a jurisdictionalized revenue requirement amongst classes, so the result of
determining a standalone customer class's revenue requirement and implementing changes accordingly
would almost certainly result in either over- or under-recovery of the overall revenue requirement.
Therefore, the Signing Parties determined the most efficient manner to address these issues and stay
consistent with the Commission's directives in Order No. 34046 was to study the costs of providing utility
services (as determined by a class cosfof-service study) and the appropriate rates and rate design
(informed by the class cost-of-service study and other important policy considerations) in the IPC-E-18-16
proceeding.
$ Motion to Approve Settlement Agreement, Att. 'l-7 to Att. 4.
31 Motion to Approve Settlement Agreement, Att. I to Att. 4.
32 lvlotion to Approve Settlement Agreement, Atts. 8-9 to Att. 4.
IDAHO POWER COMPANY'S PETITION FOR
RECONSIDERATION ANDiOR CLARIFICATION - 13
a
Each of these components comprising the Company's lnitial Study were filed with the
Commission in this proceeding on October 11, 2019, appended as Attachment 4 to the
Signing Parties' joint motion to approve the Settlement Agreement.33
b. MultipartyWorkshops
This lnitial Study described above served as a starting point for discussions with
the other parties that occurred over the course of eight separate settlement workshops
held in 2019. During this collaborative process, the study components were thoroughly
vetted and challenged by numerous parties participating in these workshops, as
evidenced by the comprehensive scoping list summarized in Staff's first status report to
the Commission.s These study components included study design, cost to serve grid
consumption of on-site generation customers, grid impacts of on-site generation
customers with and without smart inverters, the value of net exported energy, and
additional utility, environmental, and societal impacts.
c. Developing an Export Credit Rate Calculation Methodology
Ultimately, the Signing Parties agreed to adjust the Company's strawman
methodology for calculating net excess energy compensation, modifying both the energy
and capacity components. ln general, the parties agreed that the compensation rate for
excess generation would be based on avoided cost, rather than the market-based
33 Motion to Approve Settlement Agreement, Att. 4. The components of the lnitial Study in this
attachment consisted of both written documents and numerous large Excel files containing formula
calculations. The Company therefore provided these files to the Commission in compact dasc format and
committed to providing them to members of the public upon request. irotion to Approve Settlement
Agreement (cover lefter).
s First Staff Report, Att. 1, at 1-8. The Settlement Agreement reflects that all the issues identified
in the Table 1 scoping list have been resolved by the Signing Parties.
IDAHO POWER COMPANY'S PETITION FOR
RECONSIDERATION AND/OR CLARIFICATION . 14
approach utilized in the Company's lnitial Study.3s The market-based approach originally
developed by the Company in the lnitial Study36 resulted in an Export Credit Rate for
residential on-site generation of $28.17 per megawatt-hour ("MWh") as compared to the
final Export Credit Rate determination of $44.06 per MWh.
The details of this calculation were the subject of substantial debate, however, with
the parties presenting and studying multiple calculation methodologies over the course of
the eight workshops. As Commission Staff noted in their comments in support of the
Settlement Agreement, ''a significant amount of time and effort was spent exploring a
variety of methods and inputs to calculate a fair compensation value."37 The final
methodology leverages actual data from the Company's existing on-site generation
customers, is based almost entirely on information that is publicly available and
methodologies that have been vetted through public processes, and represents a
reasonable compromise.
Specifically, to determine the avoided energy value, the Signing Parties agreed to
use the Demand-Side Management avoided cost structure, which is developed through
IDAHO POWER COMPANY'S PETITION FOR
RECONSIDERATION AND/OR CLARIFICATION . 15
3s ldaho Power Co.'s Comments in Support of Settlement at 6 (Nov. 6, 2019).
s Motion to Approve Settlement Agreement, Att. 4. to Att. 4.
37 Comments of Commission Statf in Support of Settlement Agreement at 5 (Nov. 6, 2019).
the public IRP process and reflects the seasonal value of the resource.3s 3s To determine
the value of the avoided capacity costs, after studying and evaluating several methods
the Signing Parties agreed to rely on a National Renewable Energy Laboratory ("NREL")
methodology as a starting point for quantification. The NREl-based methodology was
used to determine the capacity value of solar for the Company's 2019 IRP and was
presented during the IRP Advisory Councrl meeting on December 13, 2018. The Signing
Parties agreed to take this methodology a step further to determine the capacity value of
exported solar specifically.ao The Export Credit Rate Study analyzed all customer
generators that were online during calendar year 2017 to determine what amount of their
exports are likely to occur at the time of ldaho Power's system peak loading periods (as
determined by the 100 peak hours in 2017).
The results of this analysis demonstrate that most customer generation on ldaho
Power's system is being consumed on site during the Company's system peak hours.
3a ln the Matter of ldaho Power Co.'s 2017 lntegrated Resource Plan, Case No. IPC-E-17-11,
Application, Att. 1, App. C, at 63-64 (Jun. 30, 2017).
3e Motion to Approve Settlement Agreement, Att. 1, at 2-3; ldaho Power Co.'s Comments in Suppo(
of Settlement at 6; Comments of Commission Staff in Support of Settlement Agreement at 5-6. As further
explained in Staff's comments in support of the Settlement Agreement, the Signing Parties also agreed to
support an investigation into the development of a single avoided cost value for resources on the
Company's system. lf that investigation results in a method for calculating avoided costs that is
subsequently approved by the Commission, under the Settlement Agreement it would likely apply to the
value of exported energy supplied by Schedule 6 and 8 customers. Comments of Commission Staff in
Support of Settlement Agreement at 10.
a0 ldaho Power Company's Comments in Support of Settlement, Att. 1 (Nov. 6, 2019). Attachment'l included several large Excel files pertaining to the modified Export Credit Rate studies, in addition to a
narratave document describing the NREl-based methodology for determining the capacity value of solar
exports. The Company therefore provided these files to the Commission in compact disc format and
committed to providing them to members of the public upon request. ldaho Power Company's Comments
in Support of Settlement (cover letter). While the narrative on the capacity value of solar exports was
present on the record in this proceeding when the Commission entered Order No. 34509, the Company
has provided the document again in Attachment '1 to this Petition for the Commission's revaew.
IDAHO POWER COMPANY'S PETITION FOR
RECONSIDERATION AND/OR CLARIFICATION . 16
Both the energy and the capacity value were increased by 8.1 percent to reflect avoided
transmission and distribution ('T&D) line losses.
