20220706Petition for Reconsideration.pdf

Peter J. Richardson ISB # 3195
RICHARDSON ADAMS, PLLC
515 N. 27th Street
Boise,Idaho 83702
Telephone: [phone]
Fax: [phone]
peter@richardsonadams. com
Attomeys for GeoBitrnine LLC
IN THE MATTER OF THE
APPLICATION OF IDAHO POWER
COMPANY FOR AUTHORITY TO
ESTABLISH A NEW SCHEDULE TO
SERVE SPECI.'LATIVE HIGH-DENSITY
LOAD CUSTOMERS
' _ 1 :-'
... : !rl
' :'Lit:. i
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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cAsE NO. [PC-E-21-37
PETITION FOR RECONSIDERATION
OF GEOBITMINE LLC A}.ID
PETITION FOR INTERVENTION AS
A PARTY
COMES NOW, GeoBitmine LLC ('GeoBitnine"), and pursuant to Rules 33,71-72,md
331 of the tdaho Public Utilities Commission's ('Commission") Rules of Procedure and
pursuant to ldaho Code $ 6l-626 and herby respectfully lodges its Petition for Reconsideration
of Order No. 35428 issued on June 15,2022,and Petition to Intervene, in the above captioned
matter. GeoBitnine is a prospective customer of Idaho Power, and ldatro Power has recently
informed GeoBitnine that the newly approved Schedule 20 will apply to GeoBitmine. For the
reasons set forth in detail below, GeoBitnine requests reconsideration of Order No. 35428. As is
detailed below, the Commission's approval of ldaho Power Company's (*Idaho Powe/'or the
GEOBITMINE LLC PETITION FOR RECONSIDERATION AND PETITION TO INTERVENE
IN CASE NO. TPC.E-2I-37 PAGE I
"Power Company') Applicationl to implement Schedule 202 is mistaken, unreasonable,
unlawful, erroneous and not in conformity with the law.3 Commission Rule of Procedure 331
requires that GeoBitmine state the nature and extent of evidence or argument it will present or
offer if reconsideration is granted. GeoBitmine does not believe that an evidentiary hearing is
necessary for the Commission to reconsider its order and to now reject/deny ldatro Power's
Application. Rehearing of the Commission's decision may be had by legal briefing.
I.
INTRODUCTION
r. The GeoBitmine Business Model
GeoBifrnine LLC, is a Puerto Rican limited liability company that is duly qualified to do
business in the Sate of Idaho. GeoBitnine pursues a unique business model of combining
cryptocurrency mining operations with high-capaclty indoor farming technology. GeoBitmine
uses this creative synergistic approach to utilizing waste energy from crlpto mining to sustain
year-round greenhouse farming operations. GeoBitmine's business model focuses on locating
facilities in rural agricultural regions which encourages the development and investnent in
infrastructure while at the same time creating local jobs and reducing the distance it takes for
food to get from farm-to-table. GeoBitmine's patent-pending system of crypto mining and high-
capacity indoor farming systems are called "Geo Datapods." Attached at Exhibit la is a twenty-
four-page slide deck describing in the GeoBitmine business model.
I In the Matter of the Application of ldaho Power company for Authority to Establish a New
Schedule to Serve Speculative High-Density Load Customers. Case No. IPC-E-21-37. Herein
"Application."2I.P.U.C. No. 29, TariffNo. IOI, Schedule 20 SPECULATIVE HIGH-DENSITY LOAD.
Herein "Schedule 20."
3 ldaho Code Section 6l-626
4 Although footnoted as 'confidential' this material is in the public domain, albeit proprietary.
GEOBITMINE LLC PETITTON FOR RECONSIDERATION AND PETITION TO INTERVENE
IN CASE NO. IPC-8.2I-37 PACE 2
b. GeoBitmine's Proposed Aberdeenr ldeho F'ecillty
For the past several months GeoBitmine has been in the process of developing its unique
cry,ptocurrency mining operation in conjunction with high-capacity indoor farming at the
recently idled J. R. Simplot Company potato processing plant in Aberdeen, Idaho. The Simplot
Aberdeen facility has several potato cellars, some of which are now vacant and some of which
are still used for potato storage. Initially, the proposed GeoBitrnine facility at the Simplot site
would consist of 3 Geo Datapods adjacent to an approximately thirty-thousand square foot potato
cellar owned by the J. R. Simplot Company which the University of ldatro Research and
Extension School is planning on using for academic seed research. The potato cellar will
ultimately be used for high-intensity indoor commercial food production by utilizing waste heat
from the cryptocurrency Geo Datapods which will produce a temperate year-round growing
climate. In addition to providing a temperate climate for the University of ldaho's research
station and food production, the waste heat from the cqptocurrency Geo Datapods will be
utilized to condition the air in Simplot's potato cellar(s) that are still actively being used for
potato storage. The combination of the utilization of the Geo Datapod waste heat for
conditioning the climate in the potato cellars and seed research facility and indoor food
production operations along with the cryryto currency mining operation is akin to the mature
technology known as cogoreration in the power generation business. In short, it is a highly
efficient and economically multipllng use of the energy initially provided by the local electric
utility.
GEOBITMINE LLC PETITION FOR RECONSIDERATION AND PETITTON TO TNTERVENE
IN CASE NO. IPC.E.21.37 PAGE 3
GeoBihnine was invitedto explore expansion opportunities in Eastem ldaho by, and with
assistance of,, REDI5 and was innoduced to the J. R. Simplot Company via officials frrom
Bingham County. To facilitate CeoBitmine's relationships with the J. R. Simplot Company and
the University of Idaho in the co-location of cryptocurrency mining operations with indoor food
production, University of ldatro seed research and Simplot potato storage in Aberdeen, Idatro it is
necessary for GeoBitmine to secure a year-round reliable souce of electrical power that is
available, (and priced), on a basis that is comparable to the other large power service customers
served by ldaho Power on it electrical grid.
c. Idaho Powerts Response to GeoBitminets Service Inqulres
Beginning in approximately April of this year GeoBitnine began negotiations with ldaho
Power to secure electric service to the combined cryptocurrency mining/indoor farm operation at
Aberdeen, tdalrc. The facility would have a consistent year-round electrical load of
approximately 6,000 kW, which would be sufficient electrical power and energy to operate both
cry,ptocunency and indoor farrring/university research operations. A 6,000 kW year-round
electrical load means that the Facility would qualiff for'service under Idaho Power's Schedule
19, Large Power Service tariff.6 Initially, negotiations with ldatro Power for the proposcd
cryptocurrency/farming operation appeared to be progressing in a mutually satisfactory manner.
Most recently, however, Idaho Power has taken thc position that its newly approved Schedule 20
(the "Speculative High-Density Load" tarif| will apply to any electrical service it provides to the
GeoBitrnine Facility. However, Schedule 20's rates and terms of service make it impossible to
5 REDI is the lead economic development organization for Eastern tdaho. ,See
httos ://www. rediconnects.org/about-uV
6 ldalro Power's Schedule l9 is attached hereto as Exhibit 2.
GEOBITMINE LLC PETITION FOR RECONSIDERATTON AND PETTTION TO INTERVENE
INCASE NO. IPC.E.2I-37 PAGE 4
proceed with the GeoBitrnine/J. R. Simplot/University of Idaho joint business venture's
crlptocurrency/indoor farming/universrty research operations in Aberdeen, Idaho. For the
realnns outlined below, Schedule 20 is problematic and unrealistic for GeoBitmine's proposed
Idaho operations.
II.
