20230815Final_Order_No_35893.pdf

ORDER NO. 35893 1

Office of the Secretary
Service Date
August 15, 2023
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

On December 2, 2021, Idaho Power Company (“Company”) applied to the Idaho Public
Utilities Commission (“Commission”) for authority to expand its optional clean energy offerings.
The Company seeks to (1) rename the existing Schedule 62—Green Power Purchase Program
Rider (optional) to Clean Energy Your Way (“CEYW”); (2) maintain and expand procurement
options for the renewable energy certificate (“REC”) offering under the name Clean Energy Your
Way – Flexible (“CEYW – Flexible”); (3) establish a regulatory framework for a future voluntary
subscription green power service offering named Clean Energy Your Way – Subscription
(“CEYW – Subscription”); (4) offer a tailored renewables option to the Company’s largest
customers (Special Contracts and Large Power Service) named Clean Energy Your Way –
Construction (“CEYW – Construction”); and (5) procure associated program renewable resources
outside the Commission’s current competitive bidding requirements. Application at 1-2.
On January 31, 2022, the Commission issued a Notice of Application and Notice of
Intervention Deadline. Order No. 35304. The Commission granted intervention to the Industrial
Customers of Idaho Power (“ICIP”), Idaho Conservation League (“ICL”), Clean Energy
Opportunities (“CEO”), City of Boise City (“Boise City”), and Walmart Inc. (“Walmart”). See
Order Nos. 35285, 35301, 35311, and 35320.
On March 9, 2022, the Commission issued a Notice of Modified Procedure establishing
public comment and Company reply deadlines. Order No. 35338. The Commission Staff (“Staff”),
CEO, Boise City, ICL, and Walmart filed comments to which the Company replied. The
Commission also received 31 public comments.
We now issue this final order approving the Company’s Application subject to the
modifications and requirements discussed more fully below.

IDAHO POWER COMPANY’S
APPLICATION TO EXPAND OPTIONAL
CUSTOMER CLEAN ENERGY OFFERINGS
THROUGH THE CLEAN ENERGY YOUR
WAY PROGRAM
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CASE NO. IPC-E-21-40

ORDER NO. 35893

ORDER NO. 35893 2

THE APPLICATION
The Company represented that its Green Power Program has served its customers for years
resulting in the purchase of a large amount of renewable energy. Application at 2. However, the
Company asserted that customers’ preferences regarding renewable energy have changed with
many of them seeking additional clean energy options. Id. The Company represented it has
engaged with customers and employed industry research to develop a “three-pronged offering”
that builds off the Green Power Program. Id. As a result, the Company proposed to rebrand its
Green Power Program as the CEYW program which it claims will better communicate the existing
and proposed new offerings. Id. at 1. The Company requested to change the following: 1) rename
Schedule 62 Green Energy Purchase Program Rider (Optional) to Schedule 62 Clean Energy Your
Way (Optional) and 2) rename the Green Energy Purchase Program to Clean Energy Your Way
– Flexible. Id.
The Company represented the proposed CEYW – Flexible option will operate similarly to
the existing Green Power Program. Id. at 7. The Company requested approval to expand its REC
purchase options to keep up with demand and to satisfy customers with near-term clean energy
goals that can be accomplished with RECs, and the Company proposed two options for customers,
the Limited Bulk Purchase Option and the REC “Sleeve” Option. Id. at 7-8.
Under the Limited Bulk Purchase Option, the Company would purchase a limited quantity
of RECs (not to exceed $5,000 at any time) in advance of customer requests with the intent to sell
them to interested customers later under individual customer-specific REC sale agreements. Id.
The Company proposed that it would not initiate the next bulk purchase until the prior batch had
been sold. Id.
The Company also asked for authority to serve as a “sleeve” for REC transactions with the
Company’s customers by connecting customers to non-Company REC purchases. Id. The
Company represented that this would work similarly to the Limited Bulk Purchase Option where
the Company would sell any procured RECs to interested customers at cost, thereby not creating
any proceeds to pass through the Power Cost Adjustment (“PCA”) and leaving no unsold RECs as
the Company would only procure the RECs the customer demands. Id.
The Company also requested authority to offer the CEYW – Subscription option where
customers “subscribe” to a portion of the output from a new renewable resource on the Company’s
system. Id. at 9. To offer the CEYW – Subscription option, the Company described two phases:

ORDER NO. 35893 3

Phase I (this Application) includes requesting authority to offer a voluntary subscription option,
and Phase II (following approval of Phase I) would involve the Company determining the resource
type, size, and location. During Phase II the Company proposed specific subscription pricing for
the structure approved in Phase I. Id. at 10.
The CEYW – Subscription option would be open to any customer, but the Company
proposes an individual customer cap of 15 percent of program capacity. Id. at 11. The proposed
individual subscription size would be based on a customer’s average prior year energy usage. Id.
According to the Application, customers would be able to subscribe at 50 or 100 percent of the
average prior year use for either month-to-month, or longer terms of 5 years, 10 years, or 20 years
and any REC generated by the subscribed resource would be retained and retired by the Company.
Id.
CEYW – Subscription option pricing would be developed after a resource was selected. Id.
The Company proposes the following cost and credit components:
Program Charge: (1) cost of the resource ($/kWh); (2) integration charges associated
with the resource; (3) administration and marketing costs to advertise and maintain the
offering; and (4) a term adjustment charge applied in tiers to shorter-term (month-to-
month, 5-year, and 10-year) subscribers. As anchor tenants of the Subscription offering,
full-term subscribers would not pay a term adjustment charge.

Program Credit: For the value that the specific resource would bring to Idaho Power’s
system, subscribers would receive a credit for both energy and capacity of the program
resource.
Id. at 12.
Under the CEYW – Subscription option, customers would continue to pay all standard
rates and charges applicable to their rate schedule. Id. A CEYW – Subscription option customer’s
bill would include four new line items to account for the difference: (1) subscriber amount (in
kWh), (2) subscriber charge amount, (3) subscriber credit amount, and (4) net charge. Id.
The Company represented there is enough initial interest in the CEYW – Subscription
option to fully subscribe a 50–100-megawatt (“MW”) resource. Id. The Company proposed to sell
any unsubscribed RECs and pass the proceeds through the PCA. Id. at 12-13.
The Company asserted the proposed CEYW – Construction option will be available to the
Company’s large customers served by Schedule 19 and Special Contracts. Id. at 13. The CEYW –
Construction option will operate by integrating a renewable offering into participating customers’
service agreements with the Company. Id. at 13-14.

ORDER NO. 35893 4

The Company asserted the CEYW – Construction option offers large customers a tailored
way to cover 100 percent of their energy use with a new renewable resource(s). Id. This option
works by reconciling a customer’s energy use against the generation of a renewable resource (or
resources) on an hourly basis. Id. Eligible customers would have the ability to work with the
Company to select the renewable resource(s) and provide input on the type, size, and location. Id.
at 14.
The CEYW – Construction option would impact a customer’s existing rate structure by
creating new cost and benefit streams resulting from the renewable resource(s) and work as
follows:
• When the renewable resource is not generating (for example, a solar resource does
not generate electricity at nighttime), the customer continues to take service from
the Company at their standard rates.

