20211105Answer.pdf

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LISA D. NORDSTROT
Lead Counsel
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Enclosures
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An |DACORP Comp.ny
November 5,2021
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-21-U
Randy Valley v. ldaho Power Company
Dear Ms. Noriyuki:
Enclosed for electronic filing, pursuant to Order No. 35058, please find ldaho
Power Company's Answer.
lf you have any questions about the attached documents, please do not hesitate
to contact me.
Very truly yours,
Lisa D. Nordstrom
LISA D. NORDSTROM (lSB No. 5733)
ldaho Power Company
1221 West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
[e-mail]
Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
Randy Valley,
Complainant,
Case No. IPC-E-?l-U
IDAHO POWER COMPANY'S
ANSWERvs.
ldaho Power Company,
Respondent.
COMES NOW ldaho Power Company ("Respondent," 'ldaho Powef or
"Company'), and pursuant to Procedural Rule 57, now answers the Summons of the
ldaho Public Utilities Commission ("Commission') dated October 15,2021, concerning
the forma! Complaint ('Complaint") of Randy Valley ('Complainant" or'Mr. Valley"). Mr.
Valley takes service under Schedule 6, Residential Service On-Site Generation
("Schedule 6"). The Complainant seeks review of, and relief from, ldaho Power's
application of the Commission's criteria for legacy status, or grandfathering, for residential
and smal! general service customers with on-site generation established in Order Nos.
IDAHO POWER COMPANY'SANSWER - 1
34509 and 34546.1
After describing the criteria for legacy status and the customer-generator
interconnection process, the Company answers and requests the Commission deny the
Complaint's requested relief because the Company correctly communicated the
requirements of the Commission's orders and tariffs; the Company correctly applied the
legacy status requirements set forth in the Commission's order; and it would be
inequitable to allow the Complainant additionaltime to perfect its claim to legacy status.
I. REQUIREMENTS TO PERFECT LEGACY STATUS
1. ldaho Power offers net metering service to customer-generators with the
intent to offset all or a portion of a customer's energy usage. As of September 30,2021,
ldaho Power provides net met metering service under Schedule 6 and Schedule 8, Small
General Service On-Site Generation ('Schedule 8") to 5,340 systems with legacy status
and an additiona! 3,129 systems without legacy status.
Speciffcs of Legacy Stafus
2. An "existing" system eligible for legacy status under Schedule 6 and
Schedule 8 is defined as:
"...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 and who proceeds to
interconnect their svstem within one vear of the service
date of this Order."2
1 ln the Matter of the Petition of ldaho Power Company to Study fhe Cosfg Benefits, and Compensation
of Net Excess Eneryy Supplied by Customer On-S/e Genemtion , Case No. IPC-E-I 8-1 5, Order Nos.
34509 and 34546.
2 ln the Matter of the Petition of ldaho Power Company to Study the Costs, Benefits, and Compensation of
Net Excess Eneryy Supplied by Customer On-S/fe Generation, Case No. IPC-E-18-15, Order No. 34509
at 14 (December 20, 2019). (emphasis added)
IDAHO POWER COMPANY'S ANSWER.2
3. The financialcommitment required for legacy status could be an obligation
to a third-party installer or supplier.
4. Schedule 68, lnterconnections to Customer Distributed Energy Resources
("Schedule 68"), defines interconnection with the Company's system and completion of
the interconnection process as successful completion of ldaho Power's on-site
inspection.3
5. !f a person or business had a financial commitment as of December 20,
2019, but had not submifted an application to ldaho Power, that person or business was
directed to submit an application to ldaho Power by January 20,2020, and submit receipts
with their application demonstrating that they made a financia! commitment on or before
December 20,2019.4
6. The Commission found it reasonable and just to provide legacy status to
the system, under the following criteria: (1) A customer who moves into a propefi with a
grandfathered net metering system gets to "inherit" the legacy status of the system; (2) lf
a system is offline for more than six months or is moved to another site, the legacy status
of the system is forfeited; (3) To allow for the replacement of degraded or broken panels,
the customer may increase the capacity of the legacy system by no more than 10 percent
of the originally installed nameplate capacity or 1 kilowatt ('kW'), whichever is greater;
and (4) Legacy status terminates December 20,2045.5
7. A customer with a legacy system can expand their system without losing
3 Schedule 68, lnterconnections to Customer Distributed Energy Resources, Sheet No. 68-12.
a Order No. 34509 at 14.
5 Order No. 34546 at 9.
IDAHO POWER COMPANY'S ANSWER. 3
the legacy status for the entire system if the output for the system expansion can be
metered separately.6
C ustom er G en erati on I ntercon n ection
8. The interconnection process for new systems and system expansions is
defined in Schedule 68.
9. Customers must submit a completed application form and application fee to
the Company. The Company will perform the Feasibility Review within seven (7) business
days, unless it is determined that additional studies are necessary, based on the project
information provided in the application. The Feasibility Review determines the capability
of the Company's electrical system to incorporate the proposed system and determines
if system upgrades are necessary.T
10. Idaho Power's standard business practice is to coordinate certain aspects
of the application process with a customer's agent as identified on the customer
generation application. ldaho Power typically coordinates with installers directly for the
benefit of the customer, as the installer is typically more familiar with the application
process. lt is also typical for an installer to complete the necessary permitting and
inspection requirements for the project and to submit the System Verification Form on
behalf of the customer.
11. Following receipt of the Approval to Proceed, the customer is responsible
for completing the system's installation and fulfilling allapplicable federal, state, and local
6 Order No. 34546 at 10.
7 Schedule 68, Interconnections to Customer Distributed Energy Resources Sheet No. 68-10.
IDAHO POWER COMPANY'S ANS\A'ER.4
inspection requirements.a
12. The customer must provide Idaho Power with a completed System
Verification Form detailing the specifications of all installed components of the completed
system.s
13. Once all required documentation has been submitted, and the Company
has verified that all applicable federal, state, and local requirements have been met, the
Company will complete, barring conditions beyond the Company's control, an on-site
inspection within ten (10) business days for a system with a total nameplate capacity of
100 kilovolt-ampere ("kVA") or less. to
14. Successful completion of the ldaho Power inspection constitutes the
conclusion of the application process. The customer will receive confirmation that the
application process has been completed. rt
Pertection of Legacy Stafus
15. As of December 20, 2019, there were approximately 590 applications
potentially eligible for legacy status under Schedules 6 and 8 if proof of financial
commitment was provided and the interconnection process was completed by December
20,2020.
16. As of December 20,2020, approximately 430 of the 590 systems completed
the interconnection process and perfected legacy status.
17. As of December 20, 2020, approximately 160 of the 590 systems did not
8 Schedule 68, lnterconnections to Customer Distributed Energy Resources Sheet No. 68-11.
e Schedule 68, lnterconnections to Customer Distributed Energy Resources Sheet No. 68-11.
r0 Schedule 68, lnterconnections to Customer Distributed Energy Resources Sheet No. 68-12.
11 Schedule 68, lnterconnections to Customer Distributed Energy Resources Sheet No. 68-12.
IDAHO POWER COMPANY'SANS\A'ER - 5
perfect legacy status. These systems did not perfect legacy status for a variety of reasons:
inability to provide proof of financial commitment; lack of response after submitting the
customer generation application; election to not move fonrvard with a particular project;
and/or inability to complete the interconnection process prior to the December 20, 2020
deadline. Some of these customers may experience inequitable treatment if the
Commission were to grant the relief requested by Mr. Valley in this Complaint.