SCHEDT'LE 20
PRACTICAL PROBLEMS
r. Contlnuity of Service
As opposed to creating a service schedule designed to accommodate the electric power
and energy needs of its ratepayers, Idaho Power has designed Schedule 20 to discourage, indeed
to make it impossible for new customers to take senrice from the utility. GeoBitnine's business
model combines the cryptocurency fuirction of a bircoin mining operation with local agricultural
enterpriscs an4 in this instance with the University of ldaho's agriculh,ral research activities at
its Research and Extension School. However, one of the primary prcvisions in Schedule 20
allows tdatro Power to, at its discretion, call *Interruption Events" for up to 225 hours a year. An
Intemrption Event results in the customer's facility literally golng'dark.' This is a non-starter
from any prudent business perspective. lntemrption Events can occur at any time during the
afternoon and evenings in the summer months for up to ten hours any time Idaho Power, in the
exercise of its discretion, chooses to trigger such an event. The loss of electicity during the
hottest part of the day in the hottest months of the year will be catastrophic for indoor food
production, potato storage and seed research facilities. Indeed, the very threat (or potential) of
loss of electricity renders it impossible to secure financing or investnent in GeoBitnine's
proposed Aberdeen, Idaho operations. Reliability and continuity of service consistent with the
levels of reliability and continuity of service Idaho Power offers its other customers is critically
GEOBITMINE LLC PETITION FOR RECONSIDERATION AND PETITION TO INTERVENE
TN CASE NO. IPC-E-2I.37 PAGE 5
important to GeoBifinine LLC and its waste heat off-taker business partners such as the J. R.
Simplot Company and the University of ldatrc's Research and Extension School.
b. Rates
Idaho Power proposes to charge GeoBitmine marginal energy rates which exposes
GeoBitmine and its waste heat off-taker business partners' operations to the vagaries of the
volatile and rypically very expensive unregulated spot markets for electricity. None of ldaho
Power's other rate schedules are assessed marginal energy prices. All of Idatro Power's other
similarly situated ratepayers enjoy the benefits of an average or embedded cost for rate sefting
purposes. GeoBitmine's expected load of 6,000 kW coupled with an anticipated consistently
favorable load utilization rate places it comfortably near the midrange of thc usage parameters
under of ldaho Power's existing Schedule 19, which accommodates loads of between 1,000 and
20,U)0 kW. Idaho Power's proposed marginal cost rato setting forjust Schedule 20 places
GeoBitmine at unique risk and at an extreme competitive disadvantage. The marginal pricing
risk (independent, everL of the risk of summer curtailments) makes it difficult if not completely
impossible to attract the necessary investment capital to bring GcoBibmine's business plan to
fruition.
c. Discretion to Implement Schedule 20 - The Threchold Crlterion
Another practical problem with Schedule 20 is the unfettered and unsupervised discretion
that Idaho Power has been given to determine who is and who is not required to take service as a
"Speculative High-Density Load" customer. For example, Schedule 20's Applicability section
provides:
Service under this schedule is applicable and may be mandatory for Customers who have
the ability to relocate quickly in response to short-term economic signals and meet four or
more of the following criteria:
GEOBITMINE LLC PETITION FOR RECONSIDERATION AND PETITION TO INTERVENE
TN CASE NO. IPC.E-2I-37 PAGE 6
As explained above, GeoBitnine LLC's business model is akin to a cogeneration facility that
operates in what is essentially a symbiotic relationship with the businesseVfarms that consume
the waste energy from the cryptocurrency operations. When making the determination as to
whether the "Custome$ ... have the ability to relocate quickly'' GeoBitmine's cryptocurrency
operations (the Geo Datapods) cannot be analyzed in isolation from the entire proposed
economic enterprise which necessarily includes its waste energy off-takers. Neither the J. R.
Simplot Company's potato cellar nor the University of ldaho's Agricultural Extension Research
School are able to "relocate quickly in response to short-term economic signals." [ndee{ the
University of Idaho is a state institution and its experimental research activities probably do not
respond at all to short-term economic signals. Given the economically mutually dependent
relationship between the Geo Datapods and the waste heat ofltakers, it is apparent that none of
the constituent parts are able to relocate "quickly in response to short term economic-signals."
Despite the fact that GeoBifrnine does not even meet this initial threshold criterion for the
applicability of Schedule 20 - Idaho Power has made the arbirary and unilateral finding that
GeoBitmine is required to take service under the terms of Schedule 20.
Ftuther muddying the waters in regard to the applicability of Schedule 20's threshold
criterion is that it provides no definition as to exactly what a "short-term economic signal" is or
how a "short-term economic signal" is measured. Schedule 20 also fails to define what is meant
by a'quick relocation.' Economic trends and signals can span periods of time as varied as hours,
days, years and decades or even longer. A slrort-term economic signal to a macro economist
may bd as long as a several decades. Thus, there is no way to objectively determine what is
meant in Schedule 20's reference to "short-term economic signals." The second part of the
applicability test; "quick relocation," is equally problematic. A 'quick relocation' could take
GEOBITMINE LLC PETTTION FOR RECONSIDERATTON AND PETITION TO INTERVENE
IN CASE NO. IPC-8.2T.37 PAGE 7
place in a single day as with a residential tenant's rent-skip in the dark of the night or it may take
several decades as did the transition of the ldaho economy from extraction-based industies to
service-based industries. The lack of any certainty, or even any hint, as to the meaning of these
terms makes it difficult (expensive), if not completely impossible, for potential investors to
assume the risk ofparticipating in GeoBihnine's proposed business venture in Aberdeen.
Compounding the uncertainty associated with the power company's failure to define the
critical operative terms in the applicability section of Schedule 20, is the blanket discretion ldaho
Power is given to initially determine whether or not the Schedule is "mandatory." Idaho Power's
response to the following discovery question highlights this issue:
REQIIEST FOR PRODUCTION NO. 7:7
The "Applicability" section of the Company's proposed Scheduled 20 at page 20-
2 provides that, ".Service under this schedule is applicable to and may be mandatoryfor
Cwtomers who have the ability to ...." Please reconcile the use of the two phrases "rs
applicable to" and "may be mandatory. " [f the proposed schedule "may be rnandatory"
please explain who will make the determination as to when it is or, is not, mandatory
and what criteria will be used in making the determination.
RESPONSE TO REQUEST FOR PRODUCTTON NO.7:
Idaho Power will determine whether service is mandatory under Schedule 20
based on an evaluation of the criteria outlined in the schedule's applicability section.
While a certain amount of flexibility may be useful in implementing a complex set of rules
applicable to electric serice, giving the regulated utility complete discretion to determine
whether or not its tariffs are "mandatory" injects factual uncertainty and therefore imposes
needless economic risk on potential customers who are evaluating locating in ldaho Power's
7 ldaho Power Company Response to First Production Request of the Industrial Customers of
ldaho Power. Italicized and bold text in original, underscoring provided.
GEOBITMTNE LLC PETITION FOR RECONSIDERATION AND PETITTON TO INTERVENE
IN CASE NO. IPC.E.2I.37 PAGE 8
seroice territory. As discussed below, this uncertainty is compounded by the lack of definiteness
in applying "the schedule's applicability section."
d. Discretion to Implement Schedule 20 - The 'Four out of Seven' Test
Once the murky threshold question of whether a Customer is able to "relocate quickly in
response to short-term economic signals" has been answered (solely by Idaho Power and solely
in Idaho Power's discretion) then the question of the applicability of Schedule 20 issue is
resolved by ldaho Power's determination as to whether the prospective customer meets four-out-
of-seven enumerated criteria. As with the threshold criterion, the criteria in the four-out-of-
seven test are determined solely by ldaho Power and solely within Idaho Power's discretion.
Even so, in asserting that Schedule 20 applied to GeoBibnine's proposed facility, Idaho Power
did not inform GeoBitnine which of (or how many of) Schedule 20's seven criteria apply to its
proposed facility. Rather, the Power Company, simply asserted that Schedule 20 applies to
GeoBitmine without individually justifring any, let alone four, of the seven criteria.
Because it has not specifically enumerated which of the seven criteria tdaho Power
believes are applicable to GeoBifrnine, it is impossible to analyze (critique or confirm) the power
company's conclusions. Regardless, however, five of the seven criteria are as dishessingly
vague as the threshold question has proven to be. The seven criteria are:
l. High energy use density;
2. High load factor;
3. Load that is portable and disnibutable;
a. Highly variable load growth or load reduction as an individual customer and/or
in aggregate with similar customers in the Company's service area;
5. High sensitivity to volatile commodity or asset prices;
6. Part of an industry with potential to quickly become a large concenEation of
GEOBITMTNE LLC PETTTION FOR RECONSIDERATION AND PETITION TO INTERVENE
TNCASE NO. IPC.E.2I.37 PAGE 9
power demand;
7. Lack of credit history or ability to demonstrate financial viability.s
Only the first two criteria are subject to any objectively determinable standard. The remaining
five criteria can be applied, depending upon the eye of the beholder, to practically every industry
currently operating in Idaho Power's service tenitory. [ndeed, the last five criteria are essentially
meaningless absent some objective sideboards to instnrct ldaho Power as to when they arc to be
tiggered. For example, this concem is verified by the powcr company's response to a discovery
question on criterion four, "Highly variable load growth or load reduction...:"
REQUEST FOR PRODUCTION NO. ll:e
The fourth of the seven criteria is "Highly variable load growth or load reduction..."