• When the resource is generating, the customer pays for all the generation output at
an agreed-upon price.

• For the value the resource brings to Idaho Power’s system in the form of energy
and capacity, the Company credits the customer at an agreed-upon Commission
approved value.

• In any given hour, if the renewable generation exceeds the customer’s energy use,
Idaho Power credits the customer for that excess at a negotiated value.

• The customer continues to pay all fixed costs present in the customer’s energy rate
(Renewable Energy Facility (“REF”) On-Site Usage in Attachment 1), as well as
standard rates, charges and fees (e.g., franchise fees) for reliable service provided
by Idaho Power.

Id. at 14-15.

The Company anticipated that rates and other charges under the CEYW – Construction
option would be approved by the Commission on a case-by-case basis. Id. at 15. To meet specific
requests, several interested customers may partner under a single agreement to be served under the
CEYW – Construction option. Id. Alternatively, the Company proposed offering tailored options
that would serve the needs of interested customers. Id.
The Company has designed the proposed CEYW – Construction option to ensure non-
participating customers are not affected by the agreements entered between the Company and
participating customers. Id. at 16.

ORDER NO. 35893 5

For the CEYW – Subscription and CEYW – Construction options, the Company plans to
work with developers to identify resources that meet the demands of participating customers and
requests the ability to waive the competitive bidding resource procurement rules as ordered by
Order No. 32745. Id. at 16-17.
The Company filed a proposed Schedule 62 in both clean and legislative format with its
Application. Attachment 1 to Application.
THE COMMENTS
1. Commission Staff
Renaming Schedule 62 Clean Energy Your Way
Staff recommended the Commission approve the Company’s request to rename “Schedule
62 Green Power Purchase Program Rider (Optional) to the CEYW Program.” Staff Comments at
2.
CEYW – Flexible
Noting that the differences between the existing Green Power Program and the Company’s
proposed CEYW – Flexible option were few, Staff supported the Company’s plans to maintain
and expand the CEYW – Flexible REC procurement options, specifically the Company’s request
to offer a Limited Bulk Purchase Option and add the large purchase option to Schedule 62. Id. at
4. Staff believed that the Limited Bulk Purchase Option would be beneficial, and the Company
had the “necessary safeguards to minimize the risks with advanced REC purchases” by committing
to sell an entire batch of RECs before initiating its next bulk purchase. Id.
For the Large Bulk Purchase Option (purchases of 750 MWh of RECs or more per year),
Staff recognized a need to formally incorporate bulk purchasing options as a policy, and that the
increased demand size would require third-party REC purchases. Id. Staff initially had concerns
that third-party RECs might shift costs from Option 1 (Limited Bulk Purchase Option) and Option
2 (Large Bulk Purchase Option) but resolved those concerns due to the Company’s commitment
to have separate accounting treatments and the use of “tailored agreements” for purchases. Id.
Staff recommended that the elements from the biennial Green Energy Prudence Report
carry over to the CEYW – Flexible option’s reporting requirements, including the Flexible
offering. Id. at 16; see Order No. 33570. In addition to the requirements outlined in Order No.
33570, Staff recommended the CEYW – Flexible option report, according to Staff, should include
(1) advanced procurement purchase information, and if RECs can carry over; (2) details on third-

ORDER NO. 35893 6

party RECs, including quantity requested, price, REC amount procured, and monthly revenue and
accounting, and separate accounting; (3) balance of uncommitted or excess funds that may carry
over; and (4) monthly rider balance for Schedule 62. Staff Comments at 16.
CEYW – Subscription
Staff reviewed the history of subscription programs in Order Nos. 33638 and 34317 and
compared those programs to the Company’s current proposal. Id. at 5. Order No. 33638 allowed
the Company to build a community solar system and allow retail customers to subscribe to its
output. Id.; see also Order No. 34317. Due to low enrollment, however, the Commission suspended
the subscription-based program. Id.
As proposed, the Company’s CEYW – Subscription option has two phases—Phase I being
conceptual and Phase II selecting the actual renewable resource and the rate structure. Staff
Comments at 5. The Company proposes to open enrollment in CEYW – Subscription option in the
third quarter of 2023 and select the resource by the end of 2024. Id.
Staff noted that the Company seeks approval of the general framework and several
concepts for the CEYW – Subscription option, including: (1) waiver of procurement guidelines
for resource(s); (2) CEYW – Subscription eligibility; (3) CEYW – Subscription size; (4) CEYW
subscriber term lengths; (5) RECs; (6) CEYW – Subscription pricing components; (7) CEYW –
Subscription charges; and (8) monthly billing. Id. However, because the CEYW – Subscription
option was conceptual at the time Staff filed comments, Staff expressed concerns about resource
procurement, subscription demand, avoided cost methodology, and the accounting treatment about
the CEYW – Subscription option that cannot be resolved until those details are available. Id. at 5-
6. When Staff filed comments, it supported the Company’s proposal to offer “retail customers an
opportunity to participate but does not offer support for the proposed framework or the rate
structure.” Id. at 6.
Staff noted that it could not provide a full analysis of the Company’s proposed conceptual
framework because the Company was not prepared to respond to production requests about Phase
II while Phase I was being reviewed. Id. Staff maintained it would address these concerns in Phase
II regarding: (1) the Company’s planned exemption from the Oregon Resource Procurement Rules;
(2) how the Company plans to fully subscribe up to 50 MW; (3) how the Company would
determine the avoided cost rate; (4) the Company’s planned accounting treatment; and (5) why the
Company seeks approval of its framework with supporting data. Id.

ORDER NO. 35893 7

Staff discussed its concerns about the Company’s request to procure associated CEYW –
Subscription option renewable resources outside the Commission’s current competitive bidding
requirements. Id. at 6-7. Staff’s primary concern centered on the resource not being deployed to
benefit all retail customers, but the requested waiver potentially allowing the Company to recover
costs for a non-least cost resource through the PCA. Id. at 7. Staff recognized that Phase II would
bring changes subject to Commission approval, and recommended a thorough Company analysis
of the renewable resource procurement process. Id.
Prior to filing Phase II, Staff recommended the Company meet with Staff to investigate
ways to set a reasonable avoided cost rate where participants will benefit but non-participants will
be unharmed. Id. Staff recognized that a conceptual, undersubscribed program could potentially
shift costs to non-participants and that pricing structure and resource selection were unknown
factors. Id. To address these unknowns, Staff recommended two workshops—the first workshop
would evaluate the full PCA treatment of RECs from the renewable resources of the CEYW
options, and the second workshop would focus on the accounting treatment of costs, benefits, and
loads for all CEYW options. Id. at 8. Staff expected that the second workshop would occur before
the next general rate case and that both workshops would be consistent with Staff’s
recommendations in Case No. IPC-E-21-42. Id.
CEYW – Construction
Staff recommended approval of the Company’s CEYW – Construction option, specifically
the ability to offer “tailored renewables to Schedule 19 and Special Contract customers” subject
to the following conditions: (1) passing 100 percent of REF costs to the CEYW – Construction
customers; (2) netting energy on an hourly basis to determine customer energy consumption or
exports to and from the Company’s system; (3) basing net consumption on the cost-of-service
(“COS”); and (4) basing the value of the net production exports (“Excess Generation”) to the
Company’s system on avoided cost. Id. at 9. Staff recognized the limitations of evaluating the
CEYW – Construction options without having the additional details. Id. Staff noted its appreciation
for the structure that also provides customers an opportunity to match individual requirements. Id.
Staff’s primary analysis focused on potential cost-shifting or harm to other classes of non-
participating customers. Id. Staff stated its analysis and evaluation are critical because: (1) the
Company’s proposal will bypass the process used for planning and selecting resources that ensures
the selected resource is needed for the system and is at the lowest cost; (2) all the RECs associated

