20230329IPC Answer.pdf

MEGAN GOICOECHEA ALLEN
Corporate Counsel
mgoicoecheaallenidahopower.com
March 29, 2023
VIA ELECTRONIC FILING
Jan Noriyuki, Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg 8,
Suite 201-A (83714)
PO Box 83720
Boise, Idaho 83720-0074
Re: Case No. IPC-E-23-06
Thain Cashmore vs. Idaho Power Company
Dear Ms. Noriyuki:
Enclosed for electronic filing please find Idaho Power Company’s Answer in the
above matter.
If you have any questions about the attached documents, please do not hesitate
to contact me.
Sincerely,
Megan Goicoechea Allen
MGA:sg
Enclosures
RECEIVED
2023 March, 29 4:19PM
IDAHO PUBLIC
UTILITIES COMMISSION
IDAHO POWER COMPANY’S ANSWER- 1
MEGAN GOICOECHEA ALLEN (ISB No. 7623)
LISA D. NORDSTROM (ISB No. 5733)
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
Attorneys for Idaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
THAIN CASHMORE,
Complainants,
vs.
IDAHO POWER COMPANY,
Respondent.
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Case No. IPC-E-23-06
IDAHO POWER COMPANY’S
ANSWER
COMES NOW, Idaho Power Company (“Respondent”, “Idaho Power” or
“Company”), and pursuant to Procedural Rule 57, now answers the Summons of the
Idaho Public Utilities Commission (“Commission”) dated March 8, 2023, concerning the
formal Complaint (“Complaint”) of Thain and Cathy Cashmore (“Complainants” or
“Cashmores”).
The Complainants seek review of, and relief from, Idaho Power’s application of the
criteria established by the Commission for legacy status, or grandfathering, for residential
customers with on-site generation. For the reasons set forth herein, Idaho Power
IDAHO POWER COMPANY’S ANSWER- 2
respectfully requests the Commission issue an Order denying the Complainants’
requested relief. The Company correctly determined that the Complainants’ solar
expansion was not eligible for legacy status because they did not satisfy the requirements
established by the Commission. Idaho Power has applied the criteria established by
Commission Order and does not believe a Commission-authorized exception is
warranted based on the facts of this case.
I. REQUIREMENTS TO PERFECT LEGACY STATUS
1. Idaho Power customers who install on-site generation can interconnect an
exporting system under the terms of Schedule 6, Residential Service On-Site Generation
("Schedule 6"), Schedule 8, Small General Service On-Site Generation ("Schedule 8"),
or Schedule 84, which is the tariff schedule for the Company’s commercial, industrial,
and irrigation (“C&I”) customers to take net metering service.
2. The Commission previously found that when a customer-generator made a
significant investment in an on-site system based on reasonable reliance of program
stability, it was fair, just, and reasonable, non-discriminatory, and in the public interest to
allow them to recoup the value of their investments over the anticipated life of their
investments.1
3. In a line of cases starting with Case No. IPC-18-15, the Commission began
to establish parameters for distinguishing between existing and new customers based on
the customers’ reasonable expectations when making significant personal investments in
on-site generation systems.2 In Order No. 34509 issued on December 20, 2019, the
Commission stated that, prior to that date, customers could have reasonably believed
1 In the Matter of the Petition of Idaho Power Company to Study the Costs, Benefits, and Compensation
of Net Excess Energy Supplied by Customer On-Site Generation, Case No. IPC-E-18-15, Order No.
34509 at 10 (Dec. 20, 2019).
2 Id.
IDAHO POWER COMPANY’S ANSWER- 3
that net-metering program fundamentals would remain the same and made decisions to
invest in on-site generation systems in reliance on that belief. With that pronouncement,
however, the Commission established a firm cut-off for the reasonableness of this
assumption: “After the issuance of this Order. . . we believe it will no longer be reasonable
for a customer to assume the net-metering program fundamentals will remain the same
over the expected payback period of their investment.”3
Specifics of Legacy Status
4. Finding reasonable differences between existing and new net-metering
customers based on the uncertainty that may have existed prior to the issuance of Order
No. 34509, the Commission “grandfathered” existing net-metering customers into
Schedule 6 or Schedule 8 as those schedules existed on the service date of Order No.