Proposed Schedule 20, however, does not define the phrase "Highly
variable load growttr or load reduction..." Please define or provide the criteria the
Company will use in determining, what is "Highly variable load growth or load
reduction,.." for purposes of the applicability of proposed Schedule 20. Does the
Company have load growtlr/variation criteria it intends to apply? If so, please describe the
criteria intended to be applied.
RESPONSE TO REQUEST FOR PRODUCTION NO. l1:
The Company has not determined the specific load growth or variation criteria;
rather, Idaho Power would evaluate the changes in requested load growttr or load
reductions from customers on a case-by-case basis.
Not only are the "specific criteria" for determining the applicability of this fourth item in the
applicability section not defined, Idaho Power observes that they will never be defined. Indeed,
they will only be "determined... from customers on a case-by-c,ase basis." All of the final five
criteria suffer similar fatal defects for vagueness. Critical operative terms are left undefined and
Idaho Power is given cart blanc to determine which prospective customers it will allow to take
I The seven criteria have been numbered sequentially for ease of reference. They are listed but
not numbered in Schedule 20.
e ldaho Power Company Response to First Production Request of the Industrial Customers of
Idaho Power. Bold text in original.
GEOBTTMTNE LLC PETITION FOR RECONSIDERATION AND PETITION TO INTERVENE
TN CASE NO. IPC.E.2I.37 PAGE IO
service under Schedule 19 and which prospective customers it will force to take service under
Schedule 20. Of course, the'choice'to take service under Schedule 20 is a misnomerbecause
with its intemrptability and marginal pricing provisions Schedule 20 is nothing more than a
Hobson's choice for prospective businesses looking to operate in ldaho.
uI.
PETITION FOR RECONSIDERATION
t. Legel Framework
The Commission exercises limited jurisdiction and has no authority other than that
expressly granted to it by the legislature. Washington Water Power v. Kootenai Environmental
Alliance, 99 Idatro 875, 591 P.zd 122 (1979). As a result, nothing is presumed in favor of its
jurisdiction. Untted States v. Unh Power A. Light Co.,98ldaho 665, 570 P2d 1353 (1977).
The Commission has jurisdiction over utility rate-making matters. Idaho Code $ 6l-502 et seq.
However, in exercising authority over rates, the Commission is forbidden to allow preferential
tneatment, advantage, prejudice or disadvantage between ratepayers. Idaho Code $ 6l-315;
Idaho State Homebuilders v. lToshinglon Water Power Co., 107 Idaho 415, 690 P.2d 350 (1984);
Building Contractors Assn of Southwestern ldaho, Inc., v. Idaho Public Utilities Commission,
I 28 ldatro 534, 916 P.2d 1259 (l 996).
b. Schedule 20ls an lllegally dlscriminatory classification and hence in violation of law
and beyond the Commlssionts authority to approve.
It is black letter utility law that the Commission may not approve, and utilities may not
charge, rates that Eeat customers preferentially or to disadvantage some customers to the benefit
of other, similarly situated, customers. tdaho Code Section 6l-503 codifies this prohibition:
Discrimination and preference prohibited. - No public utility shall, as to rates, charges,
service, facilities or in any other respect, make or grant any preference or advantage to
any coqporation or percon or subject any corporation or person to any prejudice or
GEOBITMINE LLC PETITION FOR RECONSIDERATION AND PETITION TO INTERVENE
TN CASE NO. IPC.E.2I.37 PAGE I I
disadvantage. No public utility shall establish or maintain any unreasonable differences
as to rates, charges, service, facilities or in any other respect, either as between localities
or as between classes of service.
Thus, while it is clear that the Commission has the authority to set different rates and charges and
establish different terms of service for different classes of customers, it is equally clear that the
Commission may not allow a utility to differentiate rates and terms of service when doing so is
preferential or discriminatory among various customers. As noted above, GeoBitmine's
requested electric service parameters are not unusual. GcoBitmine requested electric service of
only approximately 6,000 kW. In addition, GeoBitmine's electric power and energy would be
utilized on a year-round basis with an attractive load factor.l0 These requested service
parameters are not unique and, in fact, fall almost exactly in the midpoint of eligibility for
electric service under ldaho Power' existing Schedule l9.lr There is nothing in GeoBitmine's
service/usage request that is out of the ordinary or unusual when compared to Idaho Power's
other Schedule l9 customers. In fact, there is nothing in GeoBitnine's service request that even
remotely suggests it should be taking service under any schedule other than existing Schedule
19. Yet, ldaho Power's Schedule 20 grants preferential treatment to all of ldaho Power's other
ratepayers (including its Schedule 19 ratepayers) by assessing marginal rates only to Schedule 20
and forcing just Schedule 20 ratepayers to suffer draconian intemrptability provisions that are
not also imposed on any other ratepayer class on ldatro Power's system.
l0 Load factor is a measurement of the efficiency of electrical energy usage. It is calculated by
taking the total electricity (k!Vh) used in the month, divided by peak demand (kW) multiplied by
the number of days in the billing cycle and the total hours in a day.ll Schedule l9's usage parameters are between 1,000 kW and 20,000 kW. Schedule 19 does not
impose load factor requirements other than for minimum eligibility to determine if the 1,000 kW
threshold has been met.
GEOBITMINE LLC PETITION FOR RECONSIDERATION AND PETITION TO INTERVENE
IN CASE NO. IPC.E-2I.37 PAGE 12
The ldaho Supreme Court has provided ample guidance to the Commission as to the
establishment of legitimate rate classification differences. ln ldaho State Homebuilders v
Washington Water Power, the Court made clear that:
A reasonable classification of utility customers may justifr the setting of different rates
and charges for the different classes of customers. Any such difference (discrimination)
in a utility's rates and charges must be justified by a corresponding classification of
customers that is based upon factors such as cost of service. quantity of electricity used.
.t2
Electric utility rate classes are distinguished based on the costs they impose on the utility for the
provision of electric service and not on the nature of the widgets produced by the Power
Company's ratepayers.
Schedule 20 suffers frrom the identical flaw the Supreme Court found unlawful in the
Homebuilders case. Here Idaho Power is fearful that new load will cause upward pressure on its
overall cost to serve by forcing it to acquire new, tlpically more expensive, resources. Hence it
seeks to create a class of customers who are new to the system and who potentially utilize large
amounts of electricity. The ldaho Supreme Court has repeatedly found such ratemaking schemes
to be illegal:
ln Homebuilders, Washington Water Power requested approval for a seasonal commodity
rate that would serve as a signal to all electric customers regarding the utility's higher
cost of resource supply in winter and thus encourage energy conservation...
The IPUC ... [adopted] a one-time, nonrecurring contribution charge . .. for all new
customers who used electricity for space heating....
The Homebuilders court concluded that the contribution charge unlawfully discriminated
between Washington Water Power's "new" and'bld" customers, rejecting the notion that
only "new" customets are responsible for the level of resource dcmand in the winter
months. Id. at 421, 690 P .2d at 356. Although the record established that incrcased
demand necessitate an increased reliance on more expensive resources, the Court
12 Emphasis provided, parenthetical in original text. Citations omitted. Supra, 107 ldatro at4l7,
690 P.2d at354.
GEOBITMINELLC PETITION FOR RECONSTDERATION AND PETITTON TO INTERVENE
IN CASE NO. IPC-E.2I-37 PAGE 13
concluded that the resultant increased costs did not equate with a "difference in criteria of
cost of service or difference in condition of service as between the two class€s."13
Schedule 20,likewise, discriminates between "old" and'hew" customers based solely on when
they connect to the system and not on any different criteria of cost of service. The Commission
should therefore reconsider its decision and deny ldatro Power's request for approval of Schedule
20.
