20201229Answer to Agripower Solar and Sierra Club.pdf

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IISA D. NORDSTROTI
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December 29,2020
VIA ELECTRONIC FILING
Jan Noriyuki, Secretary
ldaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg 8,
Suite 201-A (83714)
PO Box 83720
Boise, ldaho 83720-0074
Re Case No. IPC-E-20-26
ln the Matter of ldaho Porver Company's Application for Authority to
Modify schedule &4's Metering Requirement and to Grandfiather Existing
Customers with Two Meters
Dear Ms. Noriyuki:
Attached for electronic filing, pursuant to Order No. 34602, is ldaho Power
Company's Answer to Petitions for Reconsideration of Agripower Solar, LLC and ldaho
Sierra Glub.
lf you have any questions about the attached document, please do not hesitate to
contiac't me.
Very truly yours,
X*!.?(^ur."*,
Lisa D. Nordstrom
LDN:slb
Attachment
LISA NORDSTROM (lSB No. s733)
ldaho Power Company
1221 West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
I nordstrom@ ida hoporuer. com
Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANYS APPLICATION FOR
AUTHORIW TO MODIFY SCHEDULE
84's METERING REQUIREMENT AND TO
GRANDFATHER EXISTING CUSTOMERS
WTH TWO METERS.
CASE NO, |PC-E-20-26
IDAHO POVVER COMPANY'S
ANSWER TO PETITIONS FOR
RECONSIDERATION OF
AGRIPOWER SOIAR, LLC AND
IDAHO SIERRA CLUB
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On December 22, 2020, Agripower Solar, LLC ("Agripowe/') and the ldaho
Chapter of the Siena Club ("Siena Club') filed Petitions for Reconsideration ("Petilion')
requesting that the ldaho Public Utilities Commission ('Commission") reconsider the
portion of Order No. &485,4 regarding the cutoff date br grandfathering existing Schedule
84, Customer Energy Production Net Metering ("Schedule 84') customers. ldaho Power
Company ('ldaho Powef or "Gompany'), in accordance with ldaho Code $ 61-626 and
RP 331.05, files this Answer to both Agripower and Sierra Club's Petitions respec{fully
IDAHO POIA'ER COMPANY'S ANSVVER TO PETITIONS FOR RECONSIDERATION OF AGRIPOVT'ER
SOLAR, LLC AND IDAHO SIERRA CLUB- 1
requesting the Commission issue an order denying Agripower and Siena Club's Petitions
for reconsideration.
Agripower and Siena Club request the cutoff date be extended from December 1,
2020, to 30 daysl and 90 days2 from a final order on reconsideration, respectively. ln the
alternative, Agripower requests that the five (5) customers discussed in its petition be
deemed as having timely applications submitted and be afforded grandfathered status
under Order No. 34854.3 Last, Sierra Club's Petition rcquests the Gommission provide
certain clarifications regarding the extent of a future review of program changes.a
ln this Answer, ldaho Power first describes how the Company's Apptication,
correspondence, and Commission notices and press releases provided several months'
notice to both customers and installers regarding the Company's Application and the
proposed December 1, 2020, effective date. Second, ldaho Power responds to
Agripowe/s description of the events that occuned following the Commission's issuance
of Order No. 34854 on December 1,2020. Lastly, the Company explains why Sierra
Club's requested clarifications regarding a future program review are unnecessary.
2020
Agripower seeks reconsideration of the eligibility for grandfathering based on what
it claims were two "surprising" outcomes of the case: (1) to be eligible for grandfathering,
I Agripower Petition for Reconsideration at 1.
2 Sierra Club Petition for Reconsideration and Clarification at 5.
3 Agripower Petition for Reconsideration at '1.
' Siena Club PetiUon for Reconsideration and Clarification at 6-7
IDAHO POWER COMPANY'S ANSI/I,ER TO PETITIONS FOR RECONSIDERATION OF AGRIPOT/'/ER
SOLAR, LLC AND IDAHO SIERRACLUB- 2
a fully submitted applications had to have been received by December 1,2020, and (2)
grandfathering did not apply only to the "change proposed in the Application -the change
from dual meters to single meters - but rather to programmatic changes that had not yet
been proposed.'6 ln its Petition, Sierra Club requests the Gommission extend the cutoff
date for legary treatment by 90 days, stating generally that "the Company has been far
less than diligent in providing its customers with timelv and necessary information to make
informed decisions about the risks and benefits of being a customergenerator.'7 The
notice arguments of Agripower and Siena Club are without basis in fact and therefore
should be denied by the Commission.