34509. The Commission defined an “existing” customer eligible for grandfathered or
legacy status under Schedule 6 and Schedule 8 as:
…a person or business who either has an on-site generation
system interconnected with Idaho Power’s system as of the
service date of this Order, or who has made binding financial
commitments to install an on-site generation system as of the
service date of this Order and who proceeds to
interconnect their system within one year of the service
date of this Order [December 20. 2019].4
5.The financial commitment required for legacy status could be an obligation
to a third-party installer or supplier. Additionally, if a person or business had made a
financial commitment as of December 20, 2019, but had not yet applied to Idaho Power,
that person or business was directed to apply to Idaho Power within thirty days of the
3 Id.
4 Id.at 14 (emphasis added).
IDAHO POWER COMPANY’S ANSWER- 4
Order, including receipts demonstrating that a financial commitment was made on or
before December 20, 2019.5
6. The Commission found it reasonable and just to provide legacy or
“grandfathered” status to the system, under the following criteria:
 A customer who moves into a property with a grandfathered net-metering
system gets to “inherit” the grandfathered status of the system;
 If a system is offline for more than six months, or is moved to another site, the
grandfathered status of the system is forfeited;
 To allow for the replacement of degraded or broken panels, the customer may
increase the capacity of the grandfathered system by no more than 10% of the
originally installed nameplate capacity, or 1 kW, whichever is greater; and
 Grandfathered status terminates December 20, 2045.6
7. The Commission also clarified that if a customer with a legacy system wants
to add generating capacity, it can do so without losing legacy status for the entire system
if the output for the system expansion can be metered separately.7
Customer Generation Interconnection
8. Schedule 68, Interconnections to Customer Distributed Energy Resources
(“Schedule 68”), sets forth the process for new customer generator systems and system
expansions to interconnect with the Company’s system, which starts with the customer’s
application and concludes with the successful completion of the Company’s on-site
inspection.8
9. Idaho Power’s standard business practice is to coordinate certain aspects
of the application process directly with the customer’s installer as identified on the
5 Id.
6 Id., Order No. 34546 at 9 (Feb. 5, 2020).
7 Id. at 11.
8 Schedule 68, Interconnections to Customer Distributed Energy Resources, Sheet No. 68-12.
IDAHO POWER COMPANY’S ANSWER- 5
customer generation application, as the installer is generally more familiar with the
application process. It is also typical for an installer to complete the necessary permitting
and inspection requirements for the project and to submit the System Verification Form
on behalf of the customer.
10. Upon receipt of an Approval to Proceed from Idaho Power, the
customer/installer is responsible for completing the system's installation and fulfilling all
applicable federal, state, and local inspection requirements.9 In addition, after installation
and following successful completion of a state or city electrical inspection, the
customer/installer must provide Idaho Power with a completed System Verification Form
detailing the specifications of all installed components of the completed system.10
11. Once all required documentation has been submitted, and the Company
has verified that all applicable federal, state, and local requirements have been met, the
Company will complete, barring conditions beyond the Company's control, an on-site
inspection within ten (10) business days for a system with a total nameplate capacity of
100 kilovolt-ampere (“kVA”) or less.11
12. Successful completion of Idaho Power’s on-site inspection constitutes the
conclusion of the application process. The customer will receive confirmation that the
application process has been completed.12
Perfection of Legacy Status
13. As of December 20, 2019, there were approximately 590 applications
potentially eligible for legacy status under Schedules 6 and 8 if proof of financial
9 Schedule 68, Interconnections to Customer Distributed Energy Resources Sheet No. 68-11.
10 Id.
11 Schedule 68, Interconnections to Customer Distributed Energy Resources Sheet No. 68-12.
12 Id.
IDAHO POWER COMPANY’S ANSWER- 6
commitment was provided and the interconnection process was completed by December
20, 2020.
14. As of December 20, 2020, approximately 430 of the 590 systems completed
the interconnection process and perfected legacy status.
15. As of December 20, 2020, approximately 160 of the 590 systems did not
perfect legacy status. These systems did not perfect legacy status for a variety of reasons:
inability to provide proof of financial commitment; lack of response after submitting the
customer generation application; election to not move forward with a particular project;
and/or inability to complete the interconnection process prior to the December 20, 2020
deadline. Some of these customers may experience inequitable treatment if the
Commission were to grant the relief requested by the Cashmores in this Complaint.13
II. FACTUAL BACKGROUND
Existing System and Application for System Expansion
16. Since 2016, the Complainants have taken net metering service under the
Company’s Commission-approved tariff schedule14 at 5169 West Yarrow Road in
Pocatello, Idaho. The original system at that location, a 28 panel, 7.98 kW solar
photovoltaic (“PV”) system, came online in June of 2016.