Schedule 20 was approved by the Commission incompletc disregard for any ofthe five
factors identified by the Supreme Court in the Homebuilders decision:
l. Cost of Service - no cost of service study has been completed for this alleged
class of customers.14
2. The Quantity of Electricity used is well within'normal' parameters for Schedule
l9 customers.
3. GeoBibnine presents no unusual Differences in Conditions of Service.
4. There are no Time of use anomalies.
5. The Nature and Pattem of electric usage is very typical for any large high load
factor industrial customer.
The Commission's approval of ldaho Power's proposed new rate class was arbitrary and illegal
in that it faild to justify its decision on anv of the oarameters required of it in order to do so.
The Commission conceded, in its order, that neither it nor ldalro Power have any idea as to what
costs should (or should not) be assigned to this purported class of customers. Hence neither
Idaho Power nor the Commission have any idea whether or not this purported class of customers
tt Bldg. Contrs. Ass'n v. Idaho PUC LzS ldatro at 538. 916 P.2d at 1263.
la [n response to StaffData Request no. 2 the Company admitted that "At the next general rate
case, the Company would evaluate Schedule 20 cost assignment based on the class's usage
characteristics and system requirements as a stand-alone rate class... ."
GEOBITMTNE LLC PETITION FOR RECONSIDERATION AND PETITION TO INTERVENE
TN CASE NO. IPC.E-2I.37 PAGE 14
can legally be singled out for different Eeatnent from all other similarly situated Schedule 19
customers.
This fatal lack of analysis is highlighted by the Commission's order requiring tdatro
Power to, at some unspecified time in the future, evaluate the cost to serve and usage
characteristics of this new 'class' of customers:
We further direct the Company to collaborate with Staffafter the Companv evaluates cost
assigmments based on usage characteristics and system reqlrirements under Schedule 20
and then assign cost and benefits incorporating intemrption rcquirement parameters.ls
Of course, on the record before it, the Commission is unable to distinguish Schedule 20's "usage
characteristics" or its "system requirements" from any other similarly situated Schedule 19
customer. Indeed, in addition to the absence of such evidence in the record, Idaho Power's
discovery rcsponses even confirm that it has not even studied the critical question of what the
rate/cost impact of its proposed new class of customem will have on its overall system:
Idaho Power has not studied how the overall system revenue requirement would be
impacted as a result of inhoducing the proposed customer class. However, a future cost-
of-service evaluation would be the appropriate study to determine how avoidance of the
highest capacity hourr, or the time of system peak, may result in lower cost assignmort
for those system components and how other customer classes may benefit as a result.
The Company believes its proposal is a reasonable near-term offering until such a
detailed study can be performed.r6
Idaho Power's application therefore puts the proverbial cart before the horse. The Idaho
Supreme Court requires a cost-of-service 'evaluation' to be completed in order to justifr the
creation of a new class of customers, but in this case ldaho Power concedes it has not even
performed such a study, much less included such an analysis in the record for review and
comment by affected parties. [t is impossible to base a rate classification on a cost of service
rs Order No. 34528 atp. 7.
16 ldaho Power response to Industrial Customers of tdaho Power Data Request No. 4.
GEOBTTMINE LLC PETITTON FOR RECONSIDERATION AND PETITION TO TNTERVENE
IN CASE NO. IPC.E-2I.37 PAGE 15
study when no such study has been completed or even attempted. In sum, therefore, Schedule 20
is unlawfully discriminatory and must be rejected by the Commission on reconsideration.
c. The Commigsion has no fectual record upon which to base lts decislon, and lts order
is lacking in sufficient llndlngs of fact, unsupported by sufiicient evidence, and
based upon arbitrary reasoning.
The Commission approved Schedule 20 with no understanding of the proposed rate class'
usage characteristics and no understanding of the proposed rate class' system requirements.
There is no evidence in the record of Schedule 20's usage characteristics that distinguish it from
Schedule 19. The Commission should therefore reconsider its order approving Schedule 20
because it is violates the requirements that the Commission's orders include findings of fact, be
supported by substantial evidence, and contain rational reasoning based upon such facts and
evidence.
While the IPUC has broad powerc, "the discretion given the Commission is not
absolute[,]" and the Commission may not act "arbitrarily or on an ad hoc basis. . . ." Wash.
Water Power v, Idaho Pub. Utils. Commh, 101 ldaho 567,575,617 P.2d,1242,1250 (1980)
(intemal quotation omitted). tt is a basic tenet of administativc law that an administrative
agency must "must set forth its reasoning in a rational manner." Wash. Water Power,l0l Idaho
at 575,617 P.2d at 1250. Thus, this Court requires that the IPUC's "'order cleady and precisely
state wlut itfound to be thefacts andfully uplain why thosefacts lead it to the decision it
mokes."' Id. (quoting Home Plate, Inc. v. OLCC,530 P.2d 862,863 (Or. App. 1975) (emphasis
in Wash. Water Power). Additionally, its orders must be "supported by substantial, competent
evidence in the resord." Rosebud Enters. v. Idaho Pub. Utilis. Comm'n,l28ldaho 609,615,917
P.2d766,772 (1996). That standard requires that evidence supporting an agency's decision
must be "substantial, when viewed in the light that the record in its entirety fumishes, including
GEOBITMTNE LLC PETITION FOR RECONSIDERATION AND PETTTION TO INTERVENE
IN CASE NO. IPC-E-2I.37 PAGE I6
the body of evidence opposed to the [agency's] view"-such as this reconsideration petition.
Idaho State Ins. Fund v. Hunnicatt, I I 0 ldaho 257, 261, 7 I 5 P.2d 927, 93 I ( I 985) (intemal
quotation omitted). These rcquirements exist to "ensure that the IPUC has applied relevant
critcria prcscribed by statute or its own regulations and thus has not acted arbitrarily or
capriciously." Rosebud Enters.,l28 ldaho at 615.
In this case, the Commission made no findings of fact whatsoever in its order approving
Idaho Power's creation of a new rate class. The Commission only made the following two
findings:
[.] We find that the Company's creation of a new electric service schedule to provide
service to potential HDL Customers is a reasonable approach to proactively mitigate
stranded asset costs to its core cugtomers.
And...
[2.] Based on our review, we find it fair, just and reasonable to approve the Application.
Although the ldaho Supreme Court gives deference to the Commission's findings of fact - it
nevertheless requires that the Commission actually make findings of fact to support its decisions.
According to the Court:
In addition to making findings of fact based on substantial, competent evidencc, the
IPUC must explain the reasoning employed to reach its conclusions in order to ensurE
that the IPUC has applied relevant criteria prescribed by statute or its own regulations and
has not acted arbitrarily or capriciously.rT
Here, of cource, there is no record evidence in any form, much less any findings of fact,
justiffing Schedule 20 based upon energy rrsage characteristics or impact of the creation of a
new class of customers. The cost-of-service study necessary to make such an evaluation has
tt Bldg. Contrs. Ass'n v. tdaho PUC (in RE Boise Water Corp. to Revise and Increase Rates
ChargedforWater Sent.) l23 ldaho 534,537,916 P.2d 1259,1262 (Idaho 1996).
GEOBITMTNE LLC PETITION FOR RECONSTDERATION AND PETITION TO TNTERVENE
TN CASE NO. IPC-E.2I-37 PAGE I7
been 'kicked down the road' for some other time. Not only is there no substantial competent
evidence supporting the creation of a new class of customers, there simply is no evidence
whatsoever. No party to the case (Idaho Power included) presented testimony or affidavits in
support of their positions. The 'record' is composed of unverified comments that have not been
subject to examination, and what materials that do exist only serve to confirm that no cost-of-
service study was performed.
The lack of a record belies the Commission's cursory *finding" that it is "fair, just and
reasonable to approve the Company's Application" or that the Company's Application is a
"reasonable approach." There is simply no substantial evidence (indeed, no evidence of any
nature whatsoever) supporting the Commission's order, no evidence to support any such findings
that could be made on reconsideration, and certainly no rational connection between the
available facts and the Commission's decision. In sum, in the absence of any justification based
upon factors such as "cost of seryice, quantity of electricity used ...[etc]"18 it is impossible for
the Commission to make a record-based evidentiary finding that creation of this new customer
class and its ensuing rates, is fair, just and reasonable.