ORDER NO. 35893 8

with the resource will be claimed by the CEYW – Construction option customer but the resource
will also be used to serve system load; and (3) the customers participating in the CEYW –
Construction option will tend to be the Company’s largest customers with the greatest impact on
the Company’s system and cost structure. Id. at 9-10.
Staff believed that the CEYW – Construction option framework could support Staff’s
preferred ratemaking principles because the customer would pay 100 percent of the renewable
resource. Id. at 11. Staff’s “virtual behind the meter” framework for this option is intended to
ensure net consumption (“Supplemental Generation”) rates are based on COS principles and net
production exports (“Excess Generation”) can be analyzed using principles of avoided cost. Id.
Within this framework, Staff emphasized the importance of holding other customers harmless,
particularly as the resources are expected to be selected based on the CEYW – Construction option
customers’ preferences. Id.
For Excess Generation “exported or sold” to the Company, Staff believed Public Utility
Regulatory Policies Act (“PURPA”) avoided cost rates should be used to base the rates which hold
customers harmless. Id. Ideally, Staff noted that the amounts of energy and capacity “would occur
on a net basis to minimize any asymmetry or double counting of its value.” Id. at 12. Staff
represented that the Company “proposes to track and price energy production and consumption on
a net basis. However, in the case of capacity and capacity-driven costs, the Company proposes to
effectively purchase 100 percent of the capacity contribution from CEYW - Construction
customer’s resource(s), while providing 100 percent of the customer’s capacity needs from the
system.” Id.
Staff supported the Company’s proposed framework for energy treatment for the reasons
stated above, specifically because it is based on COS principles. Id. However, Staff is concerned
that a CEYW – Construction option customer’s load shape may change significantly when up to
110 percent of the customer’s usage might be offset by the REF(s). Id. This would change the
customer’s COS according to Staff. Id. For this reason, Staff recommended “the COS and rates
used to recover costs from each CEYW – Construction customer be verified with each proposed
REF and that each REF contract be submitted to the Commission for approval.” Id. Staff noted
that the Company did not propose how excess energy credit would be determined, and Staff again
suggested that avoided cost principles should be used as a basis. Id. Despite its recommendation,

ORDER NO. 35893 9

Staff registered its concern that this treatment would impact the Company’s net power costs. Id. at
13.
Staff stated it is greatly concerned by “the increase in the proportion of energy priced at
avoided cost that make up the Company’s net power costs.” Id. Staff noted that “[b]ecause the
avoided cost of energy is priced at the margin, it is higher than the Company’s average embedded
energy cost.” Id. Staff’s concern is that new CEYW – Construction option REFs, aggregated with
other CEYW program offerings, additional distributed energy resources, and existing PURPA
projects, will put upward pressure on customer rates that are based on avoided cost principles. Id.
Staff recommended the Company “evaluate this overall effect in combination with alternative
methods for determining avoided cost of energy to mitigate it before more of these programs with
customers are implemented.” Id.
Staff noted that the Company’s proposed treatment for capacity is incongruent with its
ideal framework because the “capacity contribution of the CEYW – Construction customer’s
resource is not netted from the capacity needed to serve the customer’s load.” Id. Staff
recommended that the Company determine, on a case-by-case basis, the excess capacity
contribution of each REF and the use of the Company’s system to meet capacity demands of each
CEYW – Construction option customer to ensure other customers are held harmless. Id.
Staff supported using existing customer’s rate schedules to recover costs associated with
the use of system capacity when they become CEYW – Construction option customers. Id. at 13-
14. Staff supported this because existing customers’ capacity needs are not likely to change
whether their REFs are producing or not. Id. at 14. Staff noted the Company’s proposal to charge
CEYW – Construction option customers a fixed cost charge for energy generated by the
customer’s REF and consumed by the customer using the most recent COS information. Id. Staff
supported this proposal because it would help offset the impact to capacity-related cost recovery
that partially occurs through the customer’s volumetric rate. Id. Staff believed that without the
fixed cost charge proposed by the Company, CEYW – Construction option customers will
underpay for their use of capacity of the Company’s system and shift costs to other customers. Id.
at 14-15.
Staff recognized the Company’s Application did not propose how it would treat capacity
credits for exports. Id. at 14. Staff proposed that using avoided cost principles would be the best

ORDER NO. 35893 10

standard for determining the capacity credits for avoided capacity costs from exports to the
Company. Id. Staff recommended:
(1) capacity credit payments should not begin until the capacity contribution from
its resource(s) begin avoiding capacity cost, which only occurs when the system
first becomes capacity deficient; (2) the surrogate used to determine the value of
the capacity credit should be based on the lowest-cost capacity resource; and (3)
the credit should only be paid for exports of energy to the Company’s system during
system peak hours, which the Company determines as the hours when additional
capacity is needed for the system and capacity cost can be avoided.

Id. at 14.
Staff’s Proposed Changes to the CEYW Framework
Staff recommended five additional elements to reduce potential customer harm or cost
shifting: (1) each Renewable Construction Agreement (“RCA”) should be subject to Commission
approval; (2) a financial guarantee of stranded REF costs; (3) CEYW – Construction customers
pay for 100 percent of the construction costs associated with connecting the REF to the Company’s
system, including interconnection costs and any transmission/distribution upgrades; (4)
Commission review of resource selection and rates could be bypassed if the agreement included
passing 100 percent of costs to the CEYW – Construction customer and if import and export
capacity rates are reasonable and based on COS and avoided cost principles; and (5) REF size
should not exceed 110 percent of the CEYW – Construction customer’s annual energy
requirements. Id. at 14-15.
Because there will be more funds flowing into the PCA from Company-owned RECs and
other costs necessary to support CEYW – Subscription and Construction options, Staff asked the
Commission to require the Company to file its reports annually, before the Company’s PCA filing.
Id. at 15-16.
Staff also requested additional details on several items included in the proposed CEYW –
Subscription and Construction options be filed with the PCA. Id. at 16. These include: (1) CEYW
offerings’ cost information flowing through the PCA; (2) CEYW – Construction projects’ amount
of consumption and generation from REFs; (3) a monthly comparison of CEYW – Construction
customer load forecasts compared to actual generation for all Power Purchase Agreements
(“PPA”); (4) annual CEYW subscription enrollment data; and (5) forecasted CEYW subscription
enrollment and load. Id. Staff recommended the CEYW – Flexible report be filed annually instead
of biennially and be filed before the annual PCA filing on April 15. Id.