17. Idaho Power received a Customer Generation Application from the
Complainants on May 6, 2019, in which they requested approval to expand their solar PV
system through installation of 10 additional panels rated at 3.0 kW (Attachment 1). The
13 See, e.g., In the Matter of Randy Valley’s Formal Complaint Against Idaho Power Company
Concerning Grandfathering of Ten Solar Panels, Case No. IPC-E-21-34, Order No. 35253 at 6 (Dec. 9,
2021) (finding the Company appropriately enforced the Commission’s grandfathering requirements in
finding the complainant’s expanded system ineligible for legacy status based on his failure to complete
the interconnection process by December 20, 2020).
14 Pursuant to Order 34046 in Case No. IPC-E-17-13, as of June 1, 2018, residential customers with on-
site generation were moved from Schedule 84 to newly created Schedule 6.
IDAHO POWER COMPANY’S ANSWER- 7
customer listed CR Solar Installations (“CR Solar” or “Installer”) as the project contact on
the application and authorized Idaho Power to discuss the project with it.
18. Idaho Power sent the Complainants and CR Solar an Approval to Proceed
email on May 7, 2019 (Attachment 2), advising that the application for the 10-panel
system expansion had been approved and describing the next steps necessary to
complete interconnection including the following responsibilities of the customer and
Installer:
 Install the renewable generation system
 Pass the state/city electrical inspection
 Submit a System Verification Form to Idaho Power
The Approval to Proceed email also explained the application approval was good for one
year, cautioning that the application would expire if the interconnection of the system
expansion was not completed within one year, by May 6, 2020.15
19. Subsequently, on December 20, 2019, the Commission issued its Order
delineating the parameters of legacy status, “grandfathering” existing customers into
Schedule 6 or Schedule 8 as those Schedules existed on December 20, 2019.16 Existing
customers included those with on-site generation systems interconnected as of that date
as well as those that had made a binding financial commitment to install an on-site
generation system as of December 20, 2019, and that proceeded to interconnect within
one year (or by December 20, 2020).17
15 Schedule 68, Interconnections to Customer Distributed Energy Resources Sheet No. 68-8 states:
Applications that are not completed within one year of the initial Feasibility Review are considered
expired. Customers requesting connection or approval of expired applications are required to resubmit a
completed application form and $100 application fee and are subject to the full application process
described in Section 2.
16 Order No. 34509 at 14.
17 Id.
IDAHO POWER COMPANY’S ANSWER- 8
20. Idaho Power provided solar installers, including CR Solar, notice of
Commission Order No. 34509 on January 6, 2020 via email (Attachment 3 at 4-5).18
21. On January 7, 2020, Idaho Power called Complainants to discuss the
requirements outlined in the Commission’s Order and notified them that for the system
expansion to be eligible for legacy status, they would need to submit proof they had made
a binding financial commitment prior to December 20, 2019, and complete
interconnection of the system by December 20, 2020.
22. In addition to the telephone discussion with Complainants on January 7th,
Idaho Power sent a follow-up email to the Cashmores on January 9,2020, outlining the
requirements for legacy status eligibility, including the necessity of providing proof that
they had made a binding financial commitment by December 20, 2019, and the need to
finish the interconnection process a year from that date in order to be grandfathered
(Attachment 4).
23. Idaho Power sent another written notification on January 14, 2020, via email
to customers with pending Customer Generator Applications, including Complainants,
advising of the Commission’s Order in Case No. IPC-E-18-15 and again outlining the
requirements for legacy status eligibility, including the necessity of providing proof that
they had made a binding financial commitment by December 20, 2019, and the need to
finish the interconnection process a year from that date in order to be grandfathered
(Attachment 5).
24. On January 15, 2020, Idaho Power replied to an email from Complainants
providing examples of the types of documentation that would constitute proof of financial
18 The email from Idaho Power to solar installers was originally sent on Friday, January 3, 2020, but
resent on January 6th with updated hyperlinks.
IDAHO POWER COMPANY’S ANSWER- 9
commitment (Attachment 6 at 2-3). Subsequently, on January 20, 2020, the Cashmores
submitted documentation from Installer demonstrating they had made a binding financial
commitment relative to the expanded system, receipt of which was confirmed by Idaho
Power in an email dated January 21, 2020 (Attachment 6 at 1-2).
25. On January 31, 2020, Idaho Power sent email confirmation to a number of
customers, including Complainants, advising that it had timely received documentation
showing a financial commitment for their systems was made prior to December 20, 2019
(Attachment 7). The email further explained that in order to be eligible for grandfathering
per the Commission’s order, the systems “must also be installed and interconnected by
December 20, 2020,” and provided a link where the customer could access the technical
requirements and application process on Idaho Power's website.