II. FACTUAL BACKGROUND
18. The Complainant has taken net metering service under Schedule 6 at this
location in Mountain Home, ldaho, since April2013.
Existing Sysfem and Application for System Expansion
19. The Complainant has an existing system with 43 panels totaling 1 1.54 kW
that completed interconnection with ldaho Power in three (3) separate phases between
2013 and 2016. ldaho Power received a customer generation application from the
Complainant on September 16, 2019, requesting approvalof an additionalten (10) panels
rated at 3.1 kW (Attachment No. 1). The Complaint states that Mr. Valley has 53 solar
panels; however, only 43 are approved for interconnection with Idaho Power's system.
As of November 5,2021, the 10-pane! expansion has not completed the state electrical
or the ldaho Power inspection.
20. The Complainant listed RevoluSun as its installer ('RevoluSun" or "lnstalle/'
or "Agent") on the customer generation application (Attachment No. 1). RevoluSun is
familiar with ldaho Power's customer generation application process and interconnection
requirements. RevoluSun completed interconnection of approximately 16 systems for
ldaho Power customers in 2019, and 19 systems in2O2O.
IDAHO POWER COMPANY'S ANSVVER.6
21. ldaho Power sent the Complainant and RevoluSun the Approvalto Proceed
notification on September 17,2019 (Attachment No.2) for the 10-pane! system
expansion. This notification included the next steps required to complete interconnection:
o lnstallthe renewable generation system. Pass the state/city electrical inspectiono Submit a System Verification Form to ldaho Power. Pass ldaho Power inspection
22. The Approval to Proceed notice stated that if the interconnection of the
system expansion were not completed within one year, by September 16, 2020, the
application would expire.12
23. On January 7,2020, ldaho Power had a phone conversation with the
Complainant where ldaho Power discussed the requirements outlined in Commission
Order No. 34509 and notified it that for the system expansion to be eligible for legacy
status, Complainant would need to submit proof of financial commitment, submit the
System Verification Form, and complete interconnection of the system.
24. Confidentia! Attachment No. 3 contains the proof of financial commitment
submitted by the Complainant (the solar contract and a copy of checks payable for the
project) which was necessary to obtain legacy status if timely interconnection occurred.
This documentation was received by ldaho Power on January 9,2020.
25. On January 15,2020, ldaho Power sent confirmation that it had received
documentation indicating Complainant's financial commitment for the system expansion
occurred before December 20,2019.1n the confirmation email sent to the Complainant,
12 Schedule 68, lnterconnections to Customer Distributed Energy Resources Sheet No. 68-11 states:
Applications that are not completed within one year of the initial Feasibility Review are considered
expired. Cusforners requesting connection or approval of expircd applications are required to resubmit a
completed application form and $100 application fee and are subject to the full application process
described in Section 2. There is no active Customer Generation Application on file with ldaho Power.
IDAHO POWER COMPANY'S ANSWER - 7
ldaho Power extended the application expiration from September 16,2020, to December
20, 2020, pursuant to the deadline for systems to complete interconnection for legacy
status (Attachment No. 4 and attachment to the Complaint).l3 The confirmation email,
also provided a link where the customer could access the technical requirements and
application process on ldaho Power's website to complete interconnection by the
deadline (Attachment No. 4) and stated: "...to be eligible for grandfathering, systems
must also be installed and interconnected by December 20, 2020."
26. On January 21,2020, ldaho Power responded to Mr. Valley's email
regarding the documentation of a financial commitment required to proceed with the
interconnection process for the 10-panel system expansion (Attachment No. 5). ldaho
Power clarified his confusion, confirming what the January 15,2020 email stated - that
ldaho Power received the requested documentation (proof of financialcommitment before
December 20,2019). ldaho Power concluded, "ffi_..]]!.re., we will not need anything
else" (Attachment No. 5 and attachment to the Complaint, emphasis added) - there was
no other documentation that could be provided until installation and the state electrical
inspection occurred.
27. As described in the ldaho Power email confirming receipt of financial
documentation (Attachment No. 2), Mr. Valley and RevoluSun were responsible for
completing the application process pursuant to the tariff interconnection requirements:
"Following receipt of 'Approval to Proceed,' t'@Cus3rylgresponsible for completinq installation of the Customer
Generator System and fulfilling all applicable federal. state.
and local inspection requirements. Customers must also
provide the Company with a completed System Verification
13 Order No 34509.
IDAHO POWER COMPANY'S ANSVVER. S
Form detailing the specifications of all installed components
of the Completed Customer Generator System.'14
Follow-U p Com m unicati on
28. In addition to the communications with the Complainant, ldaho Power
followed up with the Complainant's agent, RevoluSun, six (6) times between June 2020
and December 2020. ldaho Power reminded RevoluSun that it had not received the
System Verification Form and that the system would risk forfeiting Iegacy status if
Complainant did not complete interconnection by December 1,2020 (Attachment Nos. 6-
8).
29. The Complaint statesls that ldaho Power should have sent the Complainant
the communications from June 23, July 8, August 26, and September 29,2020, rather
than sending to his agent, RevoluSun. However, on the signed application, Mr. Valley
gave ldaho Power permission to discuss the project directly with RevoluSun.lo
Additionally, the Company reached out directly to RevoluSun because ldaho Power
requests the System Verification Form be completed by the installer, licensed electrician,
or other qualified professional certification.
30. On June 23,2020,ldaho Power sent an email to RevoluSun indicating that
ldaho Power had not received the System Verification Form showing the additional panels
added had passed the electrical inspection. RevoluSun did not respond to this email
(Attachment No. 6).
1a Schedule 68, lnterconnections to Customer Distributed Energy Resources Sheet No. 68-11
1s Complaint at 1
16 Attachment No. 8. The interconnection application customer acknowledgement stated: I give my
permission for ldaho Power to dlscuss my prcject and electric usage history with the Project
Co ntacUCom p a ny I iste d abov e.
IDAHO POWER COMPANY'S ANS\A'ER - 9
31. On July 8,2020, after not hearing from RevoluSun, ldaho Power sent a
follow-up email. The lnstaller replied, indicating to Idaho Power that they were "waiting on
[a] status update from [their] operations team" and would respond "as soon as possible"
(Aftachment No. 6).
32. After not receiving a response for seven (7) weeks, ldaho Power again
followed up with RevoluSun via email on August 26,2020. The lnstaller acknowledged
that they had not addressed the issue due to "working remotely," and they would "get an
answe/' (Attachment No. 7).
33. Approximately five (5) weeks later, on September 29,2020, ldaho Power
sent another follow-up emailto the lnstaller, and again received no response (Attachment
No.7).
34. On November 6, 2020,ldaho Power sent another emai! to RevoluSun and
the Complainant requesting a status update and for RevoluSun to submit the System
Verification Form (Attachment No. 7).
35. Mr. Valley called ldaho Power on November 18, 2020, and the Company
orally explained that ldaho Power still had not received the System Verification Form for
the 1O-panelexpansion. Mr. Valley stated he would try to contact his lnstaller.
36. On December 1, 2020, after not hearing back from Mr. Valley, Idaho Power
sent another courtesy email and received a response from RevoluSun, indicating they
would "resolve before they lose grandfathering" (Attachment No. 8). ldaho Power did not
receive further communication from RevoluSun or Mr. Valley prior to the December 20,
2021, deadline.