Finally, while there were studies developed and presented during settlement
negotiations quantifying values for integration costs and benefits associated with deferred
T&D capacity and environmental benefits, those studies were not mutually agreed to and
were not included in the final Export Credit Rate. lnstead, the Signing Parties agreed that
zero-dollar placeholders would be included for now, with the ability for parties to advocate
for different values in future proceedings.
d. The Final Export Credit Rate Study
To implement the methodology changes for an Export Credit Rate agreed to in the
settlement workshops, the Company developed revised study components for calculating
net excess energy compensation. These study components consist of Excel-based
models that calculate the capacity value of solar for Schedules 6 and 8, together with an
associated narrative describing the capacity contributions, and an Excel-based model for
calculating an Export Credit Rate that is to be updated biennially with inputs from ldaho
Power's most recently acknowledged lRP. Together, these revised study components
comprise the Export Credit Rate Study. The Company filed this Export Credit Rate Study
with the Commission on November6,2019, as Attachment 1 to ldaho Power's Comments
in Support of the Settlement Agreement.4l Because the Export Credit Rate Study was
41 ldaho Power Company's Comments in Support of Settlement, Att. '1. The components of the
Export Credit Rate Study in Attachment 1 included several large Excelfiles containing formula calculations,
in addition to a narrative document. The Company therefore provided these files to the Commassion in
compact disc format and committed to providing them to members of the public upon request. ldaho Power
Company's Comments in Support of Settlement (cover letter). The Company has received two such
requests and has provided the executable files to those requesting them. While this Export Credat Rate
Study was present on the record in this proceeding when the Commission entered Order No. 34509, to
make it more readily accessible for the Commission's review, the Company has also now provided it in
Attachment 1 to this Petition as a PDF.
IDAHO POWER COMPANY'S PETITION FOR
RECONSIDERATION AND/OR CLARIFICATION - 17
originally filed on compact disk with executable files, the Company has included a PDF
version of the Export Credit Rate Study with an accompanying table of contents and
narrative descriptions as Attachment 1 to this Petition. The Company believes the revised
format for the Export Credit Rate Study will better facilitate a comprehensive review by
the Commission and interested parties on reconsideration.
e. Other Compensation Structure Elements Addressed in the
Study Process
ln addition to modifying the calculation methodology for an Export Credit Rate,
during the workshops, the Signing Parties also evaluated and ultimately agreed to key
aspects of an appropriate compensation structure for net excess generation. For
example, while ldaho Power's lnitial Study considered the total value of the generating
resource profile output,42 other workshop participants preferred to limit the analysis to
exports, while disregarding customer generation consumed on site. This "bright line at
the meter concept" formed an important part of the final compromise and is reflected in
the compensation structure recommended in the final Settlement Agreement.43
The Signing Parties also evaluated the interval length over which to allow
customers to net their excess energy and consumption and ultimately agreed to move
from net monthly billing to net hourly billing.aa This shorter measurement interval for
consumption and excess net energy supports the "bright line at the meter" concept by
preserving the customer's ability to consume on-site generation behind the meter, while
42 Motion to Approve Settlement Agreement, Att. I to Att. 4.
a3 See lVlotion to Approve Settlement Agreement, Att. 1, at 2 (calculating avoided energy value
based in part on "actual energy exports"); Comments of Commission Staff in Support of Settlement
Agreement at 3-4 (discussing the importance of the "bright line at the metel'concept).
44 Motion to Approve Settlement Agreement, Att. 1, at 2.
IDAHO POWER COMPANY'S PETITION FOR
RECONSIDERATION AND/OR CLARIFICATION . 18
allowing the Company to more accurately distinguish at the point of delivery between
rates for consumption and the credit provided for exported energy.as This is a significant
improvement in billing accuracy over the much longer netting period currently in place for
residential and small general service on-srte generation customers. As the Commission
observed in Case No. IPC-E-1 7-13, under the monthly net billing construct customers can
net out their imports and exports over the course of a month and thereby underpay their
share of fixed costs for the grid usage associated with actual system energy they
consume.as Net hourly billing is designed to help mitigate this inequitable cost shifting.47
The parties also evaluated an appropriate transition period for implementing the
Export Credit Rate.48 While the Signing Parties envisioned implementing net hourly billing
immediately, they agreed to an eight-year transition period for incrementing the revised
methodology for calculating an Export Credit Rate.ae Thus, under the terms of the
Settlement Agreement, the Export Credit Rate would initially be set at what is effectively
15 Comments of Commission Staff in Support of Settlement Agreement at 3-4. As the Commission
found in Case No. IPC-E-17-13, "[i]t is reasonable and fair to distinguish a customer's freedom to offset
usage behind the meter from a customer's choice to export energy to the grid." Order No. 34147 , at 16
(Sept. 21, 2018) (order on reconsideration).
a6 See Order No. 34046 at 16-17 (acknowledging the ability an on-site generation customer
currently has to " 'net out' or net to zero their electricity use[,]" which "causes them to underpay their share
of the Company's flxed costs to serve customers," and observing that "this inequity will only increase as
more customers choose on-site generation").
a7 See ldaho Power Co.'s Comments in Support of Settlement at 5. See also Comments of
Commission Staff in Support of Settlement Agreement at 4 ("Under net monthly billing, customers could
use kalowatt hours produced anytime in the month to offset kilowatt hours consumed from the Company
anytime in the month. This long netting period does not accurately reflect the customer's consumption of
Company-supplied energy because exported energy can 'mask' consumption on a customer's bill.
Shortening the billing interval from net monthly to net hourly drastically decreases this problem and
effectively eliminates any meaningful amount of 'masking."').
18 See First Staff Report, Att. 1, at 7.
as Motion to Approve Settlement Agreement, Att. 1, at 4-5.
IDAHO POWER COMPANY'S PETITION FOR
RECONSIDERATION AND/OR CLARIFICATION - 19
the status quo (the Blended Base Energy Rate for each respective customer class), with
incremental adjustments every two years to achieve full implementation of the new
methodology in the eighth year.so
f. Summary of Comprehensive Study Materials in the Record
As demonstrated in the foregoing discussion, the Company and the other parties
who participated in the settlement workshops, have fulfilled the Commission's directive in
Order No. 34046 to conduct a comprehensive study, and in so doing, the parties have
addressed all the issues identified in the Commission's Order. First, the parties analyzed
system costs and benefits, as documented in the cost-of-service study for on-site
generation initially performed by the Company. While ldaho Power developed these
study components prior to the multiparty workshops, they were thoroughly vetted during
the year-long study process and jointly filed with the Commission in support of the
Settlement Agreement on October 1 1 , 2019.5r
Second, the parties exhaustively evaluated options for an appropriate
compensation structure, culminating in an agreement among the Signing Parties to begin
implementing net hourly billing immediately, with net excess generation to be
compensated at an Export Credit Rate phased in over a period of eight years and subject
to future updates based on an acknowledged lRP. This final recommended
compensation structure is documented in the Settlement Agreement,s2 which is in turn
5a b.