Follow-Up Interconnection Communications
26. In the ensuing months, Idaho Power endeavored to follow the progress of
the Cashmores’ system expansion, attempting contact with Complainants and/or their
Installer on multiple occasions between May 2020 and December 2020. More specifically,
on May 15, 2020, Idaho Power sent an email to Installer requesting a status update
(Attachment 8); it did not receive a response.
27. On October 20, 2020, Idaho Power left phone messages for both
Complainants and Installer, and on that same day, also sent them an email (Attachment
9), which stated, in pertinent part:
IDAHO POWER COMPANY’S ANSWER- 10
In May 2019, we received an application to add an additional
10 panels (3 kW). We also received proof that a financial
commitment was made for this expansion prior to December
20, 2019. Under a PUC order, if the expansion is complete by
December 20, 2020, it will qualify for grandfathering too. If not,
the expansion must be metered separately to preserve the
grandfathered status of your original system.
28. Complainants responded to Idaho Power’s email on October 20, 2020, by
confirming that the additional panels had been installed (Attachment 10).
29. Having not yet received the System Verification Form, Idaho Power made
several attempts to call Installer, leaving phone messages on November 10th, November
13th, and November 18th. CR Solar did not respond to any of these messages.
30. On November 30, 2020, Idaho Power sent another email to the Cashmores
and Installer advising them again that the interconnection process for the system
expansion was incomplete and providing instructions on how to finish the process. The
Company also provided another reminder of the looming deadline: “If the expansion
interconnection process is complete by December 20, 2020, it too will qualify for
grandfathering. If it is not completed, the entire system could lose grandfathering
status.” (Attachment 10 (emphasis in original)). Idaho Power did not receive further
communication from Complainants or Installer prior to the December 20, 2020, deadline.
31. Figure 1 provides a summary of all communications from Idaho Power to
the Complainant and/or Installer from the time it provided notice that the application for
system expansion had been approved (May 7, 2019) until the deadline to complete the
interconnection process for legacy status (December 20, 2020).
IDAHO POWER COMPANY’S ANSWER- 11
Figure1
Idaho Power Communication and Outreach Log
May 7, 2019 –December 20, 2020
Date Type Topic Attachment
Communications with:
Complainants CR Solar
05/07/2019 Email Approval to Proceed Re:Customer
Generator Application
Attachment 2 
01/06/2020 Email IPUC Order Re: Legacy Status Attachment 3 
01/07/2020 Phone Financial Commitment & IPUC
Order Re: Legacy Status
N/A 
01/09/2020 Email IPUC Order Re: Legacy Status Attachment 4 
01/14/2020 Email IPUC Order Re: Legacy Status Attachment 5 
01/15/2020 Email Proof of Financial Commitment Attachment 6 
01/21/2020 Email Reply Re: Financial Commitment Attachment 6 
01/31/2021 Email Receipt of Proof of Financial
Commitment
Attachment 7 
05/15/2020 Email System Expansion Status Attachment 8 
10/20/2020 Phone
Message
System Expansion Legacy Status N/A 
10/20/2020 Email System Expansion Legacy Status Attachment 9 
11/10/2020 Phone
Message
System Verification Form N/A 
11/13/2020 Phone
Message
System Verification Form N/A 
11/18/2020 Phone
Message
System Verification Form N/A 
11/30/2020 Email Additional Action Needed System
Verification
Attachment 10 
32. Despite Idaho Power’s diligent and repeated efforts to ensure the
Cashmores completed the interconnection process before the December 20, 2020
grandfathering deadline passed, they did not do so. As a result, on December 22, 2020,
Idaho Power sent an email to the Cashmores and Installer advising them that the May 6,
2019, application for the system expansion had expired due to their failure to timely
complete the interconnection process (Attachment 11).
33. Subsequently, on December 30, 2020, CR Solar emailed the System
Verification Form to Idaho Power, which indicated that the final electrical inspection had
IDAHO POWER COMPANY’S ANSWER- 12
occurred on December 29, 202019 (Attachments 12 and 13). Idaho Power responded to
Installer the same day indicating that the project application had expired and resending
its December 22, 2020 email advising of the same (Attachment 14).