A. All Schedule 84 Gustomers Received Several Months' Notice of the
December 1,2020 Grandfather Cutoff Date from ilIultiple Sources.
The Company, the Commission, and the Commission Staffs ('Stafl) efforts in this
case to notify the public of the potential impact of the Company's application were
transparent and thorough.
1. Application: The Company's Application submitted on June 19, 2020,
stated its request for the Commission to'grandfather existing customers and applicants
with two-meter systems under the cunent one-for-one net meterinq billino conshuct
provided for in Schedule &4.'8 The Application explained ffrat after the proposed
December 1, 2020 Effective Date, "
s As explained in the Company's Ansnrer to Gietzen Solar LLC's Petition for Reconsideration submitted on
December 24,2020, the Company's standard business practice as set brth in Schedule 72 is to consider
an application fully submifted once the application form and $100 application Ee are received.
6 Agripourer Petition for Reconsitleration at 3.
7 Siena Club Petition for Reconsideration and Clarification at 2 (emphasis in original).
0 Application at 1 (emphasis added).
IDAHO POWER COMPANY'S ANSVVER TO PENTONS FOR RECONSIDERATION OF AGRIPO\'\'ER
SOLAR, LLC AND IDAHO SIERRA CLUB.3
orandfathered, and therefore would be subject to anv future chanoes to the billins and
compensation structure provided under Schedule 84, or a suooessor tariff offering,
ordercd by the Commission."e
2. Bill lnseft Notice: ldaho Power sent a bil! insert to q!! Schedule 9, 19, and
24 customers, regardless of whether they have on-site generation installed, to notiff them
of the changes proposed to Schedule 84.10 lncluded as Attachment 3 to the Company's
Application, the bill insert notices were provided to approximately 55,000 customerc
between July 6 and August 4,2020. The bill insert states that the Company's request
was to "grandfatherexisting customers underthe cunentcompensation structurc.'lr The
notice also provided a link to the Commission's website, a phone number to contiact ldaho
Power, a link to ihe Company's customer generation webpage, and referenced Case No.
lPc-E-20-26.
3. lnstaller Email Notice: An emai! was sent to all installers known to be doing
business in the Company's service area on June 25, 2020, notiffing them of the case and
the requested effective date of December 1,2020. lncluded as Attachment 4 to the
Company's Application, the email starts with informing installers of ldaho Power's request
to "grandfather all existing Schedule 84 systems under the current compensation
stu@."12
eApplication at 56 (emphasis added).
10 ln Order No. 34346 issued in Case No. IPC-E-18-15, the Commission found the Company's limited
communication to only cunent and pending on-site generation customers as insufficient, noting 'the
Company did not send these documents to potential on-site generation customers...potential participants
who might be thinking about making a large investment in an on-site generation Bystem."
1, Application, Attachment No. 3 (emphasis added).
1z Application, Attachment No. 4 (emphasis added).
IDAHO POVVER COMPANY'S ANSV\JER TO PETITIONS FOR RECONSIDERATION OF AGRIPOWER
SOLAR, LLC AND IDAHO SIERRA CLUB.4
4. Commission Nofibes of Application: The Notice of Application Order No.
34728 (July 17, 20201and the tunended Notice of Application Order No. 34746 (August
5,2020) summarized the Company's request to require 'customers who sign up for
Schedule 84 on or after December 1,2A20 subiect to anv future Commission-aoproved
chanoes to the Schedule 84 billing methodologv and compensation struc-ture."13
5. Commission Public Wokshop Nofibe: On September 9, 2020, the
Commission issued Notice of Live-Streamed Public Workshop, which referenced the
Company's application for authority to "make customers who sign up for Schedule 84 on
or after December 1. 2020 subject to any future Commission aporoved chanoes to the
Schedule 84 billino methodoloov and compensation structure, and...grandfather
customers who have applied to take service under Schedule &4 before December 1. 2020
to the oresent terms in Schedule &4 for 10 years.' (emphasis added) On September 11,
2020, the Commission issued a press release to publicize the scheduled Staff live-
streamed workshop.