IDAHO POWER COMPANY'S PETITION FOR
RECONSIDERATION AND/OR CLARIFICATION . 20
51 Motion to Approve Settlement Agreement, Att. 4.
5? l\4otion to Approve Settlement Agreement, Att. 1, at 2-6 (describang the Signing Parties'
agreement with respect to net hourly billing, the methodoiogy to determine the Export Credit Rate, biennial
updates, ratemaking treatment, and retail rate compensation during an eaght-year transition period).
supported by the Export Credit Rate Study filed with the Commission on November 6,
2019.53
Thus, all the information originally requested in Order No. 34046 has been
produced, analyzed, and filed.Y The Company therefore respectfully requests the
Commission find on reconsideration that the Settlement Agreement is adequately
supported by a comprehensive study in the evidentiary record and can be approved.
Although the Company believes the existing record is sufficient to grant and
process reconsideration on written briefs under Commission Rule of Procedure 331,s5
reconsideration of the Commission's rejection of the Settlement Agreement could
alternatively be conducted with an evidentiary hearing or through public comment, as
contemplated in Commission Rules of Procedure2T4 and 331.56 Therefore, ldaho Power
has also presented a PDF version of the Export Credit Rate Study as Attachment 1 to
this Petition to facilitate additional review by the Commission and the public, which the
s3 ldaho Power's Comments in Support of Settlement, Att. 1. This Study supplants the Company's
initial strawman proposal for compensating net excess generation. Motion to Approve Settlement
Agreement, Att. 8 to Att. 4.
s As noted above, issues of proper rates and rate design for residential and small general servrce
on-site generation customers are being addressed separately in Case No. IPC-E-18-16, where ldaho Power
has already filed its Fixed Cost Report and the public comment period is underway. Order No. 34466 at2.
s5 TDAPA 31 .01.01.331.03
56 IDAPA 31.01.01.331.03 (allowing for reconsideration by "evidentiary hearing, written briefs,
comments, or Interrogatories"); IDAPA 31.01.01.274 (establishing procedure governing consideration of
settlements).
IDAHO POWER COMPANY'S PETITION FOR
RECONSIDERATION ANDiOR CLARIFICATION - 21
Company would proffer if reconsideration is granted with an evidentiary hearing or
comments.5T
2. The Public Received Adequate Notice that This Docket Might Result in
Fundamental Changes to the Net-Metering Service. Regardless of this
Fact, the Commission's Decision to Grandfather Existing Customers
Effectively Moots this lssue.
ldaho Power also respectfully requests the Commission find on reconsideration
that the public received adequate notice this docket might result in significant changes to
the Company's on-site generation offering for residential and small general service
customers. As noted above, this docket is the outgrowth of the Commission's directive
to the Company in Order No. 34046 to "initiate a docket to comprehensively study the
costs and benefits of on-site generation on ldaho Power's system, as well as proper rates
and rate design, transitional rates, and related r'ssues of compensation for nef excess
energy provided as a resource to the Company."sa ln fact, the Commission explicitly
encouraged interested stakeholders lo "work together in compromise[]" on this effort,
given the ''intractability these issues have created around the region and the country
generally[.]"5e Based on the full context surrounding this matter, it is reasonable to
conclude that interested members of the public would have been aware that a multiparty
s7 See IDAPA 31.0'1.01.331.01 (requiring a description of "the nature and quantity of evidence . . .
the petitioner will offer if reconsideration is granted"). See a/so ln the Matter of the lnvestigation lnto
Whether Ponderosa Tenace Estates Water System, lnc. is a Public Utility Subject to Regulation by the
ldaho Public Utilities Commission, Case No. GNR-W-o1-01, Order No. 29123 (Sept. 24,2002\ (denying
petition for reconsideration in part due to the petitioner's failure to include new evidence with the petition);
ln the Matter of the Application of ldaho Power Co. for Authority to lncrease its lnterim and Ease Rates
and Charges for Electric Service, Case No. IPC-E-03-13, Order No. 29547, al 2 (July 13, 2004)
(explaining that at the stage of deciding whether to grant reconsideration, the Commission will not weigh
new evidence presented by the petitioneri rather, the petitioner's proffered evidence will be evaluated at
a subsequent "hearing on reconsideration that will allow all parties to review the evidence and respond").
s8 Order No. 34046 at 31 (emphasis added).
ss ld. at 22 (emphasis added).
IDAHO POWER COMPANY'S PETITION FOR
RECONSIDERATION AND/OR CLARIFICATION - 22
process involving compromise on appropriate compensation for net excess energy could
indeed result in changes being implemented to the existing compensation structure for
on-site generation.
The record also demonstrates that ldaho Power engaged in a robust public
notification process, providing ample notice to the public that this docket could result in
alterations to the net metering service. Attachment 2 to this Petition contains a long list
of such communications to the public by the Company, Staff, the Commission, and others.
ln addition to letters and emails sent to customers by ldaho Power, customers received
notice that Case No. IPC-E-18-15 could result in changes to net metering from at least
three Commission orders/notices and two press releases/editorials widely circulated in
the Company's service area. lf reconsideration is granted, ldaho Power would present
similar information evidencing notice to customers and the public generally.
The record further demonstrates members of the public not just heard but
underslood such changes were possible. Over the course of the 12-month period before
the proposed Settlement Agreement was filed in this docket, the Commission received
81 public comments regarding the case, a majority of those comments, 70 percent, were
received from existing on-site generation customers. As set forth in Attachment 3, the
evidentiary record reflects that approximately 75 percent of commenters made
statements regarding possible reductions in the compensation for their excess energy,
increases to rates or rate design changes, and changes to the one-to-one net monthly
service structure.60 As these comments demonstrate, members of the public well
60 79 of the 81 public comments were received by the Commission at least three months prior to
the filing of the Settlement Agreement. 59 of the 81 comments were filed in June 2019. See Attachment
3.