Iv.
PETITION TO INTERVENE
GeoBifrnine is not a party to the instant docket, but nevertheless may petition for
reconsideration as a"person interestedon in the orderat issue. Idaho Code Section 6l-626(l). In
the unlikely event the Commission does not grant GeoBitnine's Petition for Reconsideration,
then GeoBitmine must be a "party aggrieved" in order to appeal that decision to the ldatro
Supreme Court. Idaho Code Section 6l-621 . Therefore, in order to preserve its right of appeal
ti Homebuilders, supra * 417,590 P.2d at 354.
GEOBITMINE LLC PETITION FOR RECONSIDERATION AND PETITION TO TNTERVENE
IN CASE NO. IPC.E.2I.37 PACE 18
GeoBitmine hereby (contemporaneously with its Petition for Reconsideration) petitions the
Commission to grant its status as a party. Pursuant to Rule 72 of the Commission's Rules of
Procedure, and as detailed at length above, GeoBitmine alleges a "direct and substantialo'interest
in this proceeding because ldaho Power has recently asserted that it will subject GeoBitmine to
Schedule 20 and Schedule 20's provisions render GeoBitnine's operations infeasible .
v.
PRAYER FOR RELIEF
In accordance with Commission's Rule of Procedure 331, GeoBitmine is required to state
the nature and extent of evidence or argument it will present or offer if reconsideration is
granted. GeoBitmine asserts that the existing'evidentiary record' before the Commission, as
well as the applicable law requires that the Commission modiff OrderNo. 35428 by denying
Idaho Powor's Application for approval of Schedule 20. GeoBitmine does not believe a hearing
is necessary for the Commission to issue its order on reconsideration denying tdaho Power's
Application. GeoBitmine is prepared to provide additional briefing and oral argument should the
commission so require.
this 6th of luly 2022.
J ISB # 3l9s
RICHARDSON ADAMS, PLLC
Attomeys for GeoBitnine LLC
GEOBTTMINE LLC PETITION FOR RECONSIDERATION AND PETITION TO TNTERVENE
INCASENO. IPC-E.2I.37 PAGE 19
I TIEREBY CERTIFY that on the 6th day of July 2022,ttnre and correct copy of the within and
foregoing PETITION FOR RECONSIDERATION AND PETITION TO INTERVENE of
GeoBitmine LLC in Case No. IPC-E-21-37 was sered, by elccnonic copy only, to:
Lisa D, Nordshom
Regulatory Dockets
Idatrc Power Company
I nordstnom@ idahonower. com
docket@ idaholrower.com
Jan Noriyuki, Secretary
Idaho Fublic Utilities Commission
jan.noriyuki@fuc. idaho. gov
RileyNewton
Deputy Attorney General
ri [e-mail]. qov
Commission Secretary
Idatro Public Utilities Commission
secretary@puc. idaho. qov
Connic Aschenbrenner
Idaho Power Company
caschenbrcnnerfa idahopower. com
Peter J. Richardson
Dr. Don Reading
oeter@richardsonadam s.com
dreadin c@mindsori ns.com
Elizabeth A. Koecheritz
2140 Labs LLC
cak@givens?ursley.com
Richardson
ISB # 3195
GEOBITMTNE LLC PETMION FOR RECONSIDERATION AND PETITION TO INTERVENE
TN CASE NO. IPC.E-2I.37 PAGE 20
BEFORE TTIE IIIAITO PUBLIC TTNLITIES COM}IISSION
IN TTIE IUAITER OF TTIE APPTICATION OF
IDAHO PIOWBN. COMPANY FIOR AI,,THORJTY
TO ESTAtsLISH A NEW SCHEDI.,LETOSER.VE
SPEC1jI-ATM HIGH.DEI'ISfIY LOAD
CI.,STOMERS
cAsE NO.IFC-r-ll{?
PEf,TilON F]OR RECONSIDBRATTON OT
GEOBITMINE LI,C AND PETITTOhI F1OR
INTER1IENNONASAPARTY
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Exhibit I cmsirting of twcnty-fivo page entitlc4 "GooBitmfuc LLIC, Crypoorrrcncy Mining
with a Grooner Futuro in Mfud"'
At GeoBitMine, we believe thot creotivity empowers possibility.
tUhot ll we could llnd o woy lo develop locollobt, estoblbh lood
recurlly ond redetlne lhe woy lhc world reG3 cryplocuncncy?
By closing the loop on energy-intensive crypto mining ond leveroging
sustoinoble design, we help communities grow their own locol produce
ond foster o better tomorrow for the next generotion of formers.
ENERGY INTENSIVE
Cryptocurrency uses oround 136.38
Terowott-hours of eleclricity every
yeor-more thon the Netherlonds,
Argentino, or the Uniled Arob
Emirotes.l
FOSSII. IUEt DEPENDENI
42% ol crypto currency ln 2021 wos
mined in lhe United Stotes ond l8%
in Kozokhston2, both of these
countries heovily rely on fossil fuels
to creote electricity.
WASTEfUt
The mojorily of electrlcity used to
mine cryptocurrency is rejected into
the otmosphere os woste heot.
I & 2 - Source: unrversity of Canrbrrdge
CemDildte Cenrre tor All.rnativ€ irrrarris@lnder: Comoarisons
r,' )r,._.'6't\ :t e tt)t, ati r,,1, i Ki!-ry-(l 't
INCREASING DEI,IAND
Generql consensus is thot globol
ogriculture production hos to
increose by obout 6A-70% from the
current levels to meet the increosed
food demond in 2050.r
RESOURCE HEAVY
Agriculture occounts for 70% of oll
freshwoter wllhdrowols globollyz
ond relies heovlly on fossilfuels for
heoting, coollng, drying ond
lronsporllng goods worldwide.
HIGH BARRIER TO ENIRY
New forms toke milllons of dollors
to estoblish ond offer slim profit
morgins which discouroges
younger generotions from
entering the ogriculturol business
I - SOr.lrce: Unrversrry oi MichrBan, MSiJ
Extension Atriculture ' Feedlnr thG world
ln 2ogo rnd b.yond - Prrt l: Productlylty
cIdlrnrcil.
2 - Source: Worlc, Bonk " glfello
Arrlcu lture'
'r ,:,:r' i:- ,covrrg.,r Ceagtlrriie 2C2', ,cll Rrgf,ll keserveo 4
F
Secure sites with the lowcrl co:l, morl rurlolnoble
energy sources ovoiloble. Poir cryoptocurrency
mining with indoor grow orchitecture to provide
lree heotlng ond coollng for tormerr.
20 rw 50lAt
ATTAY
-r.rirE tAt{3 I
UCI lAilTt
utftNlilcoro?oDil
4,540 st.
GITENHO
'NOIE: ONE GEOPODil CREAIES ENOUGH HEAI TO
suPPoRT r-ACRE OF GREENHOUSE (43,560 SFI
PNOIOTYPE SHOWN IS I/IO SCALE
PATENT.PENDING DESIGN
D ift ECT. HEAT PROTOTYPE APPTICATION
FOft COLD WEATHER CLIAAATES
ttEcrltcAltlAtslotrtl
.<*-,i-..-.' ' - ,'**u#:::
x;7'-'
rr t
;:x#it lj ,,1,-tl
-lr
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'al rV"'. ,i + ;
;<l,,ii('.r''t *' ,,I I ' 'r,. "1...{ j'. !trf '!r
,.'l t.'.i
CCINf rDtNtlAl Coptr,,:rit,r C-cDErrmrr,{: 1022 . At Prart"tt pD!{rvc.j r-
!
I
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.: *;: ljl
,i1 _
IIililil,lrtlfla
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ifrlrr$'
,,E tu ^rtu,
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a,
ENVIRONMENIAI.
We wont to tronsform the norrotive
of crypto from on energy droin to o
sustoinoble resource
socrAr
Our GeoPodrM grow focilities ore
co-op bosed. We portner with locol
jurisdictions to benefit locol economies
GOVERNANCE
We strive tor lOO7o lronsporency
with our business development.