34. On January 6, 2021, Idaho Power spoke with CR Solar via telephone
explaining the requirement to separately meter the output of the system expansion or lose
legacy status and discussing the Company’s repeated efforts to communicate with
Installer and Complainants about the December 20, 2020 deadline. On January 7, 2021,
Idaho Power left a phone message for Complainants and also followed up with an email
to them and Installer that same day outlining the next steps (Attachment 3). More
specifically, Idaho Power explained that the Complainants could retain legacy status of
the existing system by having the 10-panel expansion separately metered, which would
require a new application and fee for the 10-panel expansion. As an alternative, Idaho
Power indicated that the expansion could be installed with the existing system, but that
legacy status would be forfeited (Attachment 3).
35. Idaho Power had another phone conversation with Complainants on
January 21, 2021, in which it again explained the requirements for legacy treatment
delineated by the Commission, reviewed the Company’s many efforts to communicate
the deadlines with both Complainants and Installer, and the options moving forward.
2021 Informal Complaint
36. Complainants submitted an informal complaint to the Commission on
January 21, 2021, regarding the loss of legacy treatment based on the system expansion.
On or about January 22, 2021, Complainants submitted a Customer Generator
19 But see ¶53, below, and Attachment 18 (permit records) indicating the final inspection was not
completed until January 22, 2021.
IDAHO POWER COMPANY’S ANSWER- 13
Application to Idaho Power to separately meter the additional panels to retain legacy
status of the original system (Attachment 15). In responding the Commission Staff
investigators inquiries regarding the informal complaint on January 29, 2021, Idaho Power
described the sequence of events and noted that the customer had recently requested to
have the expansion separately metered.
37. Subsequently, on May 26, 2021, Complainants sent an email to Idaho
Power advising that the 10 additional solar panels installed had “been isolated” to power
the backup battery system exclusively (Attachment 16). As a result, they indicated: “This
should resolve our appeal filed with the PUC and eliminate the need for a net meter on
the 2019 addition.” In response, Idaho Power asked Complainants to verify that they
wished to withdraw their January 2021 application to separately meter the panels, which
they confirmed (Attachment 16).
Legacy System Limit Exceeded
38. In January of 2023, a reverse rotation report run by Idaho Power signaled
that exports from the Cashmores’ solar PV system exceeded the approved size of that
system (7.98 kW) for the months of April, May, and June of 2022, which indicated an
unauthorized expansion of the system. As a result, Idaho Power sent correspondence to
Complainants on January 24, 2023, notifying the Cashmores of their system’s
exceedance, and advising them of the steps they needed to take to resolve the issue.
(Attachment 17). On January 26, 2023, Idaho Power also called and spoke with the
Cashmores about the situation. The Complainants verbally confirmed that the expansion
had been installed and was operational.
IDAHO POWER COMPANY’S ANSWER- 14
2023 Complaint
39. The Cashmores then submitted another complaint to the Commission on or
about February 9, 2023, and the Commission issued a Summons and Formal Complaint
against Idaho Power on March 8, 2023, in Case No. IPC-E-23-06. In their Complaint, the
Cashmores claim that their failure to complete the interconnection process for the system
expansion prior to the deadline to retain legacy status was due to the electrical inspector
delaying the final electrical inspection. As a result, they are requesting the Commission
grant legacy status to their entire system, including the system expansion. Notably, the
2023 Complaint was the first time the Company learned that Complainants were
attributing the failure to timely interconnect to the electrical inspector.
III. ANSWER
40. Idaho Power denies any allegation not specifically admitted and reserves the
right to supplement and/or amend its Answer if the Cashmores amend their Complaint,
respond to discovery requests, or if additional defenses are ascertained during the course
of discovery or otherwise.
A. Idaho Power Lacks Authority to Deviate from the Requirements for Legacy
Treatment Established by the Commission or from the On-Site Generation
Interconnection Rules Set forth in the Company’s Tariff.
41. Neither the Idaho Legislature nor the Commission has authorized the
Company to exercise discretion that deviates from prior Commission’s orders or the
Commission-approved tariff.
42. Idaho Power is required to follow the Commission’s prior orders as well as
the utility tariff on file with the Commission. This concept, known as the “filed rate
IDAHO POWER COMPANY’S ANSWER- 15
doctrine,” is a basic principle of utility regulation that states that a utility may charge only
the approved rates and charges it has on file with its regulatory body.
43. Together, Idaho Code §§ 61-313 and 61-315 codify the concepts that make
up the filed rate doctrine for the State of Idaho. Idaho Code § 61-313 provides, in pertinent
part, that no refund or remit of any rates or charges may be made, and no contract or
agreement extended except as specified by tariff and as are regularly and uniformly
extended to all corporations or persons. Similarly, Idaho Code § 61-315 codifies the
concept of non-discriminatory service and prohibits a utility from giving preferential
treatment to any customer or customer class over another.