IDAHO POWER COMPANY'S PETITION FOR
RECONSIDERATION AND/OR CLARIFICATION . 23
understood that this docket could result in programmatic changes. Similarly, it is clear
the parties understood this docket could materially impact net metering compensation, as
evidenced by assertions of interest in numerous petitions for intervention.6l The
Commission's decision to grandfather existing customers largely makes moot the
opposition raised in public comments, as a majority of these commenters will not be
impacted by the Settlement Agreement.
Finally, impacted customers and stakeholders were formally represented in the
proceeding. ln addition to the Company and Staff, 12 parties intervened in the case and
actively participated in presenting analyses and the detailed proposals referenced by Staff
in its August 28, 2019, status report.62 The City of Boise, for example, actively participated
in each of the eight settlement meetings and presented analyses and proposals as a
representative of approximately 30 percent of ldaho Power's residential on-site
61 Petition to lntervene of Russell Schiermeier and Procedural Comments, at 1, 2 (Jun. 14,2019)
(claiming a "direct and substantial interest in this proceeding in that terms and conditions for the continued
and potential operation of his net metering operations may be affecfed by the outcome of this proceedlng[]"
and asserting that "this proceeding ll may have a mateial impact on their ability to net meter electrical
production.") (emphases added); Petation to lntervene of lclP, at 2 (June 4, 2019) (claiming "a direct and
substantial interest in this proceeding in that its members'ability to net meter electrical production may be
affected by the outcome of this proceeding[,]" and asserting "this proceeding [] may have a material impact
on their ability to net meter electrical production."); ICEA's Petition to lntervene, at 2 (Nov. 30, 2018) ('ICEA
claims a direct and substantial interest in this proceeding in that the prices its [solar industry] members
receive for electrical sales and costs they pay to ldaho Powet may be affected by the outcome of this
proceeding.") (emphasis added); ldaHydro's Petition to lntervene, at 2 (Nov.21, 2018) ("ldaHydro claims a
direct and substantial interest in this proceeding in that the prices it receives for electrical sales and costs
it pays to ldaho Power may be affected by lhe outcome of this proceeding.") (emphasis added); Petition to
lntervene of Micron, at 3 (May 2, 2019) (claaming a "direct and substantial interest in this proceeding"
because "[a]s a large customer, Micron is particularly susceptible to the impact of potential cost shifts to
customers without on-site generation[,]" and asserting "this proceeding thal may have a material impact on
its electric rates and terms and conditions of service.") (emphasis added).
62 See Third Staff Report at 2.
IDAHO POWER COMPANY'S PETITION FOR
RECONSIDERATION AND/OR CLARIFICATION - 24
generation customers.63 The broader participating customers' interests were represented
by the Sierra Club, lCL, NWEC, Vote Solar, and participating customer Russell
Schiermeier.Ga The installer industry was also represented in the proceeding by lCEA.6s
As all of the foregoing demonstrates, residential and small general service on-site
generation customers were on adequate notice that this docket might result in
fundamental changes to the net-metering service. But even if the Commission disagrees,
the question of whether such customers received adequate notice and appreciated the
potential for programmatic changes to their excess energy compensation structure is
effectively mooted by the Commission's decision in Order No. 34509 to grandfather net
metering rates for all existing customers.66 Under the terms agreed to by the Signing
Parties, a decision by the Commission to grandfather existing customers would not nullify
the Settlement Agreement with respect to future customers.6T Therefore, the question of
63 The City of Boise stated in its petition to intervene that it "has set specific energy use and carbon
reduction goals for internal operations based on detailed baselining of current energy use and the
implementation of energy etficiency measures in combination with increased installation of renewable
energy[]" and that "the intervenor's broader sustainability goals are a reflection of the comments end
feedback received from the citizens of Boise City in the course of the lntervenor's various community
engagement processes." City of Boise's Petition for Leave to lntervene, at 2 (Nov. 29,2018).
ln its petition to lntervene, Sierra Club referenced representing 3,600 members who lave and
purchase utility services in ldaho and stated their work "includes advocating for the implementataon of
programs that assist its members and utility consumers generally to access renewable energy." Petition to
lntervene ofthe ldaho Sierra Club, at2 (Nov.30,2018). ICL (representing 11,000 members, most of whom
are ldaho Power residential customers) and NWEC stated similar causes of "ensuring utility rates and
programs are fair, just, and reasonable while expanding access to ldaho's clean energy resource options,"
and promotion of "renewable energy," respectively. Petition to lntervene of lCL, at2 (Oct.31,2018); Petition
to lntervene of the NW Energy Coalition, at 2 (Mar. 13, 2019).
6s ICEA stated in its petition to intervene that it is "dedicated to the advancement of renewable
energy, energy efficiency and their associated technologies in the state of ldaho" and "ats members currently
sell products that are subject to the schedules at issue in this matter." ICEA'S Petition to lntervene, at 2
(Nov. 30, 2018).
s See Order No. 34059 at 1 0-14
IDAHO POWER COMPANY'S PETITION FOR
RECONSIDERATION AND/OR CLARIFICATION - 25
67 Motion to Approve Settlement Agreement, Att. 1, at 7.
B
whether existing customers received sufficient notice that a collaborative and
comprehensive study process ordered by the Commission might result in programmatic
changes is simply not relevant to the ultimate determination on reconsideration, namely,
whether to approve the Settlement Agreement with respect to future customers as a
reasonable compromise resolution of many longstanding, contentious issues surrounding
net metering.
ln the Alternative, the Company Respectfully Requests the Commission
Reconsider its Directive for an Entirely New On-site Generation Study
Process, instead Allowing the Company, lnterested Parties, and the Public
to Build on Extensive Work Performed to Date.
lf the Commission declines to reconsider its decision not to approve the Settlement
Agreement, ldaho Power respectfully requests that in the alternative, the Commission
reconsider the extensive procedures it has prescribed for conducting an entirely new
comprehensive study from scratch.6s The Company appreciates the Commission's
desire for additional public involvement and scrutiny but is concerned the process the
Commission has prescribed essentially sends all of the parties back to the drawing board.
