20220824Comments on Reconsideration.pdf

Megan Goicoechea Allen
Corporate Counsel
[e-mail]
August 24,2022
Jan Noriyuki, Secretary
ldaho Public Utilities Commission
11331 W. Chinden Boulevard
Building 8, Suite 201-A
Boise, ldaho 83714
Case No. IPC-E-21-37
Application of ldaho Power Company for Authority to Establish A New
Schedule to Serve Speculative High-Density Load Customers
Dear Ms. Noriyuki
Attached for electronic filing is ldaho Power Company's Comments on
Reconsideration in the above-entitled matter.
lf you have any questions about the aftached documents, please do not hesitate to
contact me.
Sincerely,
3Em.
Megan Goicoechea Allen
AnD OOIPComtrrny
P.O. Box 70 (83707)
t221 W. ld.ho 5t.
Boisr. lO 63702
-; .:'r.",',1.' ,i!i.. '-'i '
Re
WTicni^t^0fllorr
MGA:sg
Enclosure
MEGAN GOICOECHEA ALLEN (lSB No. 7623)
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]
mooicoecheaallen@ida hopower.com
! n o rdstrom@ ida hopowe r. com
Attorneys for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTIL]TIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
AUTHORITY TO ESTABLISH NEW
SCHEDULE TO SERVE SPECULATIVE
HIGH.DENSITY LOAD CUSTOMERS.
CASE NO. |PC-E-21-37
IDAHO POWER COMPANY'S
COMMENTS ON
RECONSIDERATION
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On July 6, 2022, GeoBitmine LLC ("GeoBitmine" or "Petitionef), a prospective
customer of ldaho Power Company ("ldaho Powe/' or "Company") submifted a Petition
for Reconsideration of ldaho Public Utilities Commission ("Commission") Order No. 35428
authorizing Schedule 20 - Speculative High-Density Load ("Schedule 20"). These
comments are made pursuant to Rule 332 of the Rules of Procedure of the Commission
and the Order granting GeoBitmine's Petition for Reconsideration, Order No. 35488
issued August 3,2022.
ln authorizing the creation of a new electric service schedule to provide service to
potential HDL customers, the Commission noted that establishing Schedule 20 was "a
reasonable approach to proactively mitigate potential stranded asset costs to its core
IDAHO POWER COMPANY'S COMMENTS ON RECONSIDERATION - 1
customers."l Subsequently, in response to GeoBitmine's request for reconsideration of
this decision, the Commission found additional consideration of certain issues raised in
GeoBitmine's Petition would be appropriate, though it noted that the issue of Idaho
Power's determination of Schedule 20's applicability to GeoBitmine was beyond the
scope of this case.2
The Company appreciates the opportunity to offer additional comments on the
issues raised by GeoBitmine's Petition and to explain why Order No. 35428 was
reasonable, lawful, appropriate, and in conformity with the law. Specifically, as set forth
more fully herein: 1) the law and case record support establishment of Schedule 20;2)
Schedule 20's applicability criteria are appropriate to identify speculative, transient loads
that pose heightened stranded asset risk; and 3) recent cryptocurrency market conditions
validate the need for the Commission's adoption of Schedule 20 to protect customers
from the potential of cost shifts from stranded assets.
I. THE LAW AND CASE RECORD SUPPORT COMMISSION ESTABLISHMENT
OF SCHEDULE 20.
The service parameters and rates in Schedule 20 are reasonable and in
conformance with ldaho Code S 61-315, do not discriminate between similarly situated
customers, and are consistent with prior Commission determinations of rate
differentiation.
Moreover, moratoriums on new service for cryptocurrency mining customers have
1 Order No. 35428, p. 6.
2 Order No. 35488, p. 9-10 ("While we agree that GeoBitmine may have a substantial interest in whether
the Company appropriately required GeoBitmine to take service under Schedule 20, we find this issue to
be beyond the scope of this case and appropriately addressed in a separate proceeding or agreement
between the Company and GeoBitmine.').