44. A customer’s request to receive treatment that deviates from the tariff and/or
Commission precedent, such as the Cashmores’ request to deviate from the Commission
established requirements to maintain legacy status, implicates the “filed rate doctrine” and
authorizing such would defeat this non-discriminatory policy. The Company could not
excuse Complainants’ non-compliance with the Commission’s requirements for granting
legacy status as doing so would violate the Commission's directive establishing
December 20, 2020 as the deadline for completing the system interconnection to be
eligible for legacy status.20 In other words, regulatory compliance is an affirmative defense
to the Complaint.
B. The Company Correctly Applied the Requirements of Order Nos. 34509 and
34546 and the Company’s Tariff.
45. Contrary to the requirements of Rule of Procedure 54.03, the Complainants
did not refer to specific provisions of statute, rule, order, notice, tariff, or other controlling
20 Order Nos. 34509 and 34546.
IDAHO POWER COMPANY’S ANSWER- 16
law that the utility has violated.21
46. Idaho Power affirmatively defends that it followed the Commissions'
directives in Order Nos. 34509 and 34546 and correctly applied and enforced the
requirements for legacy treatment relative to the Cashmores’ system expansion as
established by the Commission. Idaho Power has consistently applied these criteria for
all eligible customers.22
47. Having failed to meet the requirements for legacy status for their solar
system expansion, Idaho Power appropriately provided Complainants with the following
options pursuant to Commission’s Order No. 34546: (1) Separately meter the 10-panel
expansion and retain the legacy status of the existing system; or (2) Forfeit grandfather
status of the entire system and complete interconnection of the expansion behind the
existing meter.23
48. In addition, after becoming aware of the Cashmores’ unauthorized
installation in 2023, Idaho Power provided them the following two options pursuant to
Schedule 68: disconnect immediately and complete the full interconnection process after
which the system could be reenergized or permanently disable the installation from
parallel operations with the Company’s system. Idaho Power is required by law to follow
the rules of on-site generation interconnection set forth in Schedule 68, including treating
system modifications that have not completed the interconnection process as
unauthorized installations subject to immediate disconnection until the situation is
resolved. The tariff is unequivocal, and the Company followed it as written.
21 IDAPA 31.01.01.054.03.
22 See, e.g., In the Matter of Randy Valley’s Formal Complaint Against Idaho Power Company Concerning
Grandfathering of Ten Solar Panels, Case No. IPC-E-21-34.
23 Order No. 34546 at 11.
IDAHO POWER COMPANY’S ANSWER- 17
C. Extension of the Grandfather Period for the Cashmores’ Expanded Solar
Array Would be Inexpedient and Inequitable.
49. The Complainants have requested that their whole system, including the
10-panels added in 2019, be granted grandfather status.
50. The Cashmores had over a year and a half (from May 2019 to December
2020) to complete the interconnection process for the expansion, in order for both the
existing system and the 10-panel expansion to receive legacy status. They did not do so
despite Idaho Power’s repeated efforts to facilitate compliance.
51. Based on their failure to complete the interconnection process for their 10-
panel expansion prior to the December 20, 2020 cutoff, the Complainants were advised
that they could still retain grandfathering status of their original system by separately
metering the output of the expansion. Though the Complainants originally indicated they
would separately meter the output of the 10 additional panels, they later indicated that the
expansion they installed had been reconfigured as an off-grid system (one that does not
operate in parallel with the Company’s system and is therefore not subject to the
requirements of Schedule 68).24
52. Recently, Idaho Power discovered that Complainants’ on-site generation
system exports exceeded the approved capacity, indicating that the additional panels had
ultimately been connected to the original system (and interconnected to operate in parallel
with Idaho Power’s system) despite not having completed the interconnection process
mandated by Schedule 68. In a January 2023 phone call with Idaho Power, Complainants
verbally confirmed that the system expansion was interconnected and operational.
24 Schedule 68 applies to customer generators owning or operating distributed energy resources “in
Parallel with the Company’s system.” Schedule 68, Interconnections to Customer Distributed Energy
Resources Sheet No. 68-1.