This will result in largely discarding thousands of hours of careful and collaborative
analysis and deliberation, during which 13 different parties with divergent interests worked
in good faith to come to a common understanding of a reasonable approach that was
ultimately supported by nine of those parties (and opposed by none).6s
6E Order No. 34509 at 9-10
6s See ldaho llPA's Application for lntervenor Funding, at g (Dec. 12, 2019) (requesting intervenor
fundang of approximately $82,000 for more than 370 hours of work)i ICL's Application for lntervenor
Funding, at 3, 6 (Nov. 27,2019) (requesting intervenor funding of approximately $12,000 for 59 hours of
work); ldaho Sierra Club's Request for lntervenor Funding, at 3, 6 (Dec. 10, 2019) (requesting intervenor
funding of approximately $6000 for more than 50 hours of work)i ICEA'S Petition for lntervenor Funding, at
4 (Nov. 27, 2019) (requesting approximately intervenor funding of approximately $23,000).
IDAHO POWER COMPANY'S PETITION FOR
RECONSIDERATION AND/OR CLARIFICATION - 26
lnstead, ldaho Power asks the Commission to direct the Company to (1) file a
recommendation in this docket for the immediate implementation of net hourly billing for
new Schedule 6 and Schedule 8 customers with no immediate change to the
compensation value, which ensures a neutral financial impact to those customers during
this interim period, and (2) initiate a public process to explore the appropriate value to be
assigned to hourly exported energy from all non-grandfathered on-site generators (i.e.,
Export Credit Rate) in the future.
1. The Company's Proposal
a. lmplement Net Hourly Billing During this lnterim Period
ldaho Power recommends that on reconsideration, the Commission direct the
Company to file a recommendation in this docket to begin implementing net hourly billing
for new Schedule 6 and Schedule 8 customers during the pendency of the Export Credit
Rate Study docket. During this interim period, the Company will begin presenting both
cumulative net hourly energy consumption and cumulative net hourly exports of excess
energy on customer bills, rather than merely displaying the net of these two as is done
for grandfathered customers. The Company will base both the energy consumption rate
and the Export Credit Rate at the same retail rate, which will result in a neutral financial
impact to customers. That is, the Company will immediately begin netting on an hourly
basis, but because for the time being the energy consumption and crediting rates will be
at the same amount, the ultimate amount charged or credited to new Schedule 6 and
Schedule I customers during this period will be the same as it would have been under a
IDAHO POWER COMPANY'S PETITION FOR
RECONSIDERATION AND/OR CLARIFICATION . 27
monthly netting billing construct.To The Company's implementation recommendation
could be put fomard for public review and comment prior to the Commission's final order
implementing the new billing construct.
As discussed above, it is well established that moving from net monthly billing to
net hourly billing is an important step toward reducing inequitable cost shifting.71 The
Company's lnitial Study developed for this docket included a cost-of-service study for on-
site generation,T2 which demonstrates that moving to ful/ implementation of a net hourly
billing construct, when combined with a value-based Export Credit Rate73 can significantly
reduce cost shifting - a 73 percent reduction in the modeled residential cost shift based
on this 2017 study. The following is an except of the relevant portion of this study:
70 To ensure customers remain neutral during this interim period pending the completion of a new
Export Credit Rate study, the Company will also need to make some adjustments to the ways in which the
non-base rate components are calculated on customer bills. The Company will present these adjustments
in fu(her detail at the evidentiary phase on reconsideration.
71 See Order No. 34046 al 16-17; Order No. 3r'.147 at '16; Comments of Commission Staff in
Support of Settlement Agreement at 3-4. See a/so Motion to Approve Settlement Agreement, Att. 10toAtt.
4 (cost shifting studies performed by the Company for prior dockets based on data from 2015 and 2016).
72 Motion to Approve Settlement Agreement, Att. 1-7 to Att. 4.
73 To be clear, while a new Export Credit Rate study docket is pending, the Company is not
proposlng utilization of a value-based Export Credit Rate - it is proposing the retail rate currently charged
for energy usage. Additionally, the Company is not proposing full implementation of net hourly billing,
insofar as the Company intends to make adjustments to the non-base rate components of new customers'
bills during this interim period to ensure a neutral financial impact.
IDAHO POWER COMPANY'S PETITION FOR
RECONSIDERATION AND/OR CLARIFICATION - 28
IDAHO POWERCOMPANY
NET lllETERING HOURLY gILLING RESULTS
TVVELVE MONTHS ENOING DE'EM8ER 31, 2017
(61
lbt
1c) Ia -bl
1d)
(e)
(fltd xel
is) lc + fl
(h)
(i)
tl ls/hI
(k)li+jl
Revenue SequirPmenl
Net Hourly kwhs in Ercess of Net Monthly
RVODTR Value {50.028I7 per kwh)
Cledh fo! Excess Generation
Coqt'shift to System
A.nual Customer BillinS,
Curient SeNice Char8e
ln(rease to Eliminate cost-Shifl
TotalService charge
Re ridentia I O ft5iie Generation
Net Monthlv gillinE
s1,414,220
Net Houdv AIllns
s1.434.220
91,111,6s1
ts,r50,93rl
11,055
5s.00
S14.54
s39.54
is122,569)
1,848,a51
s0.02817
5108,422
(s1a,1471
13,055
s5.00
s1.08
S6.08
Small Gen. On-Site G..e..tion
Net Monthlv BllllnE
sl5,l53
917,674
(s1/,6,r8i
Net tlourlv Silline
sl5,l5l
527,176
1s17,678)
411
s5.00
s42.95
s47.95
it8,1/71
s1,482
s0.02817
52,517
4tz
Ss.oo
511.60
sr8.60
The Company does not believe further study, beyond what has already been
presented on the record in this case, is necessary to support utilizing existing meter
functionality to implement a more accurate measurement of grid usage by, and excess
net energy from, the on-site generation customer. The presentment of cumulative hourly
energy imports and cumulative hourly energy exports on Schedule 6 and Schedule B
customers' monthly bills will provide helpful insight into the extent they are utilizing the
grid to serve both their energy needs and to facilitate export of excess on-site energy
generation. This additional granularity in the monthly billing information under the net
hourly monthly billing construct will also provide future on-site generation customers with
a better ability to assess the impact that changes to the export credit may have on their
monthly net energy costs.