IDAHO PO\A'ER COMPANY'S COMMENTS ON RECONSIDERATION - 2
been placed or upheld in several cities and local public utility districts in Washington State,
and the New York State Senate recently passed a moratorium sent to the governor for
signing, which while not binding on this Commission is persuasive of the need for
differentiation. Similarly, local regulators found it appropriate to set a special energy rate
structure for evolving industries including cryptocurrency mining, which was affirmed by
the U.S. Court of Appeals for the Ninth Circuit.3
Schedule 20 is non-discriminatory and consistent with decisions of the ldaho
Supreme Court.a The Commission acted lawfully and prudently in approving the
establishment of a separate rate class to protect al! other customers from potential cost-
shifts. GeoBitmine makes claim that "Schedule 20 was approved by the Commission in
complete disregard for any of the five factors identified by the ldaho Supreme Court in the
Homebuilders decision."s Idaho Power disagrees. ln reviewing the Commission's
authority to regulate and fix charges and rates in a non-discriminatory and non-
preferential manner, the ldaho Supreme Court noted: "Not alldifferences in a utility's rates
and charges as between different classes of customers constitute unlawful discrimination
or preference. . . "6 The Court confirmed that the setting of different rates and charges for
the different classes of customers may be justified by "a reasonable classification of utility
3 Cytline, LLC v. Pub. Util. Disf. No. 2 of Grant Cnty., Washington, S4g Fed.Appx. 656 (9h Cir. 2021). See
also Ninfh Circuit Affirms Specia/ Power Rate for Cryptocunency Miners, Sidley Environmental and
Energy Brief, March 18,2021,
https://sidlevenerqvbloq.sidlev.com/ninth-circuit-affirms-soecial-oower-rate-for-crvptocurrencv-miners/
a Seq e.9., ldaho State Homebuilders v. Washington Water Power,107 ldaho 415, 420,690 P.2d 350,
355 (1e84).
5 Petition for Reconsideration, p. 13.
6ldaho State Homebuilders,l0T ldaho a1420,690 P.2d at 355.
IDAHO POWER COMPANY'S COMMENTS ON RECONSIDERATION - 3
customers" based on factors such as cost of service, quantity of electricity used,
differences in conditions of service, or the time, nature, and pattern of use.7
Consistent with the legal precedent specifically identiffing "time, nature, and
pattern of use" as factors that may justiff separate classification of customers, ldaho
Power's Application highlights the transitorv nature of cryptocurrency mining operations
worldwide.s The quick influx of transitory load into, and potentially out of, ldaho Power's
service area creates significant risk that costs created by the transitory load will ultimately
become the burden of other customers.
Contrary to GeoBitmine's assertion, Schedule 20 is not discriminatory or otherwise
improper. Schedule 20 rate components mirror existing customer rates, marginal energy
prices, and interruptibility requirements that have previously been approved by the
Commission in relation to other ldaho Power service offerings.e
II. SCHEDULE 20 APPLICABILTY CRITERIA IDENTIFIES SPECULATIVE.
TRANSITORY LOADS THAT POSE HEIGHTENED STRANDED ASSET R!SK.
Applicability of Schedule 20
\Mile cryptocurrency mining operations are the primary example of this type of
potentialcustomer, given their reliance on the proof-of-work authentication method, ldaho
Power is only concerned with the nature of the load that results given the potential
transitory nature of their operations, the quantity of electricity used, and the nature and
pattern of use, which have repercussions for ldaho Power's system and other customers.
7 /d , citing Utah ldaho Sugar Company v. lntermountain Gas, 1 00 ldaho 368, 597 P .2d 1058 (1979).
sApplication, p. 3,13.
e ldaho Power Company's Answer to GeoBitmine LLC's Petition for Reconsideration & Objection to Late
lntervention ('ldaho Powe/s Answef), p. a-5,8-12.