IDAHO POWER COMPANY’S ANSWER- 18
53. After Complainants missed the deadline for legacy treatment of the system
expansion in December 2020, Idaho Power made clear that they would need to add a
separate meter for the 10 additional panels if they wanted to retain legacy status for the
original system.25 After originally pursuing this option, Complainants subsequently
advised Idaho Power that they did not want to move forward with installing another meter
and withdrew their January 2021 Customer Generator Application to separately meter the
additional panels.26 Their subsequent installation of the additional panels behind the
existing net meter connected in parallel with the Company’s system was done despite
having been advised that this was not an option if they wanted to retain legacy status for
the original system.27
54. Following Idaho Power’s notice to Complainants advising of their on-site
generation system’s non-compliance (Attachment 17), Complainants filed their Complaint
with the Commission arguing that their system expansion should be granted legacy
treatment despite not having completed the interconnection process by the December 20,
2020 deadline, attributing their failure to do so to delays caused by the electrical inspector.
To raise this as an issue at this time seems disingenuous in light of the timeline of events
and course of communications relative to the system expansion set forth in Section II,
above, and further, considering the discrepancies between the narrative in the Complaint
compared with the permit records.
25 This was communicated to Complainants by Idaho Power both verbally and in writing in January 2021,
including in response to their 2021 informal complaint. See ¶¶ 33-37, above.
26 See Attachment 15 (Cashmores’ January 2021 Customer Generation Application) and Attachment 16
(May-June 2021 email correspondence between Complainants and Idaho Power).
27 This was confirmed in a January 7, 2021 email from Idaho Power to Complainants and Installer, which
indicated that keeping the expansion with the original system would forfeit grandfathering for the entire
system; in a separate email to Installer Cashmore acknowledged: “Sounds like we don’t have a choice
but to meter the two systems separately.” See Attachment 3 at 2-4.
IDAHO POWER COMPANY’S ANSWER- 19
55. While Idaho Power was not privy to the interaction or communication
between the Cashmores, Installer, and the electrical inspector for the Idaho Division of
Building Safety (“DBS”), the records publicly available on the Idaho DBS online database
regarding the electrical permit for the Cashmores’ solar system expansion, Permit
Number WEB2010-05164,28 suggest a different sequence of events than those set forth
by Complainants. For example, the Complaint states that the request for an inspection
was originally made in April/May 2020, but the DBS Permit records indicate that the
original electrical permit plan was not submitted until October 29, 2020, and because the
documentation submitted at that time was determined by the examiner to be insufficient,
it was required to be resubmitted. The material was then resubmitted on November 12,
2020, but found again to be deficient, resulting in another resubmittal on November 30,
2020, that also failed to fully address the issues. Finally, on December 14, 2020, plans
were submitted that were approved with conditions on December 23, 2020. In addition,
while the Complaint indicates the final electrical inspection occurred on December 29,
2020, the DBS Permit records list it as occurring on January 22, 2021.
56. Further, an extension of the Cashmores’ legacy status would be prejudicial
to other customers with systems that lost legacy status due to similar circumstances.
Since the Commission set the criteria for systems to retain grandfather/legacy status, a
number of systems have failed to satisfy one or more of these requirements and lost
legacy status as a result. It would be inequitable to other customers who did not timely
perfect their claim to legacy status to give the Complainants additional time beyond that
28 Permit Search available here https://web.dbs.idaho.gov/etrakit3/Custom/Idaho_PermitSearch.aspx. For
ease of reference, copies and screenshots of pertinent permit materials obtained from the DBS Permit
Search are included as Attachment 18.
IDAHO POWER COMPANY’S ANSWER- 20
set by Order No. 34509.29 Idaho Power interprets Idaho Code § 61-315 as prohibiting the
preference that would result if more time were given for the Complainants to receive
legacy status for the requested 10-panel expansion.
IV. COMMUNICATIONS AND SERVICE OF PLEADINGS
57. Service of pleadings and communications with reference to this case should
be sent to the following:
Megan Goicoechea Allen
Lisa D. Nordstrom
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
[e-mail]
[e-mail]
[e-mail]
Connie Aschenbrenner
Grant Anderson
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
[e-mail]
[e-mail]
V. CONCLUSION
58. As illustrated in this Answer, the Company appropriately enforced the
requirements for grandfathering articulated by the Commission and is constrained under
Idaho law from taking action that is different than that currently permitted by Commission’s
orders and the Company’s Commission-approved tariff. Complainants failed to meet the
requirements for legacy status for their solar expansion despite the Company’s repeated
efforts to facilitate their compliance, and it would be inexpedient and inequitable to grant
Complainants additional time to perfect legacy status on its system expansion.