This proposed implementation process will also establish a clear delineation
between grandfathered and non-grandfathered customers. The grandfathering provisions
included in Order No. 34509 separate new and existing on-site generation customers
without indicating how they may be treated differently going forward. lmplementing net
IDAHO POWER COMPANY'S PETITION FOR
RECONSIDERATION AND/OR CLARIFICATION . 29
hourly billing for non-grandfathered customers will provide customers with a clear
indication of the applicable billing construct and reduce some uncertainty for those
considering the installation of on-site generation.
lmplementing net hourly billing during this interim period will also allow the
Company to gain valuable experience with this billing construct while the parties and
members of the public fine tune an approach to calculating the Export Credit Rate through
the study review process. ln addition, taking interim steps toward implementation of the
net hourly billing construct now will build on the extensive work performed to date, greatly
narrow the scope of issues to be explored going forward, and provide a clear signal to
prospective customers that the current compensation structure is subject to change.
b. lnitiate a Value of Exported Energy Docket for All Customer
Classes
The procedures prescribed by the Commission in Order No, 34509 consist of a
scoping phase, a study design phase, and a study review phase. The first two phases
have already been largely accomplished in this docket. As detailed above, during the
comprehensive study process performed in this docket, the parties completed a scoping
document (which was presented to this Commission in d raft form as a table appended to
the First Staff Report in February 2019), a comprehensive study of the costs and benefits
of excess net energy on ldaho Power's system, and substantial thinking on how to
structure compensation for that excess net energy to reduce shifting of on-site generation
customers' share of fixed d istribution system costs to other customers. Moreover, the
Company has already filed a separate but related comprehensive study regarding cost of
service and rate design in Case No. IPC-E-18-16, which is currently undergoing public
IDAHO POWER COMPANY'S PETITION FOR
RECONSIDERATION AND/OR CLARIFICATION - 30
review and comment.T4 The Company therefore proposes building on this existing body
of relevant work rather than abandoning it entirely.
Accordingly, ldaho Power respectfully requests the Commission reconsider and
instead direct the Company to initiate a petition for a new docket to broadly explore the
value of exported customer generation to serve as the basis for a methodology for
determining Export Credit Rates for all customer classes. Following sufficient notice to
the public and interested parties, a period for intervention, and a process for public input
and participation, the Company would file a final study and Export Credit Rate
recommendations for Commission review that incorporates feedback from the
Commission, the public, and other parties, and relies on the most recent data then
available.
It is also important to note that the Company, Staff, and intervening parties have
been actively discussing modifications to ldaho Power's Schedule 84, Net Metering
Service, in the 19-1 5 Case for several months. This proposed value of exported energy
study process should be broad enough in scope to properly inform Export Credit Rates
considered in the 19-15 Case, thereby achieving process efficiencies and cost savings
for the Company and interested parties.
2, Streamlined Procedures Serve the Public lnterest
Under this more streamlined set of procedures in a new docket, the existing studies
would serve as a starting point for further discussion, helping frame and focus
7a Order No 34466 at 2
IDAHO POWER COMPANY'S PETITION FOR
RECONSIDERATION AND/OR CLARIFICATION . 31
deliberations among interested parties and members of the public.i5 This more efficient
process would allow for faster resolution of the longstanding and complex issues
surrounding ldaho Power's net metering service. lt is in the public interest not to drag this
process out any longer than necessary, because only a final Commission order approving
changes to ldaho Power's on-site generation offering will fully remove the cloud of
uncertainty for prospective customers and the solar industry,
Furthermore, the sooner this uncertainty regarding the on-site generation service
is resolved, the sooner bad actors from the solar installation industry will be thwarted from
engaging in deceptive practices to capitalize on customer confusion. Certain installers
continue to provide misleading information to ldaho Power's customers about the long-
term economics of solar installation, even after being served with requests to cease and
desist. ln fact, after the Commission's issuance of Order No. 34509, the Company has
received several calls from installers asking the Company how the installer is supposed
to sell systems if they cannot tell a customer that the net monthly billing construct will
continue. The Company is concerned the installers will not change their sales approach
as long as the net monthly structure remains in place, For example, a public hearing
witness employed by a solar installation company testified "we talked to a couple other
solar companies in the area, we've all sold and installed several families and homeowners
7s lf the Commission is not inclined to allow the Company to utilize the existing study as a starting
point for further deliberation, then in the alternative, the Company respectfully requests the Commission at
least allow the Company to file the most current version of the Table 1 scoping list developed during the
settlement workshops to frame a scoping process. See First Staff Report, Att. 1; see also Second Staff
Report at 2 (discussing the status of Table 1 ). This table reflects a substantial amount of work by the parties
to the settlement process, and the Company believes it would be the best use of resources to allow
interested members of the public to build on this list rather than starting fully anew.
IDAHO POWER COMPANY'S PETITION FOR
RECONSIDERATION AND/OR CLARIFICATION - 32
in the previous years with the notion that ldaho Power was going to keep this net metering
policy in check and in place.'76
3. ldaho Power's Efforts to Reduce Confusion and Protect its Customers
ldaho Power wholly disagrees with the Commission's characterization of the
Company's role in creating an expectation that its net metering fundamentals would
remain unchanged.TT First, the Company has and continues to communicate with its
customers about the potential for changes that can impact the payback of their investment
in on-site generation.Ts
Second, as the Commission is aware, ldaho Power was instrumental in advancing
the Residential Solar Energy System Disclosure Act (the "Act),7s which requires the
written disclosures specifically referenced in the Commission's Order. The Act adds a
new chapter to Title 48 of the ldaho Code, Monopolies and Trade Practices, which is also
where ldaho's consumer protection legislation resides. The Act requires all solar energy
system retailers to deliver certain written disclosures to residential consumers to
discourage such retailers from over-representing performance of solar energy products,
as well as misrepresenting affiliations with utility companies or other energy-related
service providers, The Act further provides the ldaho Attorney General with the authority
76 f(. at22.ll.7-11 (Dec.2.20191
77 Order No. 34509 at 10 (stating that that "before the service date of this Order, customers
reasonably assumed the nelmetering program fundamentals would not change[,]" because
"Ir]epresentations made by both solar developers and the Company, whether explicit or implied, created a
reasonable basis for reliance.") (emphasis added).
78 ldaho Power Company's Opening Brief at '17-20 (Nov. 13, 2019).
7s ldaho Code S 48-1801 , et seq.
IDAHO POWER COMPANY'S PETITION FOR
RECONSIDERATION AND/OR CLARIFICATION . 33
to enforce the specific requirements of the Act, mirroring the enforcement authority found
in ldaho's Consumer Protection Act.