At the September 28, 2020 wo*shop, Staff provided an overview of the
Company's request to (1) modiff the two-meter requirement to a single meter requirement
for all new customerr, and (2) grandfather existing customers under the existing rate
structure. Mr, Joe Goodman, the President of Agripower, ('Mr. Goodman") provided
comments and asked clariffing questions at the workshop.
6. Commission Nofibes of Public Hearing and Modified Procedure: On
September 4,2020, the Commission issued Notice of Telephonic Public Hearing Order
No.34777 which referenced the Gompany's application for "authorlty to remove the two-
t3 Order No. 34728, at 1 and Order No. 34746, at 1 (emphasis added).
IDAHO POV\ER COMPANY'S ANSWER TO PETITIONS FOR RECONSIDERATION OF AGRIPOWER
SOLAR, LLC AND IDAHO SIERRA CLUB- 5
meter requirementfor new Schedule 84 customers and to orandfather existing customerc
with two-meter svstems under the cunent 1:1 monthly nettino for 10 years."r4 On October
1,2020, the Commission issued a press release publicizing the Commission's telephonic
public hearing.
The Commission heard from at least 13 individuals (including David Havell, an
installer with Agripower) at the October 13,2020, public hearing on this matter, most of
whom stated their interest was in representing agricultural customers. Several of those
individuals advocated for a 2$year grandfathering period and opposed the Commission
establishing a cutoff for grandfathering.
The Commission also received nearly 100 written comments in the matter,
submitted before the Commission's order was issued. Mr. Goodman also submitted a
written comment to the Commission on October 27 ,2020, more than a month in advance
of the Commission's order issued in this case. Based on the plain language of his
comment, Mr. Goodman appears to have understood the Company's request in this
matter quite well: he urges the Commission to implement a grandfathering period of at
least 25 years 'for those few inigation net-metering customers who relied on the terms
given them by ldaho Power when designing and installing their systems." Mr. Goodman
also urges the Commission not to establish a cutoff date to the existing terms defined by
Schedule 84 untilthe new net metering program is in place, These stiatements contradict
the argument in Agripowe/s Petition that it was surprised and unaware of the proposed
effective date for grandfathering and claims the Commission's order extends beyond what
was proposed in the Company's Application.
1r Order No. 34777 at 1 (emphasis added.)
IDAHO POVVER COMPANY'S ANSVVER TO PETITIONS FOR RECONSIDERATION OF AGRIPOWER
SOLAR, LLC AND IDAHO SIERRA CLUB- 6
As evidenced by these multiple forms of notice, customers and installers had
several months' advance notice of the December 1, 2A2O grandfather cutoff date.
Although ldaho Power is sympathetic to the impacts on the specific customers who did
not timely submit their applications and fees, the Company believes any inadequacies
were the result of a Iack of diligence rather than the lack of reasonable notice, geographic
proximity, or "dumb luck"15 argued by the petitioners.
B. Idaho Power has been Dlligent in its Efforts to Purcue a
Comprehensive Gase to Holistically Study the Costs and Benefits of
On-Slte Generation.
ln its Petition, Sierra Club claims that "by delaying the launch of a docket to study
the costrs and benefits of customer selfgeneration," the Company has not provided its
customers with the necessary information to make informed decisions.l6 The Siena Club
uses this argument as a basis to suggest the cutoff date for legacy treatment should be
extended by 90 days to February 1,2021. This assertion made by Sierra Club seems to
dismiss the work that went into the 16-month long case (Case No. IPC-E-18-15, in which
both the Company and Sierra Club participated) that was initiated by a Company
application filed less than one month after the Commission issued its final order in Case
No. IPC-E-17-13. The Company sought clarification in Case No. IPC-E-18-15 to
determine whether the outcome of the grandfathering decision in that case would apply
to the Company's commercia!, industrial, and irrigation ('Cl&!) customers; however, the
Commission ultimately determined that decision would be informed based on facts
presented in that case.
rs Agripower Petition for Reconsideration at 7.