37. Figure 1 provides a summary of all communications from ldaho Power to
IDAHO POWER COMPANY'S ANSTA'ER . 1O
the Complainant and/or RevoluSun from the time the Approval to Proceed was sent
(September 17, 2019) until the deadline to complete the interconnection process for
legacy status (December 20,2020\.
Fiqurel
38. On December 22, 2020, the Complainant and RevoluSun received an
automatically generated email from Idaho Power informing that the customer generation
application had expired (Attachment No. 9).
39. In an email exchange on December 30 and 31 , 2020, ldaho Power
responded to the Complainant's questions about what it meant that his application had
expired. First, ldaho Power explained that the Complainant could retain legacy status of
the existing 43-panel system by having the 10-panel expansion separately metered.
Second, ldaho Power explained that a new application and fee for the 1O-pane! expansion
Topic of Discussion
Communications witr:
Attachment Complainant RevoluSun
9t17t2019
ffit2020
1n5n020
1n1fi2020
6t23t2020
7t8/2020
8t26t2020
9ti29t2020
11t6t2020
fit18n020
1211t2020
Date Tvpe
Ernail
Phone
Ernail
Email
Ernail
Ernail
Ernai!
Email
Ernail
Phone
Ernail
Approvalto Proceed
Financial Comnitnent & Legacy Status
Financial Comnitrnent & Legacy Status
Reply to Financial Cormitnent Enail
System Veffi cation Status
System Verifi cation Status
System Verifi cation Status
System Vedfi cation Status
System Verification & Legacy Status
System Verifi cation Status
System Verification & Legacy Status
Attachrnent 2
NA
Attachrnent 4
Atachrent 5
Attachment 6
Attachnent6
Attachnrent 7
Attacfinnnt 7
Attachment 7
NA
Attachrnent 8
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ldaho Power Communication and Outreach Log
September 17,2019 - December 20,2020
IDAHO POWER COMPANY'S ANSI/VER - 11
would need to be submitted and would still need to pass a state electrical inspection. As
an alternative, ldaho Power indicated that the expansion could be installed with the
existing system, but that legacy status would be forfeited (Attachment No. 9).
40. On December 31 ,2020, RevoluSun submitted a service request to ldaho
Power requesting information on the cost to separately meter the 10-panelexpansion.
41. On February 25,2021,ldaho Power received a request to respond to an
informal complaint submitted by the Complainant to the Commission Staff.
42. ldaho Power responded to the Complainant's informa! complaint on March
2,2021.
43. On April 19, 2021, ldaho Power sent an emai! to the Complainant and
RevoluSun. This emai! was noticing the Complainant that if the 1O-panel expansion had
been installed, as previously indicated, that it needed to remain off unti! the application
process was completed. Attachment No. 10 shows a copy of this email and the listed
steps required to complete the application process: (1) submit an application, (2)
complete the state electric permitting process, and (3) submit a System Verification Form.
M. On May 24,2021, ldaho Power sent another emailwith identica! information
to what is included in Attachment No. 10 because ldaho Power had not received a
response from the Complainant or RevoluSun regarding the status of their 1O-panel
expansion. !f the expansion had been installed and was on, it would be out of compliance
with ldaho Power's interconnection requirements pursuant to Schedule 68, until it passed
an ldaho Power inspection.
45. On May 26, 2021, Commission Staff notified ldaho Power that the
Complainant intended to file a formal complaint.
IDAHO POWER COMPANY'S ANSWER - 12
46. On June 5,2021, RevoluSun sent an email to ldaho Power indicating that
RevoluSun had installed the 10-panel expansion on Mr. Valley's shop and the panels
were off and not producing power. RevoluSun stated that Mr. Valley and RevoluSun had
agreed to meter the panels on his shop separatelv from the existing system to maintain
the Iegacy status of the existing system. RevoluSun also stated that it would ensure
approvalwith plan review through the ldaho Division of Building Safety before submitting
a new customer generation application to ldaho Power (Attachment No. 11).
47. On September 21,2021, Idaho Power sent an emai! to RevoluSun to see if
there were any updates on the status of the project because ldaho Power had still not
received a new application for the 10-panel expansion. Attachment No. 12 includes the
response from RevoluSun where they indicated that Mr. Valley was now waiting on the
Commission to acknowledge the formalcomplaint ratherthan completing interconnection.
48. On October 15, 2021, the Commission issued a Summons and Forma!
Complaint issued against Idaho Power in Case No. IPC-E-21-34.
49. To date, Mr. Valley and RevoluSun have yet to complete the state electrical
inspection and submit the System Verification Form - both of which are required before
ldaho Powe/s inspection can be conducted to complete the interconnection of the 10-
panel expansion.
III. COMPLAINT
50. The Complaint presents three issues: whether the Company correctly
communicated the requirements of the Commission's order and tariffs; whether the
Company correctly applied the legacy status requirements set forth in Commission's
order; and whether the Commission should grant an extension of "time to meet the
IDAHO POWER COMPANY'S ANSIA'ER - 13
requirements for grandfathering of these 10 panels."17
51. The Complainant states that the "installer couldn't provide the necessary
documents with this short notice."l8
52. The Complainant requests 'time to meet the requirements for
grandfathering of these 10 panels.' le
53. The Company submits that it correctly communicated the requirements and
made several attempts to follow up with Mr. Valley and RevoluSun to ensure their
understanding.
il. The Company submits that it has correctly applied the Commission's legacy
status requirements set forth in Order Nos. 34509 and 34546 and the Commission-
approved interconnection requirements set forth in Schedule 68.
55. ldaho Power respectfully requests the Commission deny the relief sought
in the Complaint.
IV. ANSWER
56. ldaho Power reserves the right to supplement and/or amend its Answer if
Mr. Valley amends his Complaint, responds to discovery requests, or if additional
defenses arise throughout the course of discovery or otherwise.
57. ldaho Power respectfully requests the Commission deny legacy status and
not provide additional time to interconnect Mr. Valley's 10-panel expansion because the
Company correctly communicated the requirements of the Commission's orders and
17 Complaint at 2.
18 Complaint at 1.
leComplaint at 2.
IDAHO POWER COMPANY'S ANS\A'ER. 14
tariffs; the Company correctly applied the requirements set forth in Commission's legacy
status order; and it would be inequitable to allow the Complainant additional time to
perfect his claim to legacy status.
The Company Correctly Communicated the Requirements
58. The Complaint suggests that the Complainant and RevoluSun could not
provide the necessary documents with "this short notice." 20 However, the Complainant
and RevoluSun were made aware of the requirements to complete the state electrica!
inspection and submit the System Verification Form to ldaho Power when they received
the Approvalto Proceed on September 17,2019. The Approval to Proceed was sent more
than 12 months before the sixth courtesy follow-up emailfrom ldaho Power on December
1,2020.
59. Idaho Power's response stating "A!.,!h!il!re, we will not need anything else"
was in direct response to the documentation for proof of financial commitment
(Aftachment No. 4, emphasis added). The Approval to Proceed included details on
pending actions required to complete interconnection (Attachment No. 2). The Complaint
attempts to interpret the email from ldaho Power out of context to suggest that by
providing proof of financial commitment Mr. Valley was somehow able to bypass the
interconnection requirements for the 1 O-panel expansion.
60. Even if it were somehow reasonable to ignore the qualiffing "at this time"
clause, the Complainant did not (and still has not) satisfied the interconnection
requirements in place for all customer-generators without regard to Iegacy status. Mr.