IDAHO PO\A'ER COMPANY'S COMMENTS ON RECONSIDERATION - 4
The applicability of Schedule 20 is not determined based solely on an applicant's
proffered industry, but through evaluation of the criteria discussed more fully below.
ln approving the establishment of Schedule 20, the Commission allows
speculative, high-density load customers to join ldaho Power's system in a configuration
that balances providing service to these customers with protecting other customers from
the potential of future cost-shifts from stranded generation and transmission investment
to serve the Schedule 20 customer segment. Due to the nature of proof-of-work
authentication, operations that utilize this authentication method share certain traits that
may increase volatility on electrical load; they are able to both quickly establish service in
high concentrations at single or various locations in a utility's service area, and with the
same speed reduce load or relocate outside of a utility's service area. The need to
establish a new customer class and service schedule was driven by these attributes and
the resultant impact on the electrical system.
Prior to implementation of Schedule 20, there was not a service schedule that
appropriately accounted for the distinctive attributes of potential HDL customers. ldaho
Power's Schedule 19 requires that customer's exceeding 20,000 kW of demand enter
into a special contract with the Company, which is reviewed and approved by the
Commission. A special contract allows for evaluation of an individua! customer's unique
load requirements, system impacts, and contract provisions necessary to limit cost-shifts
to other customers. As the Company described in its Application,lo the nature of
cryptocurrency operations to easily disaggregate their load to multiple points of delivery
to fal! under ldaho Power's special contract threshold and take service under tariff rates,
1o Application, p. 13.
IDAHO POWER COMPANY'S COMMENTS ON RECONSIDERATION - 5
in part, necessitated the need to develop Schedule 20. The requirements for mandatory
interruption during the peak June 15 to September 15 season, as wel! as energy charged
at a marginal rate, provide cost-shift protections to all ldaho Power customers under a
standard tariff rate that would otherwise require development of a specia! contract for
each new Schedule 20 customer.
As outlined in Schedule 20, service under the schedule is applicable and
mandatory for customers who: 1) can relocate quickly in response to short-term economic
signals, and 2) meet four or more of the listed criteria. lt is the combination of both the
first criterion and meeting four of more of the additional seven criteria that narrows
applicability specifically to customers that may represent demand on ldaho Power's
system whose load may also be transient in nature.
The first criterion includes both the ability to quickly relocate and the influence of
short-term economic signals on the customer. Short-term economic signals may include
exposure to stock, commodity, currency, or other assets, which are valued on a market
such as cryptocurrencies and non-fungible tokens, as well as the custome/s electricity
prices.11 Quick relocation may be completed in a manner of weeks or months, in a period
of time of less than a year. As an example, a traditional mineral miner has exposure to
economic signals from the price of minerals on the spot or futures market. However, the
change in the spot or futures price of minerals does not motivate a miner to relocate their
mining operation from one utility's service area to another utility's service area in a manner
of weeks or months due to the large investments in plant, equipment, machinery, and
11 Turner Wrighl, Crypto miner Digihost plans to move igs from New York to Alabama, Cointelegraph
(Au9.2,2022),
httos://cointeleoraoh.com/news/crvpto-miner-dioihost-olans-to-move-riqs-from-new-vork-to-alabama.
IDAHO PO\A'ER COMPANY'S COMMENTS ON RECONSIDERATION - 6
buildings required to extract mineral substances from the ground. Short-term economic
signals are not limited to exposure to stock, commodity, currency, or other assets, but
may also be influenced based on input prices such as electricity and the difficultly in
completing industrial processes such as computational hash rate, among others.
The remaining seven criteria to consider as part of the second inquiry under
Schedule 20 are set forth below, along with specifications for the application of the criteria
as applicable, which were previously provided by ldaho Power in response to discovery
requests:12
a Hioh enerqv use densitv: Energy use of 250 kilowatt-hours or greater per square
foot annually.
Hioh load factor: 85 percent or greater annually.
Load that is portable and distributable: A characteristic of Application-Specific
lntegrated Circuit ('ASIC') or other highly specialized cryptocurrency specific
hardware. A single machine is approximately the size of a shoe box and ranges in
load from 1.3 kilowatt ('kW') to over 3 kW. ASIC and other mining machines have
limited infrastructure needs, namely electricity and internet, and may be
disaggregated quickly. To illustrate, machines at one central location of 1
megawatt could easily disaggregate to 10 locations of 100 kW each, which is not
typical of traditional data centers that are designed with more permanent
placement of equipment.