ORDER NO. 35893 11

Finally, Staff noted that these CEYW offerings create additional opportunities for Schedule
84 customers (Commercial, Industrial, and Irrigator) to offset their energy consumption with clean
energy. Id. at 17-18. Schedule 84 currently has a 100 kW Generation Facility nameplate capacity
cap. Staff speculated that there might be changes to the 100 kW eligibility cap in Schedule 84. See
Order No. 35284. If changes are recommended, these should likely carry over to CEYW –
Subscription and CEYW – Construction options. Staff Comments at 18.
2. Boise City
Boise City supported Commission approval of the Company’s Application and
authorization to: (1) rename Schedule 62 “Clean Energy Your Way Program,”; (2) maintain and
expand procurement options for RECs under CEYW – Flexible; (3) establish a regulatory
framework for subscription that is available to all customers; (4) offer the CEYW - Construction
option for Special Contract and Schedule 19 customers; (5) allow individually designed and
Commission approved CEYW – Construction arrangements; and (6) procure resources to meet
customer’s clean energy preferences through these offerings outside of the current competitive
bidding requirements. Boise City Comments at 1-2.
Boise City supported the Company’s proposed limited exemption from Oregon’s Resource
Procurement Rules because the “costs of the resources will be individually and voluntarily
accepted by participating customers in both the Subscription and Construction offerings and
because the Company commits to make a showing to the Commission that the Subscription
program resource was competitively procured in Phase II.” Id. at 3. Boise City recommended the
Company move quickly to procure the resources and collaborate with stakeholders in Phase II. Id.
at 3-4.
Boise City emphasized the importance of holding non-participating customers harmless
and asked the Company to minimize administrative and marketing costs. Id. at 2. Boise City would
like CEYW to have an option for low-income customers’ participation, specifically those
customers in the Low-Income Home Energy Assistance or Weatherization Assistance Programs
in the Phase II request. Id. at 3.
3. CEO
CEO commended the CEYW program for supporting different customers, having
purchases be “additional,” and holding non-participants harmless. CEO Comments at 1. CEO
recommended the following: (1) “expanding synergies between CEYW programs and customer

ORDER NO. 35893 12

self-builds of renewable generation”; (2) evaluating whether a broader view of certifying the clean
energy purchased by customers beyond RECs, i.e., considering any self-generators who have
installed their self-generation equipment after their respective grandfathering cutoff as meeting the
“additionality” requirement; (3) broadening perspectives on providing “community solar” to
“consider the exports of customers who have installed self-generation as clean energy” as
“Community” resources; and (4) avoiding harm to non-participants that could arise from IPC-
Customer negotiated pricing of exports for “Construction” customers. Id. at 2.
CEO expressed its concern with using the AURORA model, because AURORA cannot
predict short-term macro-economic impacts that can significantly impact the assumptions of a
long-term planning tool, and alternative models are available. Id. at 6. CEO agreed “that customer
purchases beyond their tariff’s allowance to energy at embedded energy costs, as well as all
exports, should be valued at a marginal avoided cost during the hour of the purchase or sale event.”
Id. at 7. If CEYW customers that generate energy beyond their requirements help the Company
avoid energy imbalance market (“EIM”) purchases, CEO suggested “there are available real-time,
hourly, location specific marginal prices via the EIM.” Id.
CEO offered that using EIM prices to value exports when generation exceeds that
customer’s load could: (1) reduce the potential for harm to non-participants due to the use of
inaccurate estimates of true marginal prices; (2) incentivize the CEYW customer to install storage
to provide their own reserves while allowing them to time-shift some their generation to more
closely serve their load via their own generation; and (3) reduce Commission and staff workload
in having to review separate negotiated export contract values for each new Construction customer.
Id. CEO requested a PUC-facilitated Workgroup to discuss program changes and the potential
impact CEYW might have on ongoing cases. Id. at 7-8.
4. ICL
ICL appreciated the Company’s steps to improve clean energy options. ICL Comments at
1. ICL asked the Commission to direct certain modifications to protect customers of the CEYW –
Subscription option. Id. ICL specifically asked that the Company address “missed opportunities”
to increase access to distributed and clean generation resources, save customers money, and
accelerate the transition to clean energy. Id.
First, ICL would like rapid program implementation and increased distributed generation
opportunities. Id. at 2. ICL doubted that the current proposal would increase residential

ORDER NO. 35893 13

communities’ distributed generation. Id. at 2-3. Second, ICL would like expanded access for low-
income customers to the proposed CEYW – Subscription option, as the expense will likely deter
these customers. Id. at 6. Third, ICL does not think it is realistic for the proposed program to be
operational before the end of 2024, and the addition of renewable resources will delay
implementation. Id. at 3.
ICL requested a Commission directive to support a community-owned solar program. Id.
at 7. This community-owned solar program framework would allow customers (individuals,
business entities, or nonprofits) to purchase and install solar panels, and receive power from solar.
Id. at 8-9. The Company could add the solar credit (equal to the value of solar produced by the
customer’s portion of the solar array) to the customer’s electric bill, exactly as it does with rooftop
solar customers. Id. at 9. ICL believed that this approach will expedite adding renewable
generation to the grid. Id. at 10.
ICL also asked that the Company: (1) allow for participation credits in the CEYW –
Subscription option greater than the fee required to participate; (2) work to reduce administrative
and marketing costs; (3) compensate participants for the value of energy generated by the resource
at the value of solar, if the resource is solar; and (4) consider how the program can be used to
increase distributed energy generation and benefit low-income customers. Id. at 11.
5. Walmart
Walmart submitted the testimony of Steve W. Chriss, Director, Energy Services. Walmart
expressed appreciation and support for the proposed CEYW program, subject to incorporating its
suggestions on the CEYW – Subscription and CEYW – Construction options, discussed below.
Chriss Direct at 6. Additionally, Walmart took no position on the Company’s request for
exemption from the Oregon Resources Procurement Rules and requested the following: (1) allow
CEYW – Subscription option customers to subscribe up to 100 percent of their past 12 months
consumption; (2) if there is oversubscription for the CEYW – Subscription option, prorate
subscriptions to match availability; (3) allow for 15-year subscriptions; (4) require the Company
to make annual attestations available to CEYW – Subscription option customers who choose to
have the Company retain and retire RECs on their behalf; (5) require close examination of program
costs (marketing, administrative, and term adjustment components) are applied to varying
subscription lengths; (6) allow subscription credits to exceed costs, if warranted, due to resource
performance; (7) require a full examination of the specific subscription credit structure in Phase