Valley had previously completed the same interconnection process three (3) separate
20 Complaint at 1.
IDAHO POWER COMPANY'S ANS\A'ER - 15
times between 2013 and 2016; the Complainant had both prior knowledge of, and
experience with them.
The Company Correctly Applied the Requirements of Order f\los. 34509 and 34546
61. ldaho Power affirmatively defends that it followed the Commissions'
directive in Order Nos. 34509 and 34546. The Complainant did not refer to specific
provisions of statute, rule, order, notice, tariff, or other controlling law that the utility has
violated.
62. ldaho Power has consistently applied these criteria for all eligible
customers.
The relief requested is inequitable
63. The Complainant has requested "time to meet the requirements for
grandfathering of these 10 panels."
64. Pursuant to Order No. 34546, the options available to the Complainant are
to either: (1) Separately meter the 1O-panel expansion and retain the legacy status of the
existing system; or (2) Forfeit grandfather status of the entire system and complete
interconnection of the expansion behind the existing ffieter. zt
65. Mr. Valley had approximately 15 months (September 2019 to December
2020) to complete the interconnection process of the expansion, in order for both the
existing system and the 1O-panel expansion to receive legacy status. As of the date of
this Answer, it has been approximately 11 more months removed from the December 20,
2020 deadline for legacy status - in total, approximately 26 months from when the
Complainant received the Approval to Proceed along with the next steps required to
21 Order No. 345,46 at 11
IDAHO POWER COMPANY'S ANSWER - 16
complete interconnection as mentioned above. To date, the Complainant and RevoluSun
have failed to complete the state electrical inspection and submit the System Verification
Form - both of which are required before ldaho Power's inspection can be conducted to
complete the interconnection of the 10-panelexpansion.
66. As ldaho Power explained to both the Complainant and Staff, the Company
could not give more time to Mr. Valley without violating the Commission's directive for the
deadline for completing the system interconnection for legacy status by December 20,
2020.22 !n other words, regulatory compliance is an affirmative defense to the Complaint.
67. Further, it would be inequitable to other customers who did not timely
perfect their claim to legacy status to give the Complainant additiona! time beyond that
set by Order No. 34509. ldaho Power interprets ldaho Code S 61-315 as prohibiting the
preference that would result if more time were given for the Complainant to receive legacy
status for the requested 1O-panel expansion.
68. Although the Complaint fails to state a claim against ldaho Power upon
which relief can be granted in this forum, this does not preclude Complainant from
enforcing any legal rights it may have against its agenUinstaller to the extent Complainant
may have been damaged by the agent's actions.
69. ldaho Power reserves the right to assert any and all additional defense,
ascertained during the course of discovery or otherwise, by amendment to this Answer
as the Commission's rules, procedures, and/or Orders may allow and/or withdraw or
amend the above affirmative defenses.
22 Order Nos. 34509 and 34546.
IDAHO POWER COMPANY'S ANS\A'ER - 17
V. COMTUIUNICATIONS AND SERVICE OF PLEADINGS
70. Service of pleadings and communications with reference to this case should
be sent to the following:
Lisa D. Nordstrom
ldaho Power Company
1221West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
! n o rd strom@ id a ho power. co m
[e-mail]
Connie Aschenbrenner
ldaho Power Company
1221 West ldaho Street (837021
P.O. Box 70
Boise, ldaho 83707
caschen bren ner@ idahopower.com
ganderson@ idahopower.com
vt. coNcLusloN
71. ldaho Power supports customer-owned renewable generation to offset
consumption that is safely interconnected and appropriately priced for the benefit of all
ldaho Powe/s approximately 600, 000 customers.
72. As illustrated in this Answer, Mr. Valley and his agent, RevoluSun, failed to
complete the interconnection process by the December 20,2020 deadline set by Order
No. 34509. ldaho Power communicated these requirements to both the Complainant and
its agenUinstaller on multiple occasions, even though Complainant had successfully
completed the interconnection process three (3) times previously and Complainant's
installer had successfully completed interconnection requirements for at least 30 other
ldaho Power customers. Claiming ignorance of the interconnection requirements despite
clear evidence of repeated communication about them should not result in the
Complainant receiving additional time to perfect the legacy status eligibility of the system
expansion.
IDAHO POWER COMPANY'S ANSVVER - 18
\ ftIEREFORE, ldaho Pourer respectfully requests the Commission issue its Order
denying the relief sought by the Complainant.
Dated at Boise, ldaho, this 5h day of November 2021.
&;!.ffu*-,*,
LISA D. NORDSTROM
Attorney for ldaho Power Company
IDAHO POV\ER COMPANYS ANSV\IER - 19
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 5h day of November 2021 I served a true and
correct copy of the within and foregoing IDAHO POWER COMPANY'S ANS\ /ER upon
the following named parties by the method indicated below, and addressed to the
following:
Commission Staff
Riley Newton
Deputy Attorney General
Idaho Public Utilities Commission
472 West Washington (83702)
P.O. Box 83720
Boise, ldaho 83720-007 4
Randy Valley
3020 NE Scenic Valley Lane
Mountain Home, ldaho 83il7
_ Hand Delivered
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Stacy Gust
Regu latory Ad min istrative Assistant
IDAHO POWER COMPANY'S ANSWER.20
BEFORE THE
IDAHO PUBLIG UTILITIES COMMISSION
GASE NO. IPC-E-21-34
IDAHO POWER COMPANY
ATTACHMENT 1
vq""sffim.ftk,t;6;li;*'r-, ,
,",", ..fl kh)",fn,",*,.,,renewable generatlon systems (sobr, wlnd,Thls applicatlon ls an lnterconnectlon request for exlstlng ldeho
Customer Generation Application lrS^EC@rE0
hydro, blomass and fuel cell technologlesl.
Upon recelpt of the appllcatlon and fee, ldaho Power wlll retrl€u the prorect and detcmlne lf any upgrades to the ehctrlcal grld are needed. lf no
upgrades are neede4 customer wlll receive an approval to proceed. Apdhatlon and fee erplre one year after approval to proceed. Vlslt
www. idahooower.com/CustomerGeneratlon for lnformatlon about the lnterconnectlon process, tartff schedules, and credlt transfer ellglblllty.
All generatbn systems must satisfy the requlrements ln Sdteduh 72, Intcrconncctlons to Non-Utlllty Gcneration. Upon completlon of the
inter€onnectlon prooesi, customen wlll take seMce under one of the followlng schedules:
o ldaho Resldenthl customers - Schedule 05, Resldentlal Servlce On-Stte Genentlono ldaho Smal! General Serlce customers - Schcdule (8, Small General Servlce On-Stte Generatlonr All Or€gon qlstomers, and ldaho tartp Commercial, lriSatlon and lndustrla! customers - Scheduh 84, Customer EncBy Productlon/Na
MeterlrqServlce
1. Prolect trformatbn All Fields Required
2. ProfectGontrct (lnrtallelfil Fleds Requlrcd
3. Account Holdcr Acknowled3smcnt A ll Flelds Rqulrcd
M8 Aq, Srtr Zp
Currcntn.t"Sdr"dul" 01 Note.'Aotes0, odITrqulreslngbiaterdcstgn, Fr..-.. . t
Rotes @, ts, zt requrre twolmctlr datsn (untx aptvtns os a Demoistodon ,rd;;i HyH:T[l^[:H#ffi1'J#i"-"*effilth72lurcqulrunenB.