Hiqhlv variable load orowth or load reduction as an individual customer and/or in
aqqreqate with similar customers in the Companv's service area: Changes in
requested load growth or load reductions from customers would be evaluated on
a case-by-case basis, and is consistentwith the customer requirements as outlined
in ldaho Power's Rule K.13
a
a
a
o Hioh sensitivitv to volatile commoditv or asset prices: Based on the significant price
12 See ldaho Power Company's Response to First Production Requests of the lndustrial Customers of
ldaho to ldaho Power, p.7-14.
13 ldaho Power's Rule K, Change in Load Characteristic, requires "the Customer shall give the Company
prior notice before making any significant change in either the amount or electrical character of the
Customer's electrical load thereby allowing the Company to determine if any changes are needed in the
Company's equipment or distribution system.'
https://docs. idahopower.com/pdfs/aboutus/ratesreoulatorv/tariffs/35.pdf
IDAHO PO\A'ER COMPANY'S COMMENTS ON RECONSIDERATION - 7
declines and increases for Bitcoinla as documented in the Company's Application,
customer sensitivity to an asset such as cryptocurrencies would meet the criteria.
a
demand
a
Sysfem Gosts and Benefits from Mandatory lnterruption
Schedule 20 includes a maximum of 225 event hours each June 15 through
September 15 season, up to ten hours between 1 p.m.and 11 p.m., Monday through
Friday, which even if fully utilized still results in uptime (or load factor) of 97.4 percent for
the year. ldaho Power's largest customers do not approach load factors of 97.4 percent
annually, and most data centers project load factors of approximately 90 percent.
As previously described by the Company, interruptible rates are commonplace in
utility regulation generally and specifically in relation to cryptocurrency mining
operations.l5 Many of these interruptible rates offer payment for the load curtailed during
an event, similar to ldaho Power's demand response programs. While the current
Schedule 20 rate design does not currently include an interruption crediting component,
in accordance with Staffs recommendationl6 and the directive of the Commission,lT
ldaho Power wil! evaluate the costs and benefits of the interruption requirement after
Schedule 20 customers have joined the system and before the next general rate case.
14 There are more than 300 cryptocurrencies which utilize proof-of-work authentication. Bitcoin represents
the ovenrvhelming majority of activity and has the largest market capitalization, making up nearly two-
thirds of the entire market capitalization for all proof-of-work cryptocunencies (as of August 19,2022).
https : //crv otos late. com/crvptos/oroof-of-worU
15 See ldaho Power's Answer, p. 11.
16 Staff Comments, p. 8
17 Order No. 35428, p. 6-7
IDAHO POWER COMPANY'S COMMENTS ON RECONSIDERATION - 8
Through either a future reduction in cost assignment in recognition of the ability to be
curtailed, or potentially a crediting mechanism, Schedule 20 provides a non-
discriminatory service offering that takes into account the particular usage and service
characteristics of this specific class of customers.
III. CRYPTOCURRENCY MARKET CONDITIONS VALIDATE THE
COMMISSION'S ADOPTION OF SCHEDULE 20 TO PROTECT CUSTOMERS
As the price of Bitcoin enters its third month of prices hovering below $25,000 per
Bitcoin, the impact experienced by well-established, and previously highly capitalized
cryptocurrency market participants,ls demonstrates the necessity of the Commission's
approach to insulate customers from the impact of HDL customers. Depressed Bitcoin
prices since June 2022 have resulted in cryptocurrency hedge fund bankruptcies,le
cryptocurrency exchange liquidations and withdrawal lock ups,20 as well as other early
signs of financial stress among large Bitcoin miners liquidating Bitcoin holdings to
maintain cash flow21 and at least one instance of a Bitcoin mining hosting contract being
18 Jonathan Ponciano, Crypto Wnter Watch: All The Big Layoffs, Record Withdrawals And Bankruptcies
Spar*ed By The $2 Tillion Crash, Forbes (Jul. 7, 2022),
https://www.forbes.com/sites/ionathanponciano/2022107/07/crvoto-winter-watch-all-the-biq-lavoffs-record-
withdrawals-and-bankruptcies-soarked-bv-the-2-trillion-crash/?sh=317610e97b44.
le Emma Roth, Crypfo hedge fund Thrce Anows files for bankruptcy,The Verge (Jul. 2, 2022),
https://www.theverqe.com/202217/2/23192810/three-arrows-capital-chapter-15-bankruotcv-
crvDtocurrencv.