*x,c
:rrufce Arremis, The GreenhouSe
)i,.rr.. CccbirMrne reseorcn wirh Red Sun Iorms
riii:)aNiiAr ,._<lpyrrgrrr GeoBirmrne 2022 - A| Rlghls ReServed
HIGHER
PRODUCIION
lndoor horticulture lncludlng
greens, mlcrogreens, herbs, ond
vlne crops ls lT0llmor moreproductlve lhon outdoor flelds.r
INCNEASED
TEVENUE
Eoch ocre of greenhouse
ylelds on ovoroge S5t0-C00kin crop revenue
tomotoes
growlng
2
OVENHEAD COSI
NEDUCTION
One slngle GcoPodil system wlll
sove $150k+ por ycol ln noturol
gos heotlng costs per I -ocre of
greenhouse.2
12
90% WATER USE REDUCTION
LOCAL Tru( .BASE DEVELOPMENT
stffi,ffiB, L€Hoffit J@SS
CO)aHOElmAl, - Gopyrl3hr c.oTfi*ro U8 - ff,ilChlr frrrvrd It
Agrlcullurol Jobs
. I Director
. 2-3 occountont
.23 HR Dept.
. I Food ond Sofety
. I Moster Grower
. I Assislont Moster Grower
. 3 Assistont Monoger
. 75 Loborerc
CONmBflA - @yltghf ccoghhc m -Ar nem Rcsrod
!T & Tech Jobs
Bilcoin Minlng Fqrm Servers
. I Chief lnformotion Officer
. I lT Heod of Mointenonce
. 3 Mointenonce Technicions
. 5 !T Technicions 3 A
. I Monoger
. I Chief of Security
. 3 Security Officers
CONHDENIIAI- - Copyfghr cootrltmh'e?gi,t- N Rlgms R6orved
.
!:tl'L\
tsJr.i +Totol jobs creoted per lS-ocre
greenhouse & bitcoin mining site
CONHD6.{T|AI - Copylght G€oBfimine 202 - AI Rlghts Retdvcd
THE POWER OF PARTNERSHIPS
u Universityolldaho
-
ldoho Notionol Loborotory
t
I
@
CONFIDENnAI - Copyrlghl GeoBltmhe XIZI - N Rights Ross\rod
EASTERN IDAHO !S^-'
. Community support
. Agriculturol integrotion
. Locotion, locotion, Iocotion
' The right power of the right price
. Stote ond locol incentives ond gronts
. Educotionol reseorch & development
. -,,.ii J: i\ t ;. 'i:oyrignl cecBrrmrne 2A2! - A| R;ghls Reserveo
'r.ilr1,"^$ t:
We ore creotlng new jobs yeor-round.
We ore helplng rurol formlng communlties grow ond prosper ln new u/oys.
We wlll be the most sustolnoble ogricullurol & crypto mlnlng compony In the world.
Wr bollcvo ln whol w. do, ond ll rhowr.
GeOBmMINE LLc
THANK YOU
[e-mail]
www.geobitmine.com
CONFIDENiIAL - Copyight ceoBitmine 2Cr22 - All Rights Reserved
;: -r:-i r?V f,f,i'Il-,*PMEN]
AUG 2022
'EPT
2022
FEB 2023
Drect*leot Protype fu nding
Stort & Build€ut Plon
Heot & CoolProtype tunding
Stort & Build€ut Plon
Gother doto & feedbock to
expond ovoilobility of
designed systems
,.i li,tr'i,..- -J?,/(,gtti (;eoBrrnline 2O?2 - Al Rignls Reserved
n ''la
? 'i tilF ACiiCN PLAN
CONCE?I
DESrCll
DITECI.HEAI
'TOIOTY?ESIATT [tAr a coot?IOIOIY?I 3IAT'
2022
2023
Jon Feb Mor Apr Moy Jun Jul Aug Sep Oct Nov Doc
DATA AXA]VEISr tEFtt{EtE}lI
tiAtllt
TESIIf,G IAUl{CH
Jon Feb Mor Apr Moy Jun Jul Aug Sep Oct Nov Dsc
CONFIDENnAL - Copynght Geobitmine 2022 - All Rights Reserveci 24
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Pq,l$fonel Frbnt PFndilB
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! WhlE@cfs. Madre.nleal ErElnecrlrEr Ele1rlcrl ErEln€Grlng. Rendrrlrs. SGsmped Drawirry
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BEFORE THE IDAEO PTIBLIC T'TILITTES OOMMISSION
IN THE MAT?BR, OF TI{E APPLICATION OF
IDAHO FOWER COMPANY FOR AUTTrcRITY
TO EITTABLISH ANEW SCI{EDT,LE T'O SERVE
SPECULA*TIVBHIGTI-DEI{SITYLOAD
ct slloMEnll
C SElt{o.lFc-E"2f-e7
P.EITTK'N FIOR NECONSIDERATION OF
GEOBITMINE LI.c AND PETITPN FOR.
INTERVENTTONAS APARTY
)
)
)
)
)
)
)
)
Exhibit 2 omri*ing of ocrrcn pagm cntitloE *Shodule l9 Large Powcr Scrvie.'
ldaho Porver Company First Revised Sheet No. 19,1
Cancels
|.P.U.C. No.29. TarifrNo. 101 OrhlnalSheet No. 191
IDAHO PT BUC UTILInES CotmsslolrlApplovrd Efbctlvo
Jen. 19,20tl Jan. l,20ll
Per O.N. 12112
Jcen D. Jomll SecrrtelySCHEDULE 19
LARGE PCNilER SERVICE
AVAILABILITY
Servica under this schedule ls available at points on the Companfs interconnected syatem
within the State of ldaho where existing facilitles of adequate capacrty and desired phase and voitage
are avallable. lf addltional distribution fx;ilities arc rcquircd to supply the desired servico, those
facilities provided for under Rule H will be provHed under the terms and conditions of that rule. To the
extent that additionalfacililies not provided for under Rule H, induding transmlssion and/or substafion
fiacilities, are requilud to provide the requested seruice, special arangements will be made in a
separate agreement between the Customer and the Company.
APPLICABILITY
SeMce under this schedule is applicable b and mandatory for Cusbmers who register a
metered Demand of l,flD kW or mor€ per Billing Perbd for three or more Billing Periods during the
most rscent 12 consecutlve Billing Periods. Customers whooe initial ueage, bassd on information
provided by the Customsr, is expected to be 1,000 lrW or more per Bllllng Perlod br three or mors
Billing Periods durlng 12 consecutive Bllling Perlode may, at the Cusbme/s request, tiake service
under thls schedule pdor to meeting the metersd Demand criterion. This schedule will remain
appllcable until the Customer hils to register a metered demand of 1,000 kW or more per Billlng Period
forthree or more Billing Periods during the most rscent 12 consecutiro Billing Pedods.
Deliveries at mors than one Point of tlelivery or more than one vottiage will b€ separately
metered and billed. lf the aggregate power requirement of a Customer who recelves service at one or
more Points of Delivery on the same Premlses exceeds 20,000 kW, the Customer ls lneliglble for
seruice underthis schedule and ls required to make specialcontrad arangornents n'ith the Company.
This schedule ls not applicable to service for resale, to sharsd or inigation sorvi@, to standby or
supplemential seMce, unless the Customer has entered into a Unihrm Strandby Service Agreement or
other standby agreement with the Company, or to multi-family drrellings.
Contract Ootion. Customers for whlcfi thls scfiedule is applicable may optionally take service
under a mutually agreed upon individual special contract betyreen the Customer and the Company
provided the Customer conbac{s for firm electuic Demand of 10,fi)0 kW to 20,000 kW and the special
contract tsrms, conditions, and rates aro approwd by the ldaho Public Lnillties Commlsslon wlthout
change or condition.
TYPE OF SERVICE
The Type of Service provided under this schedule is three-phase at approximately 60 rycles
and at the strandard service voltage available at the Premises to be served.