EdstlngproJectatlocatlon? EVesEtto lfyes,toutnameplateraUngofexlstlngprolect(kW): 2.9 kW
Account Number
Prolect [ocatlon Meter Number
Account Holder Randy Valley
Mwt bc thc custoopr/wrt h&cr on lhc lddp Pover G@nnt
3020 ScenicValley Dr. Mountain Home lO 83647
ProlrAType Proposed ProJectSlze (kW) r.t Phase: pSryte flthree Battery Backup: [Ves Etto
GsnGr.tor nsouro/Slrr Maxlmum Slze: 25 kW Residentlal and Small General Service; Maxlmum 9ze 1fi) kW LaEe Commerclal,
lndustrial, and lrrlgatlon. Sire deffned as nameplatc capacity of photovpltaic or turHnc powe. sourcc measurcd ln kilowatts (kW).
Tracker:@None flslngleArds[TwoAxls lf fl,cd,dhfrornhorizon(OgO'] 20 Odentatlon(S,SW,SE*".t SW
-
EWlnOr flofTurblnes- TurblneRaUng(kWrcl Manufacturer- Model-
E on"* Resoute typc
-
Gen€rfrr RatinS (lwl- Generator output E Ac E Dc
ls lnverter UL 17fl or IEEE1S4T llsted?@ves fluo Ino, what protectlon type?
vottage?lg- Phase @stngte flrhreerQ7
E sohr, flof rrarrrrar 10
ta
lftcrEriljg- Wattshe lezcil?- o uan,fast.rerEnphase Model
..^,-,MSE310BOBModuhRatiry(kwx) 310 M"nufa.ture, Misslg!Solar
so,"lD [e-mail] Phone(m)xs-m 208/968-6603
company Revolusun @nhct Janice Parma
E I certlfy that the lnformatlon provlded ln thls appllcatlon ls correct to the best of my knowhdge.
B ! understand that the on-slte generadon and net nrtering seMce, lncludllg the rate structure and lnterconnectlon requlrements, are
subjrtto dnnge ard that cun€ril rates do not rcpresent ftrture pridng.
E t Str" my permisslon for ldaho Powerto dlscr.rss my project and electrk usage hlstory wlth tE Ptolcft Contaa/pmpany listed above.
Name(rypcorprrm) RandyValley $snature '/< V OJ)JlS+f-
Phone (xl x-m 20U599.f678 Emalr [e-mail] ,K 7-E- ete
Once completed, please mailthls form and the non-refrrndable S10 appltcrtlon fee to:
U.S. Postal dellvery: ldaho Power Company Eryress dellvery: ldaho Power Company
Attn: Customer Generatlon, CHQ 8 Attn: Customer Gcnaratlon, CHQ 8
P.O. Box 70 1221 West ldaho Street
Bolse, lD &t707 Bolse, lD 83702
lf you lnYr eny
qucstlonl phrc crll
20&3tt{559of cm.ll
[e-mail]
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
GASE NO. IPC-E-21-34
IDAHO POWER COMPANY
ATTACHMENT 2
Sent:
lo:
GC:
From:
Subject:
Tue911712019 9:25 AM
jan ice. [e-mail]
[e-mail]
[e-mail]
Your application is approved! (lD 343)
RE: Solar projectfor 3020 Ne Scenic Way - Randall L Valley
Hello
We received your customer generation application on September 16, 2019 and conducted a review for
connecting your Solar project at 3020 Ne Scenic Way in Mountain Home. We have good news! Our
engineers have confirmed that no electrical grid upgrades are needed and you are free to move forward
with installing your 3.10 kilowatt system.
Your application approval is good for one year, so you have until September 16, 2O2O lo install your system
and ensure it is operational. lf your system isn't operational by September 16,2020, we'll need a new
application and fee to redo the engineering review because a lot can change in a year on our electrical grid
Now that your application has been approved, here are the steps for getting your project up and running:
Your Steps:
n lnstallyour renewable generation system.
a Pass the state/city electrical inspection. (Electrical inspection schedules vary depending on jurisdiction
and time of year. Please check with your loca! permitting office or ask your installer for an estimated
timeframe.)
o Submit a System Verification Form to ldaho Power. This form is our cue to get started on our steps.
ldaho Power's Steps:
n lnspect your system within 10 business days of receiving your System Verification Form
o Update you when your interconnection process is complete.
You can find forms and detailed information on interconnection requirements at:
www.idahopower.com/CustomerGeneration. lf you have questions about these processes or the
requirements, you can reach us at 208-388-2559 or [e-mail].
Sincerely,
ldaho Power
Customer Generation Team
ELMR4l, G/SO # 4598914
BEFORE THE
IDAHO PUBLIC UTILITIES GOMMISSION
GASE NO. IPC-E-21-34
IDAHO POWER COMPANY
CONFIDENTIAL
ATTACHMENT 3
SEE CONFIDENTIAL ATTACHMENT
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
GASE NO. IPC-E-21-34
IDAHO POWER COMPANY
ATTAGHMENT 4
From:LOC. CG
Wednesday, January 15,2020 3:01 PM
LOC. CG
LOC. CG
FW: On-Site Generation System Documentation
'rval msn.com';
Sent:
To:
Cc:
Subject:
Bcc:
Bcc:
Hello,
Thank you for your timely submission of requested documentation. Under the ldaho Public Utilities Commission Order
34509, if you made a binding financial commitment to install an on-site generation system, such as solar panels, prior to
or on December 2O 2019 you may be eligible to be "grandfathered" under the current compensation structure for on-
site generation. We have received your documentation showing a financial commitment for your system was made
prior to December 20, 20L9.
Per the commission's order, to be eligible for grandfathering systems must also be installed and interconnected by
December 20,2O2O.
More information about customer generation, including compensation structure, technica! requirements, and the
application process can be found at idahopower.com/customerseneration. More information about the case and the
order can be found at www.puc.idaho.gov.
lf you have additional questions, you can call our Customer Care team at [phone] or send us an email at
solutions@ idahooower.com.
Sincerely,
Your ldaho Power Customer Generation Team
2
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
GASE NO. IPC-E-21-34
IDAHO POWER COMPANY
ATTACHMENT 5
Sent:
To:
Cc:
Subiect:
From:LOC. CG
Tuesday, December 22,2020 8:39 AM
Randy Valley LOC. CG
Caitlin Trojacek; ashley.earl @revolusun.com
RE: On-Site Generation System Documentation
[EXIERNAL]Re: system expansion; RE: NM lD#343-RandallValley RE: [EXTERNAL]Re:
NM lD#343-Randall Valley; RE: NM lD#343-Randall Valley
Categories:Shawn
Hi Randy,
The emailyou received below was in regards to the required financial documentation showing that you had a financial
commitment with Revolusun for the expansion of your current solar project. That financial commitment was a
stipulation that the ldaho Public Utilities Commission (IPUC) put in place to allow your expansion to be grandfathered
into the then current compensation structure for on-site generation. The financial documents allowed us to extend the
expiration deadline of your project lo t2l20l2020 but the requirements for completing the project didn't change. Those
requirements are that the expansion project pass the State/City electrical inspection and your solar installer to submit a
System Verification form certifying that the inspection had taken place. Once we receive that form, our Meter Tech's
would then come out to make sure the expansion met the ldaho Power requirements for interconnection.
As we discussed on the phone in early December and with multiple emails and phone conversations with your installer,
in order to preserve the grandfathering status of the entire system, the expansion would need to be installed and
interconnected by the deadline of L2l2Ol2O2O per the IPUC order. The other ahernative to preserve grandfathering was
to have your expansion separately metered from the existing solar PV system.