Third, when calls from customers continued to pour in around deceptive and
misleading information being provided by certain solar installers within ldaho Power's
service area, the Company proactively pursued a complaint process with the Office of the
Attorney General on February 21 ,2019 ("AG Complaint").80 The Company spent months
tracking and gathering the information necessary to submit a formal complaint to the
Attorney General for purposes of protecting its customers from these deceptive practices.
ldaho Power also sent numerous cease and desist letters to solar companies reported by
its customers as engaging in these deceptive practices. ln addition, after learning that
one developer continued to spread misinformation about solar installation benefits and
ldaho Power's net metering offering, ldaho Power converted its AG Complaint, insofar as
it applied to the developer, from an informational claim to an enforcement claim.81
Based on ldaho Power's significant efforts to prevent and resolve the deceptive
and misleading information being spread to its customers, there is no evidence to support
the view that the Company is responsible either explicitly or impliedly for creating an
expectation that its nelmetering service would remain unchanged.
80 Attachment 4, AG complaint (Feb. 21 , 2019). ln addition, ldaho Power has formally complained
to the AG's office about installers who represent themselves as being affalaated with the Company.
81 True and correct copies of ldaho Poweas request for enforcement (including a supporting
transcript), the installer's response, and the Attorney General's resolution of the claim are attached hereto
as Attachment 5 (File No. 159276-223156).
IDAHO POWER COMPANY'S PETITION FOR
RECONSIDERATION AND/OR CLARIFICATION . 34
4. Recommended Procedures on Reconsideration
lf the Commission grants reconsideration under this alternative, ldaho Power will
present evidence and argument supporting a recommendation for (1) the immediate
implementation of net hourly billing for new Schedule 6 and Schedule 8 customers with
no immediate change to the compensation value, which ensures a neutral financial impact
to those customers during this interim period, and (2) how to complete the study called
for in Order No. 34509 while building on the parties' substantial work to date, as reflected
in the Export Credit Rate Study included with this petition as Attachment 1.
Reconsideration could then be conducted by written comments and/or hearing within the
13 weeks set forth in ldaho Code $ 61-626.82 At the Commission's direction, ldaho Power
will also initiate a public process in a separate docket to explore the appropriate value to
be assigned to hourly exported energy from all on-site generators (i.e., Export Credit
Rate) in the future.
III. PETITION F R CLARIFI TI N
Regardless of whether reconsideration is granted, the Company has reviewed the
Commission's Order regarding grandfathering and seeks clarification to ensure it has
clearly understood the Commission's intent.83 Specifically, the Company requests that
the Commission clarify those portions of its Order pertaining to grandfathering in three
specific respects.
82 IDAPA 31.01.01.331.03 (allowing for reconsideration by "evidentiary hearing, written briefs,
comments, or interrogatories").
83 TDAPA 31.01.01.325
IDAHO POWER COMPANY'S PETITION FOR
RECONSIDERATION AND/OR CLARIFICATION . 35
A,Possible Exceptions to the Utility Customer Relations Rules ("UGRR")
Definition of "Customer".
84 Order No. 34509 at 15 (emphasis added).
85 Rule 005.02 of the UCRR provides: "Unless restricted by definition within a rule or group of rules
to a particular class of customer, "customer" means any person who has applied for, has been accepted by
the utility, and is (a) receiving service from a utility; or (b) has received service within the past ten (10)
calendar days prior to termination by the utility; or (c) has assumed responsibility for payment of service
provided to another or others. lf the person receiving service is not the same person as the person
assuming responsibility for payment of service, the latter is the customer for purposes of obtalning or
terminating service, receiving refunds, or making changes to the account."
IDAHO POWER COMPANY'S PETITION FOR
RECONSIDERATION AND/OR CLARIFICATION - 36
First, ldaho Power asks that the Commission clarify its use of the term "customer"
as used in the grandfathering portion of its Order. The Commission grandfathered "the
customer al the meter site at the originally installed nameplate capacity of the system."aa
The definition for ''Customer" is provided in Rule 005.02 of the UCRR,ss Utilizing that
definition, the "custome/' is the person who is financially obligated for service at that meter
site as of December 20, 2019, and that customer is tied to a contract within ldaho Power's
Customer Relations and Billing System. Accordingly, it is ldaho Power's understanding
that once that service contract ends, the site will no longer be grandfathered.
It is important to note, however, that a service contract can be closed for multiple
reasons; for example, when a customer moves out, when the primary name on the
contract is changed, orwhen a service is disconnected dueto non-payment. ldaho Power
believes it is not the Commission's intent to terminate the grandfathered status in the case
where the service contract ends due to the name change as a result of the death of a
spouse, in the case of a divorce, when a rental unit changes occupants, or in the case of
new construction where the temporary service is in the builder's name with the intention
that a new customer take service when construction is complete. ldaho Power requests
the Commission clarify that closure of the service contract terminates the grandfathered
status at the site - either with or without these possible exceptions.
B. Order No. 34509 Provides Notice to ALL Customer Classes that the
Compensation Structure May Change.
Second, ldaho Power requests the Commission clarify that all customer classes
are on notice that the compensation structure may change as a result of the ordered
proceedings. The Commission stated:
Given the more clearly worded disclosure in the recently-enacted
Residential Solar Energy System Disclosure Act, and our more complete
description in this Order of what a "tariff can change" means, we perceive a
reasonable difference between existing customers and new customers.
Based on these differences, and harmonizing ldaho Code 61-315 with
ldaho Code SS 61-501, -502, and -503, we find there are reasonable
differences between existing and new net-metering customers that justify
treating these types of customers differently from each other.86
The Commission further stated that "an existing customer is a person or business who
either has an on-site generation system interconnected with ldaho Power's system as of
the service date of this Order, or who has made binding financial commitments to install
an on-site generation system as of the service date of this Order-"87
The Company interprets Commission Order No. 34509 to put a// ldaho Power
customers who are considering on-site generation on notice that future changes could
include changes to the compensation structure, including irrigation customers, and
commercial and industrial customers, as well as residential and small general service
customers. To accomplish this, the Company has begun sending the email included as
Attachment 6 for all applications received after December 20,2019, from Schedule 9, 1 9,
86 Order No. 34509 at 14.
B7 ld.
IDAHO POWER COMPANY'S PETITION FOR
RECONSIDERATION AND/OR CLARIFICATION . 37
and 24 customers, as well as Schedule 6 and B customers. ldaho Power wishes to clarify
or confirm that this reading is correct
c Schedule 6 and 8 Rate Structures May Be Adjusted in a Future Rate
Case
Third, ldaho Power wishes to clarify its understanding as to which customers are
subject to rate structures in Schedules 6 and 8, as adjusted in a future rate case. ln its
Order, the Commission stated that it was:
[G]randfathering existing customers into Schedule 6 or
Schedule 8 as those Schedules exist on the service date of
this Order We expect proposals for changes to
consumption rates and rate structures to be made only in a
general rate case in which rates and rate structure for all
customers classes are under review.88
The Company interprets the Commission's Order to mean that subsequent to a
future rate proceeding, grandfathered customers will be subject to the rate structure and
pay the rates for consumption contained within their respective Schedules 6 and 8. To
ensure that its future filings are consistent with the Commission's intent, ldaho Power
requests the Commission confirm whether this interpretation is correct.