ORDER NO. 35893 14

II; (8) open CEYW – Subscription option to customers who can aggregate more than 5-MW of
load across the Company’s service territory; and (9) for CEYW – Construction option participants,
allow the Company to offer “cost based demand charges to recover the fixed costs included in
energy charges for the customer’s applicable rate schedules” instead of the proposed REF on-site
charges. Id. at 6-8.
Walmart thought that the parties could negotiate on enrollment, and the Company could
add provisions on customer default, dissolution, or relocation. Id. at 18 and 21. Walmart suggested
cost-based demand charges to recover the fixed costs, rather than the proposed REF on-site
charges. Id. at 22. Walmart requested annual Company attestations on customers choosing to have
the Company retain and retire the RECs. Id. at 15. Walmart expressed concerns about the unclear
timelines for the program credit structure, the calculation methods for energy and capacity costs,
and the administrative and marketing costs. Walmart would like to examine program credits and
costs in Phase II. Id. at 8.
Walmart advocated for broader eligibility limits in the CEYW – Construction option for
commercial and industrial customers who can aggregate more than 5-MW of load across accounts
in the Company’s Idaho service territory, regardless of service schedule. Id. at 21. Walmart’s
concept of expanded eligibility would allow multiple customers to join under a single agreement
or one customer with multiple locations to use more than one resource. Id. Walmart, and other
multi-site customers who are individually too small for Schedule 19, would benefit from this
expansion. Id.
6. Public Comments
There were multiple public comments advocating for community-owned solar and
improving program access for low-income customers. For example, many commenters expressed
their willingness to participate in a community-solar subscription program and urged the Company
to work with community groups to make this available. Other commenters identified financial
barriers to adding solar to their residences or participating in a community-owned solar generation
program, even though they believed that such a program was beneficial.
Blaine County supported the CEYW programs and the potential to “significantly improve
customer access to clean energy procurement.” Blaine County Comments at 1. As proposed,
Blaine County would not benefit from the CEYW – Construction offering and requested expanded
options—including 25 and 75 percent options—to increase program flexibility and access. Blaine

ORDER NO. 35893 15

County would like the Company to work with municipalities on renewable energy projects through
the CEYW – Construction option, including a potential microgrid project in its jurisdiction.
The Idaho Organization of Resource Councils (“IORC”) expressed support for CEYW
programs and clean energy and advocated for community-owned solar and affordable program
access. Because “many low and middle-income Idahoans do not have the option to pay more per
month on their monthly utility bills to receive clean energy,” IORC believes that price is a “key
factor” for customer adoption. IORC Comments at 1.
Most commenters requested the CEYW options be available to all customers in Idaho and
strongly recommended the Company consider or be directed to offer community solar programs
to interested persons. Commenters also cited climate change and social justice as reasons to
approve the program and/or offer community solar.
7. Company Reply Comments
The Company acknowledged Staff’s recommendation to approve the name change of
Schedule 62 and commented that the name change aligns with the Company’s clean energy goals
and creates consistent branding for its program activities. Company Reply at 1.
CEYW – Flexible
The Company appreciated Staff’s recommendation to allow procurement of third-party
RECs. Because RECs are in high demand, the Company believes that customers will benefit from
its experience to source third-party RECs. Id. at 5.
The Company committed to additional REC reporting requirements suggested by Staff but
disagreed with a separate reporting requirement before the PCA filing for two reasons. Id. at 6.
First, the Company argued the proposed timing did not align with the PCA filing date. Id. at 7. The
Company represented that:
RECs are created by a tracking authority, such as WREGIS, 90 days after the end
of the generation period. This means December REC generation will not be
confirmed until early April in the following year. Once RECs are confirmed, the
REC seller then needs time to perform the REC transfers or retirements and prepare
confirmation reports or letters for the REC buyers. Company-owned REC sales
revenue flows to the PCA when the REC is retired. PCA sales allocation for a given
month is determined within the first couple of weeks in the following month. For
RECs retired in March, the PCA sharing amount will not be known until early to
mid-April. This means the data for CEYW reporting will be incomplete if the
reporting deadline is moved to April 15 or earlier.
Id.

ORDER NO. 35893 16

Second, the Company noted the first quarter always brings about several labor-intensive
tasks for managing the REC program and preserving the biennial reporting and the existing August
29 deadline for the additional CEYW reporting elements would be helpful. Id. at 7-8.
CEYW – Subscription
The Company supported Staff’s recommendation to allow the Company to proceed with
the general framework of the CEYW – Subscription option and validated the concerns expressed
by Staff and intervenors about the lack of detail—which it proposed would be addressed in Phase
II. Id. at 8-9. The Company agreed to work with Staff to discuss potential avoided cost methods
concerning CEYW - Subscription. Id. at 9-10. Due to program cost and credit concerns from Staff
and intervenors, the Company supported Staff’s recommendation to discuss potential methods “to
calculate a reasonable avoided cost to benefit participants while holding non-participants
harmless” in advance of Phase II. Id. The Company objected to intervenor comments requesting
that program credits be allowed to exceed the program charges, because this is a voluntary
program, and it would shift costs to non-participants. Id. at 10.
The Company supported Blaine County’s suggestion to add 25 and 75 percent subscriber
amounts based on a customer’s historic average annual energy use. Id. at 11. The Company
disagreed with Walmart’s proposal to allow any subscriber percentage up to 100 percent of their
average prior year’s use because this would be burdensome to administer. Id The Company also
supported the recommendation to add a 15-year subscriber term in addition to 5, 10, and 20-year
terms already proposed. Id. The Company added that it would propose a Term Adjustment Charge
to customers opting for 15-year terms. Id. In response to Walmart’s request to prorate customer
subscriptions to match program capacity, the Company responded that it believed it could
effectively manage a fully subscribed program using the subscriber amounts—25 - 100 percent of
historic average use—to fill the program to capacity and allow participation. Id. at 11-12. The
Company noted it is open to discussing the proposed customer cap of 15 percent of program
capacity in Phase II. Id. at 12.
Finally, the Company proposed a stakeholder workshop about options for facilitating low-
income access to the CEYW – Subscription option without impacting non-participants. Id. at 13-
14. The Company reiterated “that CEYW is a voluntary premium program.” Id. at 14.