Regards,
CG Team
From: Randy Valley <[e-mail]>
Sent: Tuesday, December 22,2020 7:53 AM
To: LOC. CG <[e-mail]>
Cc: Caitlin Trojacek <[e-mail]>; [e-mail]
Subject: [EXIERNAL] Re: On-Site Generation System Docu mentation
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 below.
I'm confused. Last year you I received the below email stating you received the required documents and you
didn't need anything else. I never heard anything about this again until a month ago and now you are saying
that my application has expired. I'm not sure that my installer knows exactly what is required and I certainly
don't know.
Please explain?
Attachments:
Thanks,
Randy Valley
From: LOC. CG <[e-mail]>
Sent: Tuesday, January 2L,2O2O 8:24 AM
To:'Randy Valley' <rvallev2@ msn.com>
Subject: RE: On-Site Generation System Documentation
Hi Randy, it looks like we received your documentation. At this time, we wil! not need anything else.
Thank you
CG Team
From: Randy Valley <rvallev2@ msn.com>
Sent: Saturday, January 18,2O2O 5:34 PM
To: LOC. CG <[e-mail]>
Subject: [EXTERNAL]Re: On-Site Generation System Documentation
KEEP IDAHO POWER SECURE! External emails may request information or contain malicious links or
attachments. Veriff the sender before proceeding, and check for additional warning messages below.
I haven't anything so I'm sure you have what is needed?
Thanks,
Randy Valley
Sent from my iPhone
On Jan 15,2020, at l2:00 PM, LOC. CG <[e-mail]> wrote
Hello,
Thank you for your timely submission of requested documentation. Under the ldaho Public Utilities
Commission Order 34509, if you made a binding financial commitment to install an on-site generation
system, such as solar panels, prior to or on December 20, 2019 you may be eligible to be
"grandfathered" under the current compensation structure for on-site generation. We have received
your documentation showing a financial commitment for your system was made prior to December 20,
2019.
Per the commission's order, to be eligible for grandfathering, systems must also be installed and
interconnected by December 20, 2020.
More information about customer generation, including compensation structure, technical
requirements, and the application process can be found at idahopower.com/customerqeneration. More
information about the case and the order can be found at www.puc.idaho.gov.
lf you have additional questions, you can call our Customer Care team at [phone] or send us an
email at [e-mail].
2
Sincerely,
Your ldaho Power Customer Generation Team
IDAHO POWER LEGAT DISCIAIMER
This transmission may contain information that is privileged, confidential andlor exempt from
disclosure under applicable law. lf you are not the intended recipient, you are hereby notified
that any disclosure, copying, distribution, or use of the information contained herein (including
any reliance thereon) is STRICTLY PROHIBITED. tf you received this transmission in error, please
immediately contact the sender and destroy the material in its entirety, whether in electronic
or hard copy format. Thank you.
3
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
GASE NO. IPC-E-21-34
IDAHO POWER COMPANY
ATTACHMENT 6
From:
Sent:
To:
Subject:
Categories:
Ashley Earl < ashley.earl @revolusun.com >
Wednesday, July 8,2020 7:41 AM
LOC. CG
IEXIERNAL]Re: NM lD#343-Randall Valley
Shawn
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 below.
I am waiting on status update from our operations team. I will get back to you as soon as possible.
On Wed, lul8,2O2O,7:04 AM LOC. CG <[e-mail]> wrote:
HiAshley,
I haven't heard back regarding the Randall Valley addition. Please respond as soon as possible.
Thank you
Shawn
CG Team
From: LOC. CG <[e-mail]>
Sent: Tuesday, June 23,2020 8:31 AM
To:'Ashley Earl' <ashlev.earl@ revolusu n.com>
Cc: LOC. CG <[e-mail]>
Subject: NM lD#343-Randall Valley
HiAshley,
I am following up on an application we received for RandallValley, 3020 NE Scenic Way in Mountain Home. tt looks like
back in Sept of 2019 an application was submitted for an additional 10 panels-3.10kw. We have not received the
system verification form showing that the additional panels added passed the electrical inspection. Do you have the
status ofthis project?
Thanks
1
Shawn Lovewell
Customer Generation Team
ldaho Power Company
208-388-2559
[e-mail]
IDAHO POWER LEGAL DISCTAIMER
This transmission may contain information that is privileged, confidentia! and/or exempt from disclosure
under applicable law. lf you are not the intended recipient, you are hereby notified that any disclosure,
copying distribution, or use of the information contained herein (including any reliance thereon) is STRICTLY
PROHIBITED. lf you received this transmission in error, please immediately contact the sender and destroy
the material in its entirety, whether in electronic or hard copy format. Thank you.
2
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
GASE NO. IPC-E-21-34
IDAHO POWER COMPANY
ATTACHMENT 7
To:
Cc:
Sent:
Subject:
From:LOC. CG
Friday, November 6,2020 8:21 AM
LOC. CG;Ashley Earl
[e-mail]
RE: NM lD#343-Randall Valley
Hello again, Ashley
We are still waiting to receive the system verification form for the 10 panel addition to Randall Valley's home. As you
know, in order for these additional 10 panels to qualify for grandfathering status, we will need to complete this project
bV t2l20l2020 per the IPUC order IPC-E-18-15.
Please submh the system verification form showing that the additional 10 panels installed have passed the state/city
electrical inspection.
Thank you
Shawn
CG Team
From: LOC. CG <[e-mail]>
Sent: Tuesday, September29,2020 8:03 AM
To: Ashley Earl <[e-mail]>
Cc: LOC. CG <[e-mail]>
Subject: RE : [EXTERNAL] Re: N M I D#343-Ra ndal I Valley
HiAshely,
It looks like we still have not received the system verification form for the additional 10 panels that were added. We
received the application for this addition in Sept of 2019. !t is set to expire soon, which would then require us to start
the process over (new app and fee). Please submit a system verification form certfiing that it has passed the state
electrical inspection so that we can schedule a site visit.
Thank you
Shawn
CG Team
From: Ashley Earl <as h lev.earl@ revolusu n.com>
Sent: Wednesday, August26,2O2O 8:52 AM
To: LOC. CG <[e-mail]>
Subiect: IEKIERNAL] Re: N M I D#343-Randall Va lley
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 below.
Unfortunately working remotely, some items get left unaddressed via email. I have Tuck in my office today and will get
an answer
On Wed, Aug 25, 2O2O,7:40 AM tOC. CG <[e-mail]> wrote:
1
HiAshely,
Just checking in again on the status of this project. The last correspondence we had was end of July and you were
waiting to hear from your operations team.
Thanks
RandallValley
3020 NE Scenic Way
Mountain Home,lD
Shawn Lovewell
Customer Generation Team
ldaho Power I Customer Relations & Energy Efficienry
L22LW.ldaho St I Boise, lD | 83702
Work 208-388-2559
[e-mail]
IDAHO POWER LEGAI DISCLAIMER
This transmission may contain information that is privileged, confidentia! and/or exempt from disclosure
under applicable law. lf you are not the intended recipient, you are hereby notified that any disclosure,
copying, distribution, or use of the information contained herein (including any reliance thereon) is STRICTLY
PROHIBITED. lf you received this transmission in error, please immediately contact the sender and destroy
the material in its entirety, whether in electronic or hard copy format. Thank you.