t6 Sierra Club Petition for Reconsideration and Clarification at 2
IDAHO POWER COMPANY'S ANSWER TO PETITIONS FOR RECONSIDERATION OF AGRIPOWER
SOLAR. LLC AND IDAHO SIERRA CLUB- 7
The Company's subsequent filings to request closure of Case No. IPC-E-19-1S
and initiate Case No. IPC-E-20-26 have been timely and with an eye towards filing a
comprehensive case to holistically study the value of excess energy for all Cl&l
customers. While recognizing customer frustration about the current tack of information
to make investnent decisions is legitimate, the suggestion the Company has delayed
progress on these matters is without merit based on the numerous cases it has filed in
recent years to resolve these complex pricing and customer equity issues.
Establishing grandfather cutoffdates for allcustomer classes is an important step;
it will promote equity between customer classes and hcilitate full participation in the net
metering oompensation and fixed cost cases that ldaho Pourer will initiate at the
conclusion of this case and the on-site generation interconnection Case No. IPC-E-2Q,
30. ldaho Power is also concemed that instead of focusing on protecting customers who
have already made a financial investment, reconsideration to extend the grandfather
cutoff date beyond the seruice date of Order No. 34584, as proposed by Agripower and
Sierra Club, would undermine the future value of notice given in Commission dockets and
result in the preferential treatment of certain customers.
II. POTENTIAL IIf,PACTS TO SPEGFIC CUSTOMERS
Agripowe/s Petition provides five (5) specific examples of potential customer
impacts related to the December 1, 2020, cutoff date in Order No. 34854. tn several of
the accounts, Agripower focuses on the "unknown' grandfather cutoff date as a basis for
why the Comrnission should extend grandfathering treatment. For example, it ctaims on
behalf of the Meyers that "neither customer, nor Agripower Solar, could have anticipated
IDAHO POWER COMPANYS ANSWER TO PETITIONS FOR RECONSIDERATION OF AGRIPOWER
SOLAR, LLC AND IDAHO SIERRA CLUB- 8
that December 1 would be the cutoff date for legacy treatment.'l7 Hotrever, as more fully
described above, Agripower was keenty aware of the proposed cutoff date, and each of
the customers referenced had received notice of the pending case.
Agripowe/s Petition on behalf of the five customers is one of self-interest and not
solely to protect customer investments. For example, after notifying Agripower on
December 9,2020, that ldaho Power had still not received fully submitted applications
from Greg Nickell (or his lessee), in an email included as Attachment 1, the Agriporer
instalter replied, 'l figured as much. ln all our hurrying, we just plain left these ones out.
The good news is my lack of organization only cost us about $3 million." The statement
made bythe installer implies the customer had made no financialcommitment priortothe
Gommission order; instead, the installerwas motivated to submit an application to ensure
a multi-million{ollar sale on behalf of his employer.
ln its Petition, Agripower also claims - again, "upon leaming of the deadline" - that
Mr. Russell Schiermeier ('Mr, Schiermeier") drove to Boise to write out nearly 100 checks
for application fees, so applications for several customers would be considered fully
submitted by the date of the order. Unfortunately, Agripower misreprcsents that three of
those application fees were intended to be submitted on behalf of Russell Patterson ("Mr.
Patterson') by claiming "Mr. Schiermeier failed to identify in the 'memo' field that any of
these checks were for Russell Patterson's installations."ls
To clarify for the Commission, there was no opportunity for the Company or Mr.
Schiermeier to commit an oversight concerning Mr. Patterson's installations because Mr.
17 Agripower Petition for Reconsideration at 7
lE Agripower Petition for Reconsideration at 8.
IDAHO POVi/ER COMPANY'S ANSWER TO PETITIONS FOR RECONSIDERATION OF AGRIPOVVER
SOLAR, LLC AND IDAHO SIERRA CLUB- 9
Schiermeier intentionally wrote a meter number on each cfreck submitted and aggregated
the checks in envelopes, by cttstomer. On each envelope, Mr. Schiermeier wrote the
customer name, meter numbers, and check numbers contained within. Upon receiving
an inquiry from the installer, ldaho Power provided copies of each of the envelopes to
verify there were none submitted on behalf of Mr. Patterson. ln a follonv-up phone call
with the Company on December 9, 2020, the installer admitted it was an Agripower
oversight that the custome/s application bes were not submitted in a timely fashion.