ORDER NO. 35893 17

CEYW – Construction
The Company agreed with two of Staff’s three recommended requirements for approval of
the CEYW – Construction program. Id. at 14-15. The Company agreed it was reasonable to “1)
verify the cost-of-service rates used to recover costs from each Construction customer; [and] 2)
evaluate the effect of increased energy priced at avoided cost in the Company’s overall net power
costs and evaluate alternative methods of determining avoided cost of energy.” However, the
Company disagreed that it should submit all PPAs to the Commission for authorization. Id. The
Company noted it will file all PPAs for the CEYW – Construction option with the Commission
but does not believe approval should be required because “the selection, size, and other details of
a Construction customer’s supporting resources are not necessary for the Commission to review
so long as the customer pays in full for those resources.” Id. at 15.
Regarding Staff’s additional recommendations for approval of CEYW – Construction
projects, the Company agreed with Staff about ensuring all construction-related renewable
resource costs are passed through to the customer; hourly netting of the customer’s energy
consumption against the renewable resource(s) generation; and that net consumption is based on
cost-of-service rates. Id. at 15-16. However, the Company disagreed that net production exported
to the Company’s system should be valued based on avoided cost. Id. at 16. The Company
recommended that the “Commission preserve the flexibility for excess renewable energy
generation compensation to be negotiated within each individual Renewable Construction
agreement.” Id. at 16 and 27-28.
The Company did not support CEO’s recommendation to use EIM as the basis for any
excess renewable energy generation exported to the Company’s system instead of the Integrated
Resource Plan (“IRP”) market forecast. Id. at 16-17. The Company stated:
[a]ctual market prices are surely the best way to compensate Construction
customers for a market sale of their excess renewable energy generation. But the
Company cannot state with certainty whether any excess renewable energy
generation in a given hour will result in system use or a market sale. As a result,
the Company finds a market forecast from the IRP to be the most reasonable price
stream.
Id. at 17.
The Company disagreed with Walmart’s recommendation to allow aggregation of
customer load sites in the Construction offering in the CEYW – Construction option. Id. The
Company argued that the customer aggregation would violate the conditions of the Company’s

ORDER NO. 35893 18

Rule C and that it is not feasible or practical (time and effort intensive) to extend the option to its
smaller customers. Id. at 17-18. The Company iterated that it designed the CEYW – Construction
option for its largest customers and developed separate programs for other customers that do not
fit into the largest group. Id. at 18.
Workshops and Reporting
The Company agreed to hold a workshop on the PCA treatment of CEYW offerings and
how system-generated RECs would be passed through to participants through the PCA in advance
of the next general rate case.1 However, the Company iterated its disagreement with Staff’s
suggestion that CEYW participants should not benefit from system-generated RECs through the
PCA arguing that it would “penalize this subset of customers from experiencing the same reduction
of power costs enjoyed by all customers for energy services they take from Idaho Power.”
Company Reply at 19.
The Company agreed to host a workshop on the accounting treatment of costs, benefits,
and loads for all CEYW offerings before the next general rate case.2 The Company agreed that
workshops in Phase II of the CEYW – Subscription options would be valuable to discuss and build
consensus around program details with the parties. Company Reply at 20. The Company
recommended it lead the workshops instead of Staff. Id.
The Company considered Staff’s additional reporting requirement reasonable, except that
the information belonged in the future CEYW reporting requirement—not the PCA. Id. at 20-21.
The Company noted that most of the recommendations had little bearing on the PCA and could
further complicate what is already complicated, unnecessarily. Id. at 21.
Additional CEYW Recommendations and Alternatives
The Company noted that several comments requested the Company investigate
community-owned solar options and expand program access for low-income customers. While the
Company believed these ideas fall outside the scope of its Application, the Company agreed to
include the issues in a future stakeholder workshop. Id. at 21.
Regarding several comments about CEYW and on-site generation, the Company would
not rule out that the resource would be distributed (opposed to transmission connected) because
the resource had not been selected yet. Id. at 22. However, the Company noted it was unclear how

1 This is not feasible since the Company filed its general rate case on June 1, 2023.
2 Ibid.

ORDER NO. 35893 19

on-site generation could serve as a CEYW resource because it “does not own or control the on-
site generation and therefore cannot assign other customers the costs, credits, or RECS associated
with those resources.” Id. at 23. The Company did indicate there may be creative ways to allow
on-site generators to serve as CEYW resources and invited stakeholders to present alternatives in
a future workshop. Id. at 24-25.
Resource Procurement
The Company agreed with Staff’s recommendation to allow the Company to procure
resources for the CEYW programs outside of the current competitive bidding requirements. Id. at
13.
RECs
The Company disagreed with Walmart’s request for the Company to “make attestations
available on an annual basis to participating customer [sic] who choose to have the Company retain
and retire the RECs.” Id. at 24 quoting Walmart Comments at 7. The Company argued it had
accounted for these for the CEYW – Subscription customers when it proposed REC treatment
would be considered based on customers’ interest on a case-by-case basis. Id. at 12.
COMMISSION DECISION
The Commission has jurisdiction over this matter under Idaho Code §§ 61-501, -502, and
-503. Idaho Code § 61-501 authorizes the Commission to “supervise and regulate every public
utility in the state and to do all things necessary to carry out the spirit and intent of the [Public
Utilities Law].” Idaho Code §§ 61-502 and -503 empower the Commission to investigate rates,
charges, rules, regulations, practices, and contracts of public utilities and to determine whether
they are just, reasonable, preferential, discriminatory, or in violation of any provision of law, and
to fix the same by order. Pursuant to its statutory duties, the Commission has the authority to
review and investigate contracts. Empire Lumber Co. v. Washington Water Power Co., 114 Idaho
191, 192, 755 P.2d 1229, 1230 (1987).
The Commission has reviewed the record, including the Company’s Application, the
comments from Staff, the Company, Intervenors, and the public. The Commission commends the
efforts of the parties and public to submit thorough and thoughtful comments that have provided
the Commission with a robust record to base its decision upon. Based on our review, and consistent
with our authority under Title 61, we find it to be fair, just, and reasonable to approve the CEYW
program as discussed below.

ORDER NO. 35893 20

First, the Commission approves renaming the existing Schedule 62—Green Power
Purchase Program Rider (optional) to “Clean Energy Your Way Program” and renaming the Green
Power Program to “Clean Energy Your Way – Flexible”. The Commission believes that renaming
these programs will help communicate their goals, and the new offerings, to existing customers
and customers.
Second, the Commission supports expanding the CEYW – Flexible REC procurement
options, including having a Limited Bulk Purchase Option. This is beneficial to the Company and
its customers because the demand—according to the Company—will likely require third-party
REC options in addition to the Company’s RECs. The Company should ensure it minimizes risks
to customers through policy safeguards by selling an entire batch of RECs before initiating its next
bulk purchase, and by using separate accounting treatments and tailored agreements for purchases.
If the safeguards in place for the Limited Bulk Purchase Options fail to provide the anticipated
safeguards, the Company should work with Staff and interested parties to create a solution that
ensures all customers are protected adequately.
Third, the Commission appreciates the Company’s desire to include Staff’s proposed
additional reporting requirements in a consolidated report. In Order No. 33570, the Commission
ordered the Company to submit biennial Green Energy Reports. The Commission directs the
Company to provide reporting on an annual basis as opposed to biennially-before the Company’s
annual PCA filing on April 15 each year. This reporting shall continue to provide the same
information that it was previously ordered to submit in its biennial Green Energy Prudence Reports
which includes:
• Customer count under each participation option, by Schedule;
• Monthly RECs purchased;
• Monthly revenue and expenses for Schedule 62;
• Updated costs associated with re-certifying the RECs prior to retirement;
• Summary of marketing activities and expenses;
• Solar 4R Schools expenses;
• Percentage of RECs purchased within the Company’s service territory; and
• Monthly funds transferred to the PCA from the Company-owned REC
purchases.