20 Ryan Browne & Arjun Kharpal, Crypto lender Celsius pauses withdnwals due to'extreme market
conditions', CNBC (Jun. 13, 2022), https://www.cnbc.com/2022l06/13/crvpto-lender-celsius-pauses-
withdrawals-bitcoi n-slides. html.
21 Alys Key , Crypto Miner Core Scientific Dumps $165M Bitcoin to 'Enhance Liquidity', Decrypt (Jul. 6,
2022),
httos://decrvot.co/104493/crvoto-miner-core-scientific-dumps-165m-bitcoin-to-enhance-liquiditv:
Jennifer Sor, Rrsing energy costs and plummeting crypto prices mean public bitcoin minerc arc'fighting to
suNive',lnsider (Jul. 5, 2022),
https://markets.businessinsider.com/news/currencies/bitcoin-miners-enerqv-costs-oil-oas-inflation-orices-
bankruotcv-risk-2022-7.
IDAHO POWER COMPANY'S COMMENTS ON RECONSIDERATION - 9
terminated for cause based on alleged failure of miner to pay utility bills and hosting
fees.22
The current Bitcoin market downturn has caused significant liquidations of Bitcoin
holdings by cryptocurrency miners, reaching 400 percent of June production, and an
overall reduction of 25 percent of Bitcoin holdings.23 At the current pace of liquidations
exceeding production, the impact to miners' operational cash flow may soon lead to a
shakeout in the industry as the Bitcoin market price trends toward breakeven production
cost. According to one industry insider: 'lf you factor in overhead costs for infrastructure
and interest rates, the total costs for some miners may already be above $20,000, which
is around Bitcoin's current price."2a The financial stress for many cryptocurrency miners
is compounded by nearly $4 billion in loans, many collateralized by Bitcoin mining
machines which have lost nearly half their value, resulting in loans assumed by analysts
to now be undercollateralized.2s
Additional examples of the challenges currently facing the cryptocurrency mining
industry abound with operationa! profitability severely impacted and miners challenged to
2 Jesse Coghlan, Compass Mining loses facility after allegedly failing to pay power b//, Cointelegraph
(Jun.28, 2022),
httos://cointeleoraph.com/news/compass-minino-loses-facilitv-after-alleoedlv-failinq-to-oav-oower-bill.
23 Stacy Elliott, What Bitcoin Miners Are Doing to Sulive the Bear Markef, Decrypt (Aug. 1,2022),
https://decrvpt.co/106267/what-bitcoin-miners-are-doino-survive-bear-market.
2a David Pan, Almost $4 Billion in Bitcoin Miner Loans Arc Coming Under Stress, Bloomberg (Jun.24,
2022),
https://www.bloomberq.com/news/articles/2022-06-24/almost-4-billion-in-bitcoin-miner-loans-are-comino-
u nd er-stress#xi4v7vzkq.
,u Amy Castor & David Gerard, Bitcoin mining in the crypto cnsh - the mining companies' creative
accou nting, amycastor.com (Aug. 4, 20221,
https://amvcastor.com/2022l08/04/bitcoin-minino-in-the-crvpto-crash-the-minino-comoanies-creative-
accountinq/:
Best Owie,_Beaish Signal: tMry Bitcoin Miner Sell-Offs May Continue, NEWSBTC (Aug. 12, 2022),
https://vtrunlrr.newsbtc.com/news/bitcoin/bearish-sional-whv-bitcoin-miner-sell-offs-mav-continue/.