2
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
GASE NO. IPC-E-21-34
IDAHO POWER COMPANY
ATTACHMENT 8
Sent:
To:
Cc:
Subiect:
From:Ashley Earl < [e-mail] >
Tuesday, December 1,2020 1:14 PM
LOC. CG
[e-mail]
[EXIERNAL]Re: system expansion
KEEP IDAHO POWER SECURE! External emails may request information or contain malicious links or attachments. Verify
the sender before proceeding and check for additional warning messages below.
We are working on resolving this. Will make sure to have resolve before we lose grandfathering.
Ashley
On Tue, Dec 1,2020, 1:11PM LOC. CG <eG@jdg-ho@>wrote:
Hello,
I am reaching out once again on the status of the 10 panel system expansion. An application for this expansion was
submitted to ldaho Power on 9lt7 /2019 along with proof that there was a financial commitment prior to L2/2O/2O19.
As of today we have not received the System Verification form showing that this expansion has passed the state
electrical inspection. This application is set to expire on L2l2Ol2O20. The entire system is in jeopardy of losing
grandfathering status unless 1) we receive the SVF for the 10 panel expansion, or 2) the expansion gets separately
metered.
Please advise.
Shawn lovewel!
Customer Generation Team
ldaho Power I Customer Relations & Energy Efficiency
LzzlW.ldahoSt I Boise, lD | 83702
Work 208-388-2559
1
[e-mail]
TDAHO POWER f.E6At DtSCtAtMER
This transmission may contain infsrmation that is privileged, confidentlal and/or exempt from disclosure
under applicable law. lf you are not the intended recipient, you are hereby notified that any disclosure,
copying; distribution, or use of the information contained herein (includlng any reliance thereon! is STRICILY
PROHIBITED. lf you received this transmission in error, please immediately contact the sender and destroy
the material in its entirety, whether in electronic or hard copy format. Thank you.
2
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPG.E.21.34
IDAHO POWER COMPANY
ATTACHMENT 9
From:
Sent:
To:
Subject:
KEEP IDAHO POWER SECURE! External emails may request information or contain malicious link or attachments. Verify
the sender before proceeding, and check for additional warning messages below.
Thank you
From: LOC. CG <[e-mail]>
Sent: Thursday, December3L,2O2O 9:28 AM
To: Randy Valley <[e-mail]>
Subjec: RE: Expiration of ldaho Power Net Metering/Onsite Generation application for lD 343
Right now there is no difference. Right now customers receive a one for one credit on their bill. Grandfathered
customers will receive that one for one until 2045. Non-grandfathered customers are receiving that currently, but if the
tariff changes then they will be subject to those new rules.
lf you have a new service meter installed then it will be subject to the same monthly charge as your current service
meter. But as I mentioned in my email below, l'm not entirely sure of the costs for installation of that new service.
Shawn
From: Randy Valley <rvalley2@ msn.com>
Sent Thursday, December 31, 2O2O 9:21 AM
To: LOC. CG <[e-mail]>
Subject: [EKIERNAL]Re: Expiration of ldaho Power Net Metering/Onsite Generation application for lD 343
KEEP TDAHO POWER SECUREI External emails may request information or contain malicious links or attachments. Verify
the sender before proceeding, and check for additional warning messages below.
Let me ask my questions in a little different way
Are non-grandfathered panels compensated differently and if so, how are they compensated. How are
grandfathered pa nels compensated?
What is the monthly meter charge for the second meter?
Thanks,
Randy
From: LOC. CG <[e-mail]>
Sent: Thursday, December3L,2020 8:36 AM
Randy Valley < [e-mail] >
Thursday, December 31,2020 9:40 AM
LOC. CG
[EXTERNAL]Re: Expiration of ldaho Power Net Metering/Onsite Generation application
for lD 343
1
To: Randy Valley <lgal![e-mail]>; LOC. CG <[e-mail]>
Subject: RE: Expiration of ldaho Power Net Metering/Onsite Generation application for lD 343
Hi Randy,
The ldaho Public Utilities Commission grandfathered existing residential customers who had on-site generation as of
December 20,20L9 under the rules of ldaho Powe/s current service offering. So your current solar PV systems (not
including the expansion) would be grandfathered under the current compensation structure until 2045. One of the
conditions of receiving that 'grandfathe/ status was that your expansion of 10 panels had to complete the
interconnection process by the deadline that was put in place by the IPUC which was L212012020. The interconnection
process is completing the electrical inspection and having ldaho Power come out and do their inspection. Since that did
not occur, your expansion application expired and now needs to be re-submitted with a new application and application
fee.
To retain the grandfathered status of your current system, the expansion would need to be separately metered and
those 10 panels would need to be wired to that new service meter. I am not sure how much it costs to have a new
service installed and I know that you would need to have an electrician pull an electrical permit and pay them to do
some of the work. There would also be costs that would need to be paid to ldaho Power to install a meter, run conduit
and probably some other items that I am not clear on. A different department does that work, not Customer
Generation.
lf you want to forfeit grandfathering of your entire system, then you would just need to re-submit your 10 panel
expansion application along with the S100 application fee, have your electrical inspection pass, submit your system
verification form to us and we would come out to inspect it and make sure it is operational.
Hope this information is helpful
Thanks
Shawn
CG Team
From: Randy Valley <rvallev2@ msn.com>
Sent: Wednesday, December 30, 2020 2:53 PM
To: LOC. CG <[e-mail]>
Subiect: [EXTERNAL]Re: Expiration of ldaho Power Net Metering/Onsite Generation application for lD 343
KEEP IDAHO POWER SECURE! External emails may request information or contain malicious links or attachments. Verify
the sender before proceeding, and check for additional warning messages below.
I have some questions:
What does not being grandfathered mean?
How much is the monthly charge for a separate meter?
I'm sure I will need an electrician install what is needed for the second meter. ls that true?
Thanks,
2
Randy Valley
From: LOC. CG <[e-mail]>
Sent: Wednesday, December 30, 2020 9:55 AM
To: Randy Valley <[e-mail]>; LOC. CG <[e-mail]>
Cc: Ashley Earl <[e-mail]>; Caitlin Trojacek <[e-mail]>
Subiec: RE: Expiration of ldaho Power Net Metering/Onsite Generation application for lD 343
Hi Randy,
There are a couple of things that can be done. ln order to preserve the grandfathered status of your first 3 projects, the
expansion will need to be metered separately. What that means is a new service meter will need to be installed and the
10 additional panels that have been added will need to be connected to that new meter. Installing this new service
meter will incur additional costs for you.
Since the expansion application has expired, a new application and application fee will need to be re-submitted and will
need to pass the state electrical inspection.
The other option is to submit an new application and fee for the additional 10 panel expansion and forfeit the
grandfathered status of your entire system. The expansion still needs to pass the state electrical inspection and a system
verification form submitted by your installer so that we can come out and complete our inspection.
In the meantime, please make sure your system is offline. To the best of our knowledge, the additiona! 10 panels have
not passed the state electrical inspection which means that the AC Disconnect should be in the off or "open" position so
that it is not pushing back any electricity to the grid.
Thank you,
Shawn Lovewel!
Customer Generation Team
ldaho PowerlCustomer Relations & Energy Efficiency
L22LW. ldaho St I Boise, lD | 83702
Work 208-388-2559
[e-mail]
From: Randy Valley <[e-mail]>
Sent: Thursday, December 24, 2O2O 9:51 AM
To: LOC. CG <[e-mail]>
Subiec: [EXTERNAL]Re: Expiration of Idaho Power Net Metering/Onsite Generation application for lD 343
KEEP IDAHO POWER SECURE! Externalemails may request information or contain malicious links or attachments. Verify
the sender before proceeding, and check for additional warning messages below.