See Order No. 33570 at 3. Additionally, the Commission directs the Company to include the
following information in this consolidated, annual report:

ORDER NO. 35893 21

• Information on advanced procurement purchases and if any remaining
RECs from those REC purchases will carry over into the next year;
• Information on all tailored agreements for third-party RECs in Flexible
Option 3 Large Purchase Option including, but not limited to: (a) REC
purchase agreement price and quantity requested; (b) quantity and price of
RECs procured for the customer; (c) monthly revenue and expenses; and
(d) provide proof of separate accounting treatment;
• Provide balance of uncommitted/excess funds to be carried over into the
next year; and
• Provide the monthly balance of the rider for Schedule 62.

Fourth, the Commission agrees to allow the Company to procure associated program
renewable resources outside the Commission’s current competitive bidding requirements, subject
to review in Phase II for the CEYW – Subscription option. The Commission reminds the parties
that Phase II will provide opportunities to review and adjust the proposed procurement process.
We recognize that not all details are available at this “framework” stage and encourage the
Company to follow a thorough procurement process that protects all customers. This would
include addressing concerns about the possibility of an under-subscribed program. For example,
if the CEYW – Subscription option is not fully subscribed, the Company’s proposed recovery
through the PCA could negatively impact non-participants for the cost of a resource that is not
least cost. Again, this concern is best addressed in Phase II.
In the CEYW - Subscription option, the Company proposed to dispatch unsubscribed
energy to the Company’s system with cost of that energy to be included in customer rates and/or
in the PCA mechanism. Due to an increase in costs and benefits transferred to the PCA from
Company-owned REC purchases and other costs being passed through the PCA from the CEYW
- Construction options and potentially the CEYW – Subscription option, the Commission directs
the Company to include the foregoing supplemental information in future PCA filings regarding
these CEYW options:
• CEYW offering cost information that flows through the PCA;
• The amount of consumption and generation from the renewable resources
serving CEYW Construction projects;
• Annual CEYW Construction customer load forecasts compared to CEYW
Construction customer's annual generation forecast for all signed PPAs
broken down on a monthly basis;
• Annual CEYW Subscription enrollment; and
• Forecasted CEYW Subscription enrollments and load.

ORDER NO. 35893 22

Further, the Commission strongly encourages the Company to find alternatives to account
for undersubscription that either minimizes or eliminates the impact to non-subscribers during
Phase II of the CEYW - Subscription option design phase. The Commission also finds that going
forward it is appropriate for Staff to request additional information when the Company files Phase
II of the CEYW - Subscription option and on a case-by-case basis after contractual agreements for
the CEYW - Construction options are submitted for approval. The Commission accepts the
Company’s framework for a future voluntary subscription green power service offering under the
proposed CEYW – Subscription option. However, we note acceptance of the Company’s
framework does not guarantee the outcome of the options available; rather, the framework will
serve as a starting point for building the subscription offerings, which will be reviewed during
Phase II.
Fifth, the Commission directs the Company to discuss potential avoided cost methods for
the CEYW – Subscription and Construction options with Staff. It remains vital that COS principles
are maintained in these new offerings, and that non-participants are held harmless. This discussion
should happen within six months of the issuance of this Order.
Sixth, for CEYW – Subscription, the Commission finds that adding 25 and 75 percent
options as proposed by Blaine County, for a total of four subscriber options—25, 50, 75, and 100
percent—will facilitate greater customer access, and is preferable to unique, adjustable subscriber
options. Additionally, the Commission also directs the Company to offer a 15-year subscription
term, for a total of four term options—5, 10, 15, and 20 years, for similar reasons. The Commission
believes the additional term length and subscriber options will benefit customers while maintaining
structured parameters for the Company as it develops offerings. In Phase II the parties should
determine the appropriateness of caps for individual customer subscription amounts, if necessary.
Seventh, the Commission supports the Company’s proposed CEYW – Construction option,
subject to the additional requirements discussed below. The Commission directs the Company to
verify the COS rates used to recover costs from each CEYW – Construction customer to ensure
the Company does not pass on capacity-related costs to the Company’s other customer classes that
are normally recovered through its volumetric charge for energy no longer supplied from the
Company’s system, but supplied by the CEYW customer’s REF, through a fixed cost charge for
energy generated by the customer’s REF, as was proposed by the Company.

ORDER NO. 35893 23

The Commission reaffirms that principles of avoided cost can provide a threshold to protect
other customers when determining credits for excess energy, but it does not require that the amount
of the credits should be based on avoided costs as a matter of policy. Order No. 35607 at 12-13.
The Company is free to negotiate rates with CEYW – Construction customers and “the
Commission will generally approve such rates provided they are fair, just, and reasonable to all
customers.” Id. To the extent that energy credits paid to CEYW – Construction customers and
other types of generation are informed by avoided cost and become an increasing proportion of
the Company’s net power cost, the Commission directs the Company to evaluate its impact on
overall net power costs and to Idaho customers. To mitigate the impact, the Commission directs
the Company to evaluate other methods for determining energy credit payment amounts to ensure
these credits do not put upward pressure on rates. The overall goal of these requirements is to
ensure no harm non-participants and to uphold COS principles consistent with Commission
precedent. To that end, the Commission believes it is important that the Company: (1) ensure all
CEYW – Construction related renewable resource costs are passed through to the customer; (2)
compare hourly netting of the customer’s energy consumption against the renewable resource(s)
generation; (3) base net consumption on COS rates; and (4) value the net production exported to
the Company’s system to be no more than avoided cost.
Eighth, the Commission reaffirms its decision to require the performance-based payment
method for capacity credits paid to CEYW – Construction customers as directed by the
Commission in Order No. 35735.
Ninth, the Commission requires every RCA and associated PPA be submitted to the
Commission for review and authorization, consistent with Commission Order No. 35482. The
Company shall incorporate the requirements from Order No. 35482 that (a) payments of
Renewable Capacity Credits for CEYW-Construction projects begin on the first capacity
deficiency date approved by the Commission at the time the PPA (or a resource construction
agreement) is executed by the Company, and (b) the resource(s) used as a surrogate to determine
avoided capacity cost be identified using the lowest-cost selectable resource from the most recently
acknowledged IRP determined at the time of PPA execution.
Tenth, the Commission directs the Company to host a workshop on the CEYW costs,
revenues, and loads in base rates within one hundred twenty (120) days of the issuance date of this
Order. The Commission also directs the Company to hold a workshop to evaluate how system-