In its Petition, Agripower also accuses ldaho Power of refusing 'to apply any of
these submitted funds, even for withdrawn applicants, toward Mr. Patterson's system."le
It is not common practice, nor should it be, for the Company to apply a check, written on
behalf of a particular customer and a certain meter point, to an unrelated customer at the
request of an installer.
Finally, it should be noted that Agripower only explicitly states a financial
commitment was made on behalf of Danell and Jordan Funk, Double Eagle Dairy;2o it
does not expressly state if any of the otherfour (4) specific examples of customer impacts
had made a binding financial commitment. ldaho Power has no record that a binding
financial commitnent occurred. To the extent that a custome/s application had not been
received by ldaho Power and has not made a financia! commitment by December 1,2020,
the customer would not be financially harmed by the Commission's order. lnstead, a
customer would know that they are subject to the cunently undefined terms of the non-
It Agripourer Petition br Reconsideration at 8.
zo ldaho Power received 17 applications underthe namos Double Eagle Dairy, DarrellM. Funk, and Double
Eagle properties between August and October 202O that would be eligible for grandfather status if
interconnected within one (1) year. An additional2S applications werc received by ldaho Power under the
names Danell M. Funk and Double Eagle Properties on December 18,2020.
IDAHO POWER COMPANY'S ANSVVER TO PETITIONS FOR RECONS]DERATION OF AGRIPOVI,ER
SOLAR, LLC AND IDAHO SIERRA CLUB- 10
grandfathered successor program, which is what the Company believes was the intention
of the Commission's order.
II!. SIERRA CLUB'S REQUEST TO CLARIFY FUTURE PROGRAM REVIEW
ln its Petition, Sierra Club requested the Commission clarify the extent of a future
program review and implies, through its requested clarification, that ldaho Power intends
to limit its customers' right to self-generate.2l While the Company does not believe it is
necessary forthe Commission to further clariff beyond its existing orders and ldaho Code
S 61-119(1)'s implication that generation for one's own use is legally permissible, the
Company wishes to respond to Sierra Club's Petition.
First, and most importantly, the Company reiterates its support for its customers'
right to generate a portion of their energy needs. ldaho Power has supported this right
since its first customerwith on-site generation started taking net metering service in 1997.
ln fact, in 2001, afrer receiving feedback from potential net metering customers that the
then-current provisions governing net metering service were difficult to understand and
cumbersome to implement, ldaho Power voluntarily applied to the Commission to
establish Schedule 84. Recently, the Company has also proactively taken steps to
expand optionali$ to customers desiring to interconnect non-exporting systems.2z
ln its Petition, the Sierra Club appears to conflate ldaho Powe/s desire to
modernize both net metering program fundamentals and pricing of exported energy with
a desire to curtail a custome/s right to self-generation. As it has maintained in several
21 Siena Club's Petition for Reconsideration and Clarification at 5.
22 ln the Matter of ldaho Power @mpany's Application to Establisfr Tariff Schedule 68 - lnterconnections
to Customer Distributed Energy ResourcEs, Gase No. IPC-E-20-30.
IDAHO POWER COMPANY'S ANSWER TO PETITIONS FOR RECONSIDERATION OF AGRIPOWER
SOLAR, LLC AND IDAHO SIERRA CLUB- 11
recent net metering and pricing-related cases2s in front of the Commission, ldaho Power
is focused on establishing practices and implementing rate designs for all customers, as
well as compensation structures for customers with on-site generation, that will be fair
and sustainable into the future.
Sierra CIub also asks the Commission to modiff its prior direc'tion as it relates to
what should be included in (or more pointedly out of) scope in the frrture case. ln Order
No. 34546 issued in Case No. IPC-E-18-15, the Commission found it reasonable that the
issues for study, as presented in Table 1 to the first Staff Report issued in that case, could
serve as the basis for a scoping recommendation in a future case.2a This comprehensive
list was developed with input from parties to Gase No. IPC-E-18-15, and includes: costs
to serve grid consumption, several value streams of exported energy (including those
listed by Sierra CIub in their Petition2s), and rates and rate design. Further, the
Commission affirmed in Order No. 34854 that the 100-kW limit is appropriately considered
after program fundamentals (like those expected to be included in a future study) are
addressed. Therefore, ldaho Power believes the Commission has prcviously addressed
the matters identified in the Siena Club's request sucfi that no further clarification is
neoessary.
tv. coNcLUStoN
ldaho Power respectfully requests the Commission issue an order denying
Agripower and Sierra Club's Petitions for reconsideration and find that (1) potential
23 Case Nos. IPC-E-12-27,lPC-E-17-13, IPC-E-I8-15, !PC-E-18-16, IPC-E-I9-15, and IPC-E-20-26.
2a Order No. 34546 at 7.