IDAHO PO\A/ER COMPANY'S COMMENTS ON RECONSIDERATION - 1O
maintain cash flow. ln the most recent fiscal quarter, the three largest publicly traded
Bitcoin mining companies, Core Scientific, !nc., Marathon Digital Holdings, lnc., and Riot
Blockchain lnc., collectively posted Iosses exceeding $1 billion for the second quarter of
2022.26 Another Bitcoin miner, Stronghold Digital Mining (SDIG), recently sold nearly two-
thirds of its mining machines (26,200 machines) to cancel $67.4 million in debt. !n that
case, SDIG was better off than many of its peers, however, as it is a vertically integrated
cryptocurrency miner that also owns and operates approximately 165 megawatts ("MW')
of power generation capacity, finding it more economical to resell the 100 MW of spare
generation capacity into the energy market than use it to mine Bitcoin.2T
Beyond impacts from the protracted decline in Bitcoin prices from the al!-time high,
an upcoming transition to a thousand-fold more energy efficient consensus mechanism
(authentication method) of the second largest by market capitalization cryptocurrency,
Ethereum, has the potential to have broad impacts across the cryptocurrency mining
space. Currently, both Bitcoin and Ethereum utilize energy intensive proof-of-work
consensus mechanisms, however, on September 15 or 16, the Ethereum "merge" is
scheduled to occur, transitioning Ethereum from proof-of-work to a proof-of-stake
consensus mechanism.2s The dramatic reduction in energy requirement to mine
26 David Pan, Largest Bitcoin Miners Lost Over $1 Billion Duing Crypto Crash, Bloomberg (Aug. 16,
2022),
https://www.bloomberq.com/news/articles/2022-08-16/laroest-bitcoin-miners-lost-over-1-billion-durino-
crypto-crash.
27 Mark Tyson, Bitcoin Mining Company Sells 26,200 Rrgs fo Eliminate $67M Debts, Tom's Hardware
(Aug. 18,2022),
https://www.tomshardware.com/news/bitcoin-mininq-companv-sells-rios-to-eliminate€7m-usd-debt.
28 Richard Lawler, Ethereum's big proof-of-stake blockchain switch coutd happen on September 1*,The
Verge (Aug. 11,2022),
https:i/www.theverqe.com/202218/1 1/23301638/ethereum-crvpto-blockchain-proof-of-stake-environment.
IDAHO POWER COMPANY'S COMMENTS ON RECONSIDERATION - 11
Ethereum using the proof-of-stake consensus mechanism has the potential to disrupt the
cryptocurrency mining industry, garnering headlines such as "Ethereum's'Merge'is about
to put every ether miner out of work,"2e and "Ethereum Miners Wil! Have Few Good
Options AfterThe Merge.'3o \Mile most directly impacting Ethereum miners, the dramatic
reduction in energy consumption by Ethereum will eliminate one of cryptocurrency's
greatest criticisms, the amount of energy consumed and the associated power generation
emissions by the mining process.3l With the potential to be a less environmentally
impactfu! cryptocurrency, proof-of-stake Ethereum may drive either more broad adoption
of Ethereum over Bitcoin, or a push for Bitcoin to also evaluate the proof-of-state
consensus mechanism, either outcome reducing electricity demand of Bitcoin mining,
which might result in stranded generation and transmission investment made in support
of current Bitcoin mining load.
Schedule 20's margina! energy rates and Ioad interruption during ldaho Power's
peak load periods prudently addresses and/or minimizes the potentia! investment
necessary to accommodate a volatile industry, investment which may not be recovered
from customers whose load is transitory. Cryptocurrency mining's growing demand on
the electrical system continues to result in additional costs32 or restrictions in mining
2e Timothy B. Lee, Ethereum's "Merge" is about to put every ether miner out of work, ARS Technica (Aug.
8,2022),
https://arstechnica.com/tech-policv/2022l08/the-meroe-the-bioqest-chanqe-in-ethereum-historv-
exolained/https://arstechnica.com/tech-policv/2022l08/the-merqe-the-biooest-chanqe-in-ethereum-
historv-exolained/.
s Colin Harper, Ethereum MinersWillHave Few Good Options AfterThe Merge, Forbes (Aug. 21 ,2022),
https://www.forbes.com/sites/colinharper/2022108/21lethereum-miners-will-have-few-oood-options-after-
the-merqe/?sh= 5a 1 d4f04407a.