ORDER NO. 35893 24

generated REC benefits are passed on to CEYW – Construction customers in the PCA within one
hundred twenty (120) days of the issuance date of this Order.
Eleventh, we find it fair, just, and reasonable that the eligibility date for payment of
Renewable Capacity Credits of future renewable resources acquired by the Company for CEYW-
Construction customers begins on the first capacity deficiency date approved by the Commission
at the time the PPA or a resource construction agreement is executed by the Company. Staff and
the Company have agreed with this treatment in Case No. IPC-E-22-06.
Twelfth, we reaffirm Order No. 35482, that found it fair, just, and reasonable that the
resource(s) used as a surrogate to determine avoided capacity cost be identified using the lowest-
cost selectable resource from the most recently acknowledged IRP at the time of PPA execution.
This treatment will ensure methodological consistency between CEYW – Construction projects
and fair compensation for capacity avoidance resources.
Thirteenth, consistent with our findings in Case Nos. IPC-E-21-42 and IPC-E-22-06 we
find it fair, just, and reasonable that the credits for excess energy and capacity included in power
supply expense be subject to 95% sharing in the PCA. These credits are based on avoided cost and
are an integral part of the Company’s overall power supply expense cost structure, which the
Company has the responsibility to manage. Furthermore, the resources under CEYW –
Construction projects and associated agreements, unlike resources under PURPA, which the
Company is mandated to take by the Federal Energy and Regulatory Commission, are freely
negotiated by the Company with its customers.
O R D E R
IT IS HEREBY ORDERED that the Commission approves renaming the existing Schedule
62—Green Power Purchase Program Rider (optional) to Clean Energy Your Way and renaming
the Green Power Program to Clean Energy Your Way – Flexible.
IT IS FURTHER ORDERED that the Commission supports expanding the CEYW –
Flexible REC procurement options, including having a Limited Bulk Purchase Option.
IT IS FURTHER ORDERED that the Company must file a consolidated CEYW report
annually before the Company’s PCA filing. The CEYW – Flexible report is to incorporate the
requirements from Order No. 33570 including, (1) customer count under each participation option,
by Schedule; (2) monthly RECs purchased; (3) monthly revenue and expenses for Schedule 62;
(4) updated costs associated with re-certifying the RECs prior to retirement; (5) summary of

ORDER NO. 35893 25

marketing activities and expenses; (6) solar 4R Schools expenses; (7) percentage of RECs
purchases within the Company’s service territory and; (8) monthly funds transferred to the PCA
from the Company-owned REC purchases. Additionally, the consolidated report must include (1)
information on advanced procurement purchases and if any remaining RECs from those REC
purchases will carry over into the next year; (2) information on all tailored agreements for third-
party RECs in Flexible Option 3 Large Purchase Option (REC purchase agreement price and
quantity requested; quantity and price of RECs procured for the customer; monthly revenue and
expense; proof of separate accounting treatment); balance of uncommitted/excess funds to be
carried over into the next year; and the monthly balance of the rider for Schedule 62.
IT IS FURTHER ORDERED that the Commission approves the Company’s framework
for a future voluntary subscription green power service offering under the proposed CEYW –
Subscription option subject to Commission review during Phase II of the CEYW – Subscription
option design phase.
IT IS FURTHER ORDERED that the Company may procure associated program
renewable resources outside the Commission’s current competitive bidding requirements, subject
to review in Phase II for the CEYW – Subscription option.
IT IS FURTHER ORDERED the Company shall include the foregoing supplemental
information in future PCA filings regarding CEYW options: (1) the CEYW offering cost
information that flows through the PCA; (2) the amount of consumption and generation from the
renewable resources serving CEYW - Construction projects; (3) annual CEYW - Construction
customer load forecasts compared to CEYW - Construction customer’s annual generation forecast
for all signed PPA’s broken down on a monthly basis; (4) annual CEYW - Subscription enrollment;
and (5) forecasted CEYW Subscription enrollments and load. The Commission strongly
encourages the Company to find alternatives to account for undersubscription that either
minimizes or eliminates the impact on non-subscribers during Phase II of the CEYW –
Subscription option design phase.
IT IS FURTHER ORDERED that the Commission directs the Company to discuss
potential avoided cost methods for the CEYW – Subscription and Construction options with Staff
and that such discussion should happen within six months of the issuance of this Order.
IT IS FURTHER ORDERED that the Company shall include subscriber options of 25, 50,
75, and 100 percent. The Company shall offer term length options of 5, 10, 15, and 20 years.

ORDER NO. 35893 26

IT IS FURTHER ORDERED that the Company’s proposed CEYW – Construction option
framework is approved.
IT IS FURTHER ORDERED that the Company verify the COS rates used to recover costs
from each CEYW – Construction customer to ensure the Company does not pass on capacity-
related cost to the Company’s other customer classes that are normally recovered through its
volumetric charge for energy no longer supplied from the Company’s system, but supplied by the
CEYW customer’s REF.
IT IS FURTHER ORDERED the Company evaluate the impact of energy credits and other
types of generation informed by or set at avoided cost as the proportion of these types of cost in
overall net power cost increase, and to investigate other methods for determining energy credit
payment amounts to ensure these credits do not put upward pressure on rates.
IT IS FURTHER ORDERED that the Commission reaffirms its decision to require the
performance-based payment method for capacity credits paid to CEYW – Construction customers
as directed by the Commission in Order No. 35735.
IT IS FURTHER ORDERED that the Company submit every RCA and associated PPA to
the Commission for review and authorization, consistent with Commission Order No. 35482.
IT IS FURTHER ORDERED that the Commission directs the Company to host a workshop
on the CEYW costs, revenues, and loads in base rates within one hundred twenty (120) days from
the issuance date of this Order. The Commission also directs the Company to hold a workshop to
evaluate how system-generated REC benefits are passed on to CEYW – Construction customers
in the PCA within one hundred twenty (120) days from the issuance date of this Order.
IT IS FURTHER ORDERED that we find it fair just and reasonable that the eligibility date
for payment of Renewable Capacity Credits of future renewable resources acquired by the
Company for CEYW - Construction customers begin on the first capacity deficiency date approved
by the Commission at the time the PPA or a resource construction agreement is executed by the
Company. Staff and the Company have agreed with this treatment in Case No. IPC-E-22-06.
IT IS FURTHER ORDERED that we reaffirm Order No. 35482, that found it fair, just, and
reasonable that the resource(s) used as a surrogate to determine avoided capacity cost be identified
using the lowest-cost selectable resource from the most recently acknowledged IRP at the time of
PPA execution.

ORDER NO. 35893 27

IT IS FURTHER ORDERED that consistent with our findings in Case Nos. IPC-E-21-42
and IPC-E-22-06 we find it fair, just, and reasonable that the credits for excess energy and capacity
included in power supply expense be subject to 95% sharing in the PCA.
THIS IS A FINAL ORDER. Any person interested in this Order may petition for
reconsideration within twenty-one (21) days of the service date of this Order regarding any matter
decided in this Order. Within seven (7) days after any person has petitioned for reconsideration,
any other person may cross-petition for reconsideration. See Idaho Code § 61-626.
DONE by Order of the Idaho Public Utilities Commission at Boise, Idaho this 15th day of
August 2023.

________________________________________
ERIC ANDERSON, PRESIDENT

________________________________________
JOHN R. HAMMOND, JR., COMMISSIONER

________________________________________
EDWARD LODGE, COMMISSIONER

ATTEST:

Jan Noriyuki
Commission Secretary

I:\Legal\ELECTRIC\IPC-E-21-40 CEYW\orders\IPCE2140_final_cs.docx