25 Siena CIub's Petition br Reconsideration at 6-7.
IDAHO POYI'ER COMPANY'S ANSVVER TO PETITIONS FOR RECONSIDERATION OF AGRIPOWER
SOLAR, LLC AND IDAHO SIERRA CLUB- 12
customers and installerc received reasonable notioe of the Company's Application and
the potential changes to the Schedule &4 tariff, (21 a system with a fully submitted
application (both application form and be) physically received by the Company on or
beforc December 1,2020, is eligible for to be grandfathered under the one-br-one net
metering billing conEtruct in place prior to that date if interconnected within one year of
their application date, and (3) further clarification requested in Sierra Club's Petition is not
warranted.
DATED at Boise, ldaho, this 29th day of December 2A20.
X*!-(^*t,.*,
Lisa Nordstrom
Attomey for Idaho Porer Company
IDAHO POV\'ER COMPANY'S ANSVVER TO PETITIONS FOR REGONSIDERATION OF AGRIPOWER
SOLAR, LLC AND IDAHO SIERRA CLUB- 13
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 29th day of December, 2020, I served a true and
correct copy of the within and foregoing IDAHO POWER COMPANY'S ANS\IVER TO
PETITIONS FOR RECONSIDERATION OF AGRIPOWER SOLAR, LLC AND IDAHO
SIERRA CLUB upon the following named parties by the method indicated below, and
addressed to the following:
Commlssion Staff
Edward Jewell
Deputy Aftomey General
ldaho Public Utilities Commission
11331 West Chinden Blvd., Bldg No. 8
Suite 201-A (83714)
Boise, lD 83720-0074
ldaho lrrigation Pumpers Association, lnc.
Eric L. Olsen
Echo Hawk & Olsen, PLLC
505 Pershing Ave., Suite 100
PO Box 61 19
Pocatello, lD 83205
Hand Delivered
_U.S. Mail
Overnight Mail
_FA)(X Email [e-mail]
_Hand Delivered
U.S. Mail
_Overnight Mail
_FA)(X Email [e-mail]
Anthony Yankel
12700 Lake Ave. Unit 2505
Lakewood, OH 44107
ldaho Conservation League
Benjamin J. Otto
ldaho Conservation League
710 N.6th Street
Boise, lD 83702
City of Boise City
Scott Muir
Deputy City Attorney
Boise City Attorney's Office
105 N. CapitolBlvd.
PO Box 500
Boise, ID 83701-0500
_Hand Delivered
U.S. Mail
Overnight Mail
_F$(X Email [e-mail]
_Hand Delivered
U.S. Mail
Overnight Mail_FA)(X Email [e-mail]
Hand Delivered
U.S. Mail
Overnight Mail_ Fru(X Email [e-mail]
IDAHO POI/I/ER COMPANY,S ANSVI,ER TO PETITIONS FOR RECONSIDERATION OF AGRIPOVVER
SOLAR, LLC AND IDAHO SIERRA CLUB. 14
illicron Technology, lnc.
Austin Rueschhoff
Thorvald A. Nelson
Holland & Hart, LLP
555 17th Street, Suite 3200
Denver, CO 80202
Jim Swier
Micron Technology, lnc.
8000 South FederalWay
Boise, lD 83707
ldaho Sierra Club
Kelsey Jae
Law for Conscious Leadeship
920 N. Clover Dr.
Boise, lD 83703
Lisa Young
Mike Heckler
ldaho Sierra Club
503 W Franklin St.
Boise, lD 83702
lndividual
Russell Schiermeier
29393 Davis Road
Bruneau, ID 83604
Gietzen Solar
Logan Gietzen
120 gth Ave. S.