IDAHO
lssued per Order No. 32132
Effective - January 1,2011
lssued by IDAHO POWER COMPANIY
Gregory W. Said, General Manager, Regulatory Affairs
1221 WoEt ldaho Street, Boise, ldaho
ldaho Porver Gompany
!.P.U.C. No. 29. TarifrNo. 101 Origlnal Sheet No. 19-2
IDAHO PUBLIC UflLMES COTTISSIOilApproved Efioc'tlveFeb.2l,200E tarch l,200E
Pcr O.l{.3050E
Jean D. Jrwrll SecruhrySCHEDULE 19
LARGE POWER SERVICE
(Continued)
BASIC LOAD CAPACIW
The Basic Load Capacity is the average of the two grcatest monthly Billing Demands
established during the l2-month perid which includes and ends with the cunent Billing Period, but not
less than 1,000 kW.
BILLING DEMAND
The Billing Demand is the average kW supplied during the 1S-consecutive-minute period of
maximum use during the Billing Period, adjusted br Power Factor, but not less than 1,000 kW.
ON-PEAI( BILLING DEMAND
The On-Peak Billing Elemand is the average kW supplied during the l5-mlnute period of
maximum use during the Billing Period forthe On-Peak time period.
TIME PERIODS
The time perbds are defined as 6lloirs. Alltimes are stated In Mountaln Time.
Summer Season
On-Peak:
Mid-Peak:
Off-Peak:
Non-summer Season
Mi&Peak:
Ofr-Peak:
1:fi) p.m. to 9:00 p.m. Mondaythrough Friday, except holidays
7:00 a.m. to 1:00 p.m. and 9:fi) p.m. to 1l:fi) p.m. Monday hrwgh
Friday, except holidays, and 7:00 a.m. to 11:00 p.m. Saturday and
Sunday, except holidays
11:00 p.m. to 7:00 a.m. Monday through Sunday and all hours on
holidays
7:00 a.m. to 11:00 p.m. Monday through Saturday, except holidays
11:00 p.m. to 7:00 a.m. Monday thro4gh Saturday and all hours on
Sunday and holidays
The holidays observed by the Gompany are New Yea/s Day, Memorhl Day, lndependence
Day, Labor Day, Thanksgiving Day, and Christmas Day. When New Yea/s Day, lndependence Day, or
Christmas Day falls on a Sunday, the Monday immediately following that Sunday will be considered a
holiday.
SUMMER AND NON.SUMMER SEASONS
The summer season begins on June 1 of each year and ends on August 31 of each year. The
non-summer season begins on September 1 of each year and ends on May 31 of each year.
IDAHO
lssued per Order No.30fl)8
Effective - March 1, 2008
lssued by IDAHO POWER COMPANY
John R. Gale, Vice President, Regulatory Affairs
1221 West ldaho Street, Boise, lD
SCHEDULE 19
LARGE POWER SERVICE
(Continued)
FACILITIES BryOND THE POINT OF DELIVERY
At the Customer's request and at the option of the Company, Oansbrmers and other facilities
installed beyond the Point of Delivery to prwide Pdmary or Transmisslon Service may be owned,
operated, and maintained by the Company in consideration of the Cusbmer paying a Facilites Charge
to the Company. This service is provitled under the prwisions set forth in Rule M, Facilities Charge
Service.
POWER FACTOR ADJ USTMENT
Where the Custome/s Pourer Factor is lees than 90 peroent, as determined by measurement
undr actual load conditions, the Company may adiust the kW measured b determine the Billing Demand
by multiplying the measured kW by 90 percent and dlvtsing by the actual Power Factor.
TEMPORARY SUSPENSION
When a Customer has properly invoked Rule G, Temporary Susoension of Demand, the Basic
Load Capacity, the Bitling Demand, and the OrrPeak Billing Demand shall be prcnated based on the
period of suctr suspension in aocordance wtth Rule G. ln the event the Custome/s metered demand is
lees than 1,000 kW during the period of such suspenslon, the Baslc Load Capacity and Billing Demand
wlll be set equal to 1,000 kW for purposes of determlnlng the Gusbme/s Monthly Charge.
MONTHLY CHARGE
The Monthly Charge is the sum of the folloMng drarges, and may also include cfiarges as set
brth in Schedule 55 (Power Cott Adjustment), Schedule 91 (Energy Efficiency Rider), and Scfiedule g5
(Adjustment br Munlclpal Franchise Fees).
SECONDARY SERVICE
ldaho PoryerCompany Trruenh Revised Sheet No. 1$3
Canels
|.P.U.C. No. 29. TariffNo. 101 Eleventh Revigod Sheet No. 1$3
IDAHO PUBUC UTluTlES COtmSSloilApprovod EflbcdveJuml,2022 Jwtc 1,20i8
PcrOl{ 35a23
Jen NodyrH Scctttery
Non*ummer
$s9.00
$0.93
$l.go
nla
4.74660
4.2171i,
Service Charge, per rnonth
Basic Charge, per kW of
Basic Load Capacity
Demand Charge, per kW of
Billing Demand
On-Peak Demand Charge, per kW of
On-Peak Billing Dernand
Energy Gharge, per kWh
On-Peak
Mld-Peak
Off-Peak
Summer
$3s.00
$0.93
$5.es
$1.03
6.4456S
5.1034'
4.5292i,
nla
IDAHO
lseued per Order No. 35423
Eftdive-June 1,2022
lssued by IDAHO POWER COMPANY
Timothy E. Tatum, Vice President, Regulatory Afiairc
1221 West ldaho Sbeet, Boise, ldaho
ldaho Powar Company Sixbenth Revised Sheet No. 19f
Cancels
|.P.U.C. No.29. TaffiNo. 101 Fifteenth Revised Sheet No. 19..4
SCHEDULE 19
LARGE POWER SERVICE
(Gontinued)
MONTHLY CHARGE (Continued)
PRIMARY SERVICE
|DAHO PUBUC tmLmES CommssloirApproved Efiscthrctutp7,Ni212 Junc 1,2022
PcrOll Sil2,l
Jan l{ofiukl Socrctary
Non-summer
$299.00
$1.28
$l.s+
nla
3.976sS
3.5550'
Non-eummer
$2ee.00
$o.zt
$4.41
n/a
3.9577Q,
3.53830
Service Gharge, per month
Basic Charge, per kW of
Basic Load Capaclty
Demand Charge, per kW of
Billing Demand
On-Peak Elsmand Charye, per kW of
On-Peak Bllllng Demand
Energy Charge, per kWh
On-Peak
Mid-Peak
Off-Peak
TRANSMISSION SERVICE
Servlce Gharge, per month
Basic Charge, per kW of
Basic Load Capacity
Elemand Charge, per kW of
Billing Demand
On-Peak Demand Charge, per kW of
On-Peak Billing Demand
Energy Charge, per kWh
On-Peak
Mid-Peak
Ofi-Peak
Summer
$299.00
01.28
$6.12
$0.e7
5.3049'
4.2185i
3.7639d
Summer
$299.00
So.zt
$s.gs
$0.s7
5.2U7$
4.188eS
3.73%l
n/a
n/a
PAYMENT
The monthly billfur service supplied hereunder ls payable upon receipt, and becomes past due
15 days from the date on which rendered.
IDAHO
lssued per Order No. 33423
Effec'tive - June 1,2022
lssued by IDAHO POWER COMPANY
Timothy E. Tatum, Vice President, Regulatory Afralrs
1221 West ldaho Street, Boise, ldaho
ldaho Porusr Company
|.P.U.C. No.29. Tadfi No. 101 OrhinalSheet No. 1$5
SCHEDULE 19
LARGE POA'ER SERVICE
(Continued)
IDAHO PUBLIC UflUnES COf,IlSSlOltlApprorcd EfioctlvcFcb.25,20ll Feb.25,2llll
PorO.l{.320E2
Jcen D. Jewrll Secrctary
INTEREST
Dellnltlonr
Additional Schedule 19 Aoolicant ls a Sciedule 19 Customer wfiose Application requires the
Company to provide new or relocated service from Substation Facilities senod by an exlstng secillon of
Transmlssion Facllities with a Tnansmisdon Vested lntersst.
Aoollcant is a Schedule 19 Customer wlrose Application requircs the Company to provlde new
or relocated servbe from Substation Facilities served by Transmisslon Facllitles that are ftee and clear
of any Tmnsmission Vested lnterest.