Should the Commission determine that any of the requested issues for clarification
is more appropriate for reconsideration, ldaho Power believes that the evidentiary record
could be augmented by written comments or oral argument at the discretion of the
Commission.
tv. coNcLUstoN
The Settlement Agreement in this docket is supported by substantial evidence in
the record that the parties fulfilled the Commission's directive in Order No. 34046 to
88 Order No. 34509 at 14-15
IDAHO POWER COMPANY'S PETITION FOR
RECONSIDERATION AND/OR CLARIFICATION - 38
conduct a comprehensive study addressing all the issues identified in the Commission's
Order. Therefore, ldaho Power respectfully requests the Commission approve the
Settlement Agreement on reconsideration as a reasonable resolution of many
longstanding and contentious issues surrounding the Company's on-site generation
service.
ln the alternative, the Company requests the Commission to reconsider its
direction to conduct an entirely new scoping process and comprehensive study.
Recognizing the significant efforts expended by the parties to date, the Company
recommends the Commission direct the Company to (1) file a recommendation in this
docket for the immediate implementation of net hourly billing for new Schedule 6 and
Schedule 8 customers in a manner that ensures neutral financial impact to those
customers during this interim period, and (2) initiate a public process to explore the
appropriate value to be assigned to hourly exported energy from all on-site generators in
the future, building on the substantial body of work performed in this case.
Regardless of the Commission's decision on reconsideration, if it is not the
Commission's intent for its decisions in this case to hinder progress toward settlement in
the 19-15 Case for customers taking net metering service under Schedule 84, the
Company respectfully requests that the Commission issue an order explicitly stating such
and direct parties to continue negotiations toward settlement in that case.
Finally, the Company seeks clarification of several aspects of the Commission's
Order grandfathering existing customers.
DATED at Boise, ldaho, this 1Oth day of January 2020.
ISA NORDST M
Attorney for ldaho Power Company
IDAHO POWER COMPANY'S PETITION FOR
RECONSIDERATION AND/OR CLARIFICATION - 39
I HEREBY CERTIFY that on the 10th day of January 2020 I served a true and
correct copy of IDAHO POWER COMPANY'S PETITION FOR RECONSIDERATION
AND/OR CLARIFICATION upon the following named parties by the method indicated
below, and addressed to the following:
Commission Staff
Edward Jewell
Deputy Attorney General
ldaho Public Utilities Commission
472 West Washington Street (83702)
P.O. Box 83720
Boise, ldaho 837 2O-0O7 4
ldaHydro
C. Tom Arkoosh
ARKOOSH LAW OFFICES
802 West Bannock Street, Suite LP 103
P.O. Box 2900
Boise, ldaho 83701
ldaho Conservation League and NW
Energy Coalition
Benjamin J. Otto
ldaho Conservation League
710 North 6th Street
Boise, ldaho 83702
NW Energy Coalition
F. Diego Rivas
NW Energy Coalition
1 1 0'1 8th Avenue
Helena, Montana 59601
ldaho lrrigation Pumpers Association, lnc.
Eric L. Olsen
ECHO HAWK & OLSEN, PLLC
505 Pershing Avenue, Suite 100
P.O. Box 6119
Pocatello, ldaho 83205
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IDAHO POWER COMPANY'S PETITION FOR
RECONSIDERATION AND/OR CLARIFICATION - 40
CERTIFICATE OF SERVICE
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tavlor. pestell@arkoosh. com
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Anthony Yankel
12700 Lake Avenue, Unit 2505
Lakewood, Ohio44107
Vote Solar
Briana Kobor
Vote Solar
358 South 700 East, Suite 8206
Salt Lake City, Utah 84102
David Bender
Earthjustice
3916 Nakoma Road
Madison, Wisconsin 5371 1
Al Luna
Nick Thorpe
1625 Massachusetts Avenue, NW, Suite 702
Washington, DC 20036
City of Boise
Abigail R. Germaine
Deputy City Attorney
Boise City Attorney's Office
150 North Capitol Boulevard
P.O. Box 500
Boise, ldaho 83701-0500
ldaho Clean Energy Association
Preston N. Carter
GIVENS PURSLEY LLP
601 West Bannock Street
Boise, ldaho 83702
IDAHO POWER COMPANY'S PETITION FOR
RECONSIDERATION AND/OR CLARIFICATION - 41
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nthorpe@earth iustice, orq
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ldaho Sierra Club
Kelsey Jae Nunez
KELSEY JAE NUNEZ LLC
920 North Clover Drive
Boise, ldaho 83703
Zack Waterman
Michael Heckler
ldaho Sierra Club
503 West Franklin Street
Boise, ldaho 83702
PacifiCorp d/b/a Rocky Mountain Power
Yvonne R. Hogle
Rocky Mountain Power
1407 West North Temple, Suite 320
Salt Lake City, Utah 84116
Ted Weston
Rocky Mountain Power
1407 West North Temple, Suite 330
Salt Lake City, Utah 84116
lndustrial Customers of ldaho Power
Peter J. Richardson
RICHARDSON ADAMS, PLLC
515 North 27th Street (83702)
P.O. Box 7218
Boise, ldaho 83707
Dr. Don Reading
6070 Hill Road
Boise, ldaho 83703
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IDAHO POWER COMPANY'S PETITION FOR
RECONSIDERATION AND/OR CLARIFICATION . 42
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m ichael. p. heckler@qmail. com
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Micron Technology, lnc.
Austin Rueschhoff
Thorvald A. Nelson
Holland & Hart, LLP
555 Seventeenth Street, Suite 3200
Denver, Colorado 80202
Jim Swier
Micron Technology, lnc.
8000 South Federal Way
Boise, ldaho 83707
lnd ividual
Russell Schiermeier
29393 Davis Road
Bruneau, ldaho 83604
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l)/vhlJ-,oRiffi-eivT@aiiireAssistantIJ
IDAHO POWER COMPANY'S PETITION FOR
RECONSIDERATION AND/OR CLARIFICATION - 43
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[e-mail]
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