31 Gian M. Volpicelli, Ethereum's'Merge' ls a Big Deal for Crypt*and the Planet, Wired (Aug. 18,2022),
https://www.wired.com/story/ethereum-meroe-biq-deal+rvoto-environmenU.
IDAHO PO\A'ER COMPANY'S COMMENTS ON RECONSIDERATION - 12
operations in countries around the world,33 and has garnered the interest of the U.S.
Senate to better understand and track the growing energy use of the industry.il ldaho
Power is not alone in recognizing that cryptocurrency mining creates new impacts and
risks to the electrical system, and that additional oversight or operational parameters may
be required.
tv. coNcLUstoN
ln initiating this proceeding, the Company was driven by a desire to provide electric
service to HDL customers while also addressing the challenges resulting from the
distinctive usage characteristics of HDL customers in order to insulate other customers
from their impact. As demonstrated by ldaho Power herein and throughout this
proceeding, HDL customers are indeed a distinct customer class whose electric use is
characterized by certain attributes, paramount of which is transience, that justiff the
different rates and charges implemented through Schedule 20. The Commission's
decision approving the establishment of Schedule 20 conforms with ldaho law and is
consistent with prior Commission orders, and ldaho Power, therefore, respectfully
requests the Commission affirm its original decision set forth in Order No. 35428.
32 Sergio Goschenko, National Power Administration Will Propose a Special Cryptocunency Mining Fee in
Paraguay, Bitcoin.com (Aug. 4, 2022),
https://news.bitcoin.com/national-oower-administration-will-oropose-a-special-crvptocurrencv-mininq-fee-
in-paraquay/.
33 Lubomir Tassev, Kosovo Renews Crypto Mining Ban Amid Risrhg Eneryy Pices, Bitcoin.com (Aug. 5,
2022),
httos://news.bitcoin.com/kosovo-renews-crvoto-minino-ban-amid-risino-enerqv-prices/.
s Robert Walton, Sen. Wanen leads lawmakers calling for DOE, EPA to track'distutbing' Bitcoin,
Ethereum eneryy use, Utility Dive (Jul. 19,2022),
httos://www.utilitvdive.com/news/warren-lawmakers-doe-eoa-bitcoin-enerqv-use-emissions/627554/:
Press Release, EnvironmentalWorking Group, EWG applauds cryptocunency energy use oversight
provision in Senate drgdal assefs bil, EWG.org (Aug. 4, 2022),
httos://www.ewq.orq/news-insiohts/news-release/2022l08/ewq-applauds-cryptocurrencv-enerov-use-
oversiqht-provision.
IDAHO POWER COMPANY'S COMMENTS ON RECONSIDERATION - 13
Respectftrlly submitted this 24th day of August 2022.
Wffiud^,l-00ftn
MEGAN GOICOECHEA ALLEN
Attorney br ldaho Power Company
IDAHO POWER COMPANY'S COMMENTS ON RECONSIDERATION.14
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 24th day of August 2022, I served a true and
correct copy of the foregoing ldaho Power Company's Comments on Reconsideration
upon the following named parties by the method indicated below, and addressed to the
following:
Commission Staff
Riley Newton
Deputy Attorney General
ldaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg No. 8,
Suite 201-A (83714)
P.O. Box 83720
Boise, ldaho 83720-007 4
GeoBitmine LLC
Peter J. Richardson
Richardson Adams, PLLC
515 N.27th Street
P.O. Box 7218
Boise, ldaho 83702
lndustrial Customers of ldaho Power
Peter J. Richardson
Richardson Adams, PLLC
515 N. 27th Street
P.O. Box 7218
Boise, ldaho 83702
Dr. Don Reading
6070 Hill Road
Boise, ID 83703
2140 Labs LLC
Elizabeth A. Koeckeritz
Givens Pursley LLP
601 W. Bannock Street
Boise, ldaho 83702
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Stacy Gust, Regulatory Administrative Assistant
IDAHO POWER COMPANY'S COMMENTS ON RECONSIDERATION - 15