Aoolication is a request by an Applicant or Additiona! Schedule 19 Applicant for new elecilric
service from the Company.
Connec'ted Load is the total nameplats blW rating of the elecfric loads connec'ted br Sctedule
19 service.
DistiMion Facilities indude stsuctures, wires, lnsulators, and related equipment that ars
operated at a 34.5 kilovolt or louer rating.
Substation Allowancs is the portlon of the co6t of the Substation Facilities funded by the
Company.
Substration Facilities indude those fadlities and related equipment that transform the voltage of
en€rgy from a 44 kilovolt or highe rating to a 34.5 kilorrolt or loupr rating.
Transmlssion Facilities lndude structurss, wir€s, insulatoe, and rehted equlpment that are
operated at a 4,4 kilovolt or higher rating.
Transmission Llne lnstallation is any installation of new Transmission Facllfties owned by the
Company.
Transmission Line lnstallation Charoe is the partially refundaUe charge assess€d an Applicant
or Additional Schedule 19 Applicant whenever a Transmission Line lnshllation is bullt for that
individual.
Transmission Vested lnterest is the right to a rslUnd that an Applicant or Additional Schedule 19
Applicant holds ln a spedflc sedion of Transmiseion Facilitbs when Additional Scfiedule 19 Appllcants
attach to that section of Tnansmission Facilities.
Transmlsslon Vested lnterest Charoe is an amount collec'ted fiom an Additional Schedule 19
Applicant fior rsfund to a Tnansmission Vested lnterest Hdder.
Transmission Vested lntorost Holder is a person or entity that has pald a rsfundable
Transmlsslon Llne lnstrallation Charge to the Companyfor a Tranemission Line lnstallation.
IDAHO
lssued per Order No.32982
Effective - February 25,2014
lssued by IDAHO POWER COMPAIIY
GregoryW. Said, Vice President, Regulabry Affairs
1221 Weot ldaho Strset, Boise, ldaho
ldaho Porver Company Eighth Revised Sheet No. 19{
Cancols
!.P.U.C. i.|o.29. Tarilf No. 101 Seventh Revised Sheet No. 19{
IDAHO PUBUC UNLlTlEs COTTIEST'ilApproved EflbcflveXar.15,202i1 tar. 112022
PcrOt{ 35Eas
Jan ilorlyrkl Sccr*sySCHEDULE 19
LARGE POWER SERVICE
(Continued)
SPECIAL ARRANGEMENTS FOR SUBSTATION ALLOWA].ICES AND/OR TRANSMISSION VESTED
INTEREST (Continued)
Dsllnltlonr (Contnued)
Transmisslon Vestsd lnterost Portion is that part of the Company's bansmission system in which
a Transmission Vested lntersst is held.
lf a Schedule 19 Custome/s request for seMce requires the installation of new or upgraded
transformer capadty In Substation Facilities, the following considerafions wlll be lnduded ln the separate
agreement betrveen the Customer and the Company:
The Customer will lnltlally pay for the cost of new or upgraded Substation Facilities
requircd because of the Cusbme/s request. The Customerwlll be eliglble b recelve a one-time
Substation Allowance based upon subsequent sustained usage of capacity by the Customer.
a. Substiation Allorvance: The maximum posslble allouvance will be
determined by multlplylng the Custome/e actua! increase in load by $57,840 per illW, but
will not exceed the actual cost of the Substration Facilities.
b. Substatlon Allwance Refunds: The Substatlon Allowance wlll be rcfunded
to the Customer over a five-year period, with annual paymentrs based on the Custome/s
Basic Load Capacrty at he time of rcfund. The first rsfund will b€ paid one year bllorting
the first month energy is delivered through the new Substation Facilities.
The refunds will occur based on the follouring adjustment, which will b6
added to the Substatlon Allorvance received In the prevlous year. lf thete ls no
change in load fiom the previors year, the Substation Allowance br that year Is
equalto the Substation Allmrance ftom the provious year:
(Chang6 ln load fom the previous yeEr a msasurEd h MW) x (Subrffim Albtrane per MVU)
Numbe of Substatm Allowance Rsftrnds unalning ln fivu-yer pedod
The Custome/s annual rcfunds will be made in acoordance wtth the
Substation Allorance amount stated ln the separate constnrc{lon agrcement
between the Customer and the Company.
Trenrmlsdon Vested lnterprt
lf a Schedule 19 Custome/s rsquest for seMce requires the installation of now or upgraded
capaclty in Transmission Facillties, and those Transmission Facilities artr serving the Customer by a
radial feed, the bllowing consideratlons wlll be Induded in the sepanate agreement between the
Customer and the Gompany:
IDAHO
lssued per Order No. 35345
Effective - March 15,2022
lssued by IDAHO POWER COMPAI{Y
Timothy E. Tatum, Vice President, RegulatoryAfiairs
1221 West ldaho Strest, Boise, ldaho
ldaho PwerCompany
!.P.U.C. No.29. TariffNo. 101 OtuinalSheet No. 197
SCHEDULE 19
LARGE POA'ER SERVICE
(Contlnued)
SPECIAL ARRANGEMENTS FOR SUBSTATION ALLOWAI.ICES AND/OR TRANSMISSION VESTED
INTEREST (Continued)
Transmlrslon Vestod lntercst (Continued)
The Customer will initially pay for the cost of nerv or upgraded Transmission Facilities required
because of the Custome/s request. The Cusbmer may be eligible to receive Transmi&rion Vested
lnterest Refunds in accordance with Sdredule 19.
Tranrml$lon Vestod lntercd Refunda
Transmlssion Vested lnterest Rdrnds will be paid by the Company and funded by the
Additional Schedule 19 Applicant's Transmission Vested lnterest Charge as calculated in
accordance s,tth Scfiedule 19. The initialApplicant wil! be eligible to receMe refunds up to 80
percent of their original consffucillon mt.
Transmission Vested lnterest RslUnd Limitationsa. Transmission Vested lnterest Refunds will be funded by no more than 4
Additiona! Schedule 19 Appllcantrs durlng the $year perbd following the
completion date of the Transmisslon Llne lnstallatbn.b. ln no circumstiance will refunds exceed 100 peroent of the relUndable portion of
any partfs cash payment to the Company.
Tranrmlrolon Veded lntersrt Gharger:
Additional Schedule 19 Applicants with a Connected Load of greater than I ltrlW who
connect to a Transmission Vested lntorest Portion of a Transmission Line lnstallation wlll pay a
Transmission Vested lntercst Gharge to bo refunded to the Tnansrnission Vested lnterest
Holder.
An Mditional Schedule 19 Appllcant will pay an amount detemined by this equation:
Transmission Vested lnterest Charge = A x B nfiers;
A = Load Ratio: Additional Schedule 19 Applicant's Connec{ed Load dMded by the sum
of AdditionalApplicant's Connected Load and Transmission Vested lnterest Holde/s
load.
E = Vested lnterest Holde/g un*efunded contribution
The Additbnal Schedule 19 Applicant has no Transmission Vested lnterest and the
Transmission Vested lnterest Holder remains the Transmlssion Vested lntErest Holder. The
Transmission Vested lnterest Holde/s Transmission Vestsd lnterest will be reduced by the
neupst Additional Schedule 19 Applicanfs payment.
The Transmission Vested lnterest Gharge wlll not exceed the sum of the Transmission Vesbd
lnteresB in the Transmlssion Line lnstallation. !f an Additional Schedule 19 Applicant connects to a
portlon of a vested Transmisslon Line lnstrallaUon whlch was establlshed under a prior rule or schedule,
the Transmission Vested lnterest Charges of the previous rule or echedule apply to the Additional
Schedule 19 Applicant.
TDAHO PUBUC UTTUTTES Cotf,lssrol{Apfrowd EfbcthloFeb.25,201{ Feb.25,20ltl
PcrO.N.32982
Jcen D. Jmell Sccratary
IDAHO
lssued per Order No. 32982
Efiective - February 25, 2014
lssued by IDAHO POWER COMPANY
Gregory W. Said, Vice President, Regulatory Affairs
1221Wep;l ldaho Street, Boise, ldaho