What does this mean for me? I'm not happy with the installer for not getting this done. I also feel that the
email I received from you last year was misleading which caused me to not stay after them to complete
whatever was needed.
3
Randy Va!ley
From: cg@ idahopower.com <cg@ ida hopower.com>
Sent: Tuesday, December 22,2O2O 5:46 AM
To: [e-mail] <[e-mail]>; [e-mail] <ashlev.earl@revo
Cc: [e-mail] <[e-mail]>
SubieC: Expiration of ldaho Power Net Metering/Onsite Generation application for 1D 343
Randall L Valley,
On 9/16/2019, ldaho Power received an application to install an on-site generation system at 3020 Ne
Scenic Way. According to our records, that system has not been completed and the application is now
considered expired. As noted in the rules for net metering and onsite generation, outlined in Schedule 72-
Interconnections to Non-Utility Generation:
Applications that arc not completed within one year of the initial Feasibility
Review are considered expired. Cusfomers requesting connection or approval of expircd
applications arc rcquircd to rcsubmit a completed application form and $100 application fee,
and arc subject to the full application process.
The purpose of the Feasibility Review is to ensure the components of the electrical grid in your area can
handle the energy load of the proposed on-site generation system. ln a 12-month period, much can change
to increase the demand on the electrica! grid, such as population growth or existing customers using more
of the system. A new feasibility review ensures the current demands of the electrical grid can support an on-
site generation system safely.
lf you have any questions, you can reach us at 208-388-2559 or by email at [e-mail].
Sincerely,
ldaho Power
Customer Generation Team
IDAHO POWER tEGAt DISCTAIMER
This transmission may contain information that is privileged, confidential and/or exempt from disclosure
under applicable law. lf you are not the intended recipient, you are hereby notified that any disclosure,
copying, distribution, or use of the information contained herein (including any reliance thereon) is STRICTLY
PROHIBITED. lf you received this transmission in error, please immediately contact the sender and destroy the
material in its entirety, whether in electronic or hard copy format. Thank you.
4
, j,1.
To:
Cc:
Sent:
Subject:
From:VM-CG
Monday, April 19, 20217:21 AM
[e-mail]
VM-CG
Solar PV System Expansion
Dear Mr. Valley,
We wanted to check in with you on your solar PV expansion at 3020 NE Scenic Valley Ln in Mountain Home. ln
September 2019, we received an application to add ten solar panels to the existing grandfathered system. The
application for the system expansion expired on December 20,2020, because the state electrical inspection was not
completed, and a completed System Verification Form was not provided to Idaho Power.
We understand that you may have installed the ten-panel expansion. lf so, please ensure that the expansion remains
off until you have completed the application process pursuant to Schedule 68 (lnterconnections to Customer
Distributed Energy Resources). The following steps are needed to complete the application process:
1) Submit a Customer Generation Application
2l Complete the state electric permitting process
3) Submit a Svstem Verification Form after the system is installed and successful completion of the state electrical
inspection.
As a reminder, your original 11.54 kW system is grandfathered. Pursuant to the ldaho Public Utilities Commission orders
in Case No. IPC-E-18-15. you have two options for system expansions:
1) Retain grandfather status for the original system by separately metering the system expansion.
2l Lose grandfather status for the original system and interconnect the system expansion behind the same meter
as the original system.
Per Schedule 58, if a system expansion does not complete the interconnection process it will be subject to immediate
Company inspection. lt may be necessary to lock off the system until the customer completes the interconnection
process or permanently disables the system.
lf you or your installer have any questions, please let us know. More information about our interconnection
requirements and the application process can be found at idahooower.com/customergeneration.
Sincerely,
ldaho Powe/s Customer Generation Team
1
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
cAsE NO. IPC-E-21-34
IDAHO POWER COMPANY
ATTACHMENT 11
Ftom:
Scnt:
To:
Subiect:
KEEP IDAHO POWER SECURE! External emails may request information or contain malicious links or attachments. Verifu
the sender before proceeding, and check for additional warning messages below.
Hello There,
I spoke w'tth Patty on Friday, June 4th with the CG Department and lwanted to follow up with a confirmation email per
our discussion.
Our customer Randy Valley at 3020 NE Scenic Valley Lane had 10 additional panels added by our company to his shop.
The panels are currently off and not producing any solar power.
Mr. Valley and Revolusun have agreed to add an additional meter to his shop to maintain the grandfathering on his
original system. We would like to ensure approval with plan review through the ldaho Division of Building Safety before
we submit his new customer generation application.
I simply wanted to make you aware that we will be applying for a new meter, a new CG application, and we will do so
after plan review through DBS.
Please let me know if you have any questions.
Thank you,
Caitlin
Caitlin Customer O Manager
idaho. revolusun.com
2149 East Summersweet Drive. Boise. lD 83716
208.315.4082 Office
Caitlin Trojacek <[e-mail]>
Saturday,June 5,2021 10:05 AM
VM-CG
[DffERNAL]System Expansion for Randy Valley
1
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
GASE NO. IPG-E-21-34
IDAHO POWER COMPANY
ATTACHMENT 12
Sent:
To:
Cc:
From:Caitlin Trojacek < [e-mail]>
Tuesday, September 21,2021 2:18 PM
Best, Patti
VM-CG
Re: [EXTERNAL]System Expansion for Randy Valley
KEEP IDAHO POWER SECURE! External emails may request information or contain malicious links or attachments. Verify
the sender before proceeding, and check for additional warning messages below.
Hello Patti,
These panels are still not operational and he is stillwaiting on the IPUC. So at the moment nothing has happened or
changed.
Thank you,
Caitlin
On Tue, Sep 21, 2O2Lat 10:58 AM Best, [e-mail]> wrote:
HiCaitlin,
Any updates on this project?
Patti B
From: Ca'rtlin Trojacek <[e-mail]>
Sent: Saturday, June 5,2021.10:05 AM
To: VM_CG <CG @ idahopower.com>
Subject [EffERNAL]System Expansion for Randy Valley
KEEP IDAHO POWER SECUREI External emails may request information or contain malicious links or attachments.
Verify the sender before proceeding, and check for additionalwarning messages below.
Hello There,
I spoke with Patty on Friday, June 4th with the CG Department and I wanted to follow up with a confirmation email per
our discussion.
Subject:
1
Our customer Randy Valley at 3020 NE Scenic Valley Lane had 10 additional panels added by our company to his shop.
The panels are currently off and not producing any solar power.
Mr. Valley and Revolusun have agreed to add an additional meter to his shop to maintain the grandfathering on his
original system. We would like to ensure approval with plan review through the ldaho Division of Building Safety before
we submit his new customer generation application.
I simply wanted to make you aware that we will be applying for a new meter, a new CG application, and we will do so
after plan review through DBS.
Please let me know if you have any questions.
Thank you,
Caitlin
Caitlin T Customer rations Manager
idaho. revolusu n.com
2149 East Summersweet Drive. Boise, lD 83716
208.315.4082 Olfice
IDAHO POWER tEGAt DISCLAIMER
This transmission may contain information that is privileged, confidential and/or exempt from disclosure
under applicable law. lf you are not the intended recipient, you are hereby notified that any disclosure,
copying, distribution, or use of the information contained herein (including any reliance thereon) is STRICTLY
PROHIBITED. lf you received this transmission in error, please immediately contact the sender and destroy
the material in its entirety, whether in electronic or hard copy format. Thank you.
2