Buhl, ldaho 83316
Hand Delivered
U.S. Mail
Overnight Mail
_ FA)(X Email [e-mail]
tnelson @hollandhart.com
[e-mail]
o lqa rganoamari@ holla nd ha rt. com
Hand Delivered
U.S. Mail
Overnight Mail
_ FA)(X Email [e-mail]
_Hand Delivered
U.S. Mail
Overnight Mail
_FAXX Email [e-mail]
_Hand Delivered
U.S. Mail
_Overnight Mail
_F$(X Email [e-mail]
michael.o. [e-mail]
_Hand Delivered
U.S. Mail
_Overnight Mail
_FN(X Email [e-mail]
_Hand Delivered
U.S. Mail
Overnight Mail
_FA)(X Email [e-mail]
IDAHO POWER COMPANY,S ANSV\,ER TO PETITIONS FOR RECONSIDERATION OF AGRIPOWER
SOLAR, LLC AND IDAHO SIERRA CLU& 15
Agriporuer Solar, LLC
Prcston N. Carter
Blake W. Ringer
Givens Pursley LLP
601 W. Bannock St.
Boise, ldaho 83702
_Hand Delivered
U.S. Mail
Overnight Mail_F$(X Email [e-mail]
[e-mail]
Stephanie L. Buckner,
Executive Assistant
IDAHO POVIIER COMPANY'S ANSVI/ER TO PETITIONS FOR RECONSIDERATION OF AGRIPOVI'ER
SOLAR, LLC AND IDAHO SIERRA CLUB- 16
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-E-20-26
IDAHO POWER COMPANY
ATTACHMENT
IDAHO POWER COMPANY'S ANSWER TO PETITIONS
FOR RECONSIDERATION OF AGRIPOWER SOLAR,
LLC AND IDAHO SIERRA CLUB
TO
Hom;
To:
$blcct:
Date:
Ittlc'ftmdrE:
Aaloo-hEloclc
[E(ERllAt]RE: New Net Meterlng Applcadons
Frldry, Decanbc 11, 2020 1:05:58 Ptr{
lnaoe00l -nno
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tnagdns.mo
KEEP IDAIIO POWER SECUR"E! External emails may rcquest information or contain
malicious links or attachments. Veriff the sender before proceeding, and check for additional
waming mcssages below.
| figured as much. ln all our hurrying, ljust plain left these ones out,
The good news is my lack of organization only cost us about 53 million
From: LOC. CG <[e-mail]>
Sent: Friday, December ll,2O2O 12:58 PM
To: Aaron Pace <[e-mail]>; LOC. CG <[e-mail]>
Subject: RE: New Net Metering Applications
HiAaron,
These two were not included with the 5 we received for DC Farms.
Thanks
Shawn
From: Aaron Pace <aaront0aSripowersolar >
Sent: Wednesday, December9,2O2O 9:13 AM
To: LOC. CG <CG@idahopower-com>
Subiect IEKTERNAL][WARNING: MESSAGE ENCRYPTEDIFW: New Net Metering Applications
KEEP IDAHO POWER SECUREI External emails may request information or contain malicious links or
attachments. Verify the sender before proceeding, and check for additional warning messages
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Team CG,
Will you check to see if these applications were received along with the flurry that went in on the
1st?
Aaron
From: Aaron Pace
Sent: Tuesday, December L,2020 3:08 PM
To: davidcoop@f mail.com; greg@ nickell.org
Cc: Joseph Goodman <[e-mail]>; Marty Baird <[e-mail]>
Sublect: New Net Metering Applications
David,
l'm not sure if anyone has spoken to you about these yet or not, but these are net metering
applications for a couple of solar installations on the farm you lease from Greg Nickell. These need to
be submitted today to ldaho Power along with their S100 check. Please scan the signed application
and checks and send them to [e-mail]. lt is preferred that the applications physically
get to ldaho Power though I imagine that will be difficult. Please FedEx them to arrive tomorrow if
possible.
tr
Aaron Pace
Chief Data Officer
AgdPower Solar
ffi +180t{70-7662
ffi [e-mail]
* urnvw-agrigorersolar.com
B 40 W Truman Ave, Salt Lake City, UT 84115
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