29 See In Re Complaint of Randy Valley, Case No. IPC-E-21-34, Order No. 35253 at 6 (on a similar fact
pattern, the Commission found that complainant failed to meet the requirements for legacy status, despite
repeated attempts by the Company to assist him with compliance and found there was no reasonable
basis to deviate from the requirements of Order Nos. 34509 and 34546).
IDAHO POWER COMPANY’S ANSWER- 21
59. Although the Complaint fails to state a claim against Idaho Power upon
which relief can be granted in this forum, this does not preclude Complainants from
enforcing legal rights, if any, they may have against their installer or others.
WHEREFORE, Idaho Power respectfully requests the Commission issue its Order
denying the relief sought by the Complainants.
DATED at Boise, Idaho, this 29th day of March 2023.
________________________________
MEGAN GOICOECHEA ALLEN
Attorney for Idaho Power Company
IDAHO POWER COMPANY’S ANSWER- 22
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 29th day of March 2023, I served a true and
correct copy of Idaho Power Company’s Answer upon the following named parties by the
method indicated below, and addressed to the following:
Commission Staff
Riley Newton
Deputy Attorney General
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg No. 8,
Suite 201-A (83714)
PO Box 83720
Boise, ID 83720-0074
Hand Delivered
U.S. Mail
Overnight Mail
FAX
_____ FTP Site
X Email: [e-mail]
Thain and Cathy Cashmore
5169 West Yarrow Road
Pocatello, Idaho 83201
Hand Delivered
U.S. Mail
Overnight Mail
FAX
_____ FTP Site
X Email: [e-mail]
________________________________
Stacy Gust, Regulatory Administrative
Assistant

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ATTACHMENT 1

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ATTACHMENT 2

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ATTACHMENT 3

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ATTACHMENT 4

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ATTACHMENT 5
From:VM_CG
To:VM_CG
Subject:Second Notice: Information about your Customer Generation Application
Date:Tuesday, January 14, 2020 12:14:00 PM
Hello,
We previously received your application to install an on-site generation system and interconnect toIdaho Power’s electrical system. We want to make you aware that under a recent order issued bythe Idaho Public Utilities Commission (IPUC), you need to take additional action promptly inorder to preserve certain potential benefits.
On December 20, 2019, the IPUC publicly issued an order in Case No. IPC-E-18-15, which providedthat customers like you who applied to interconnect on-site generation systems on or beforeDecember 20, 2019, but have not yet completed the interconnection process, must meet certaincriteria in order to remain eligible for the current net monthly kilowatt-hour credit compensationstructure (commonly referred to as a “1-to-1 offset”) for on-site generation. To remain eligible, youmust (1) provide to Idaho Power by January 19, 2020 evidence of a financial commitment to installan on-site generation system and (2) have the system installed by December 20, 2020.
Under the IPUC’s order, the financial commitment can be an obligation to a third-party installer orsupplier. To be eligible, you must submit receipts or a fully executed agreement demonstrating thata binding financial commitment was made on or prior to December 20, 2019. You may submitdocuments by responding to this email and attaching copies of your receipt(s) and/or agreement ormailing them to the address below. Please include your Idaho Power account number and serviceaddress as a reference when you are submitting the required documents.
If Idaho Power does not receive that information by January 19, 2020, or if the system is notinstalled by December 20, 2020, you will be subject to future changes in on-site generation tariffsand offering structure. Please note that those changes could profoundly affect items such as thecompensation structure for excess generation, and thus the economics of the purchase or lease ofan on-site generation system. For customers eligible for grandfathering under the currentcompensation structure, grandfathering will only apply to the customer at the meter site at theoriginally installed nameplate capacity of the system. Please note that, generally stated, this“grandfathering” does not apply to the rate structure and rates paid for consumption of electricpower.
For customers who do not meet the criteria to be grandfathered, please note that Idaho Power’s on-site generation tariffs, Schedules 6, 8, and 84, as with all tariffs, are not contracts and are subject tochange at any time upon order of the IPUC. Changes to the on-site generation tariff in the futuremay include, but are not limited to, modifications to rates, billing components, billing structure,compensation structures, and the value for excess energy produced by (and thus the amount acustomer would be compensated for) the customer’s on-site generation system.
The IPUC’s order is consistent with the Idaho Residential Energy System Disclosure Act, whichrequires a disclosure that reminds customers that legislative or regulatory actions can affect oreliminate one’s ability to sell or get credit for any excess power generated by the system and mayaffect the price or value of that power.
More information about customer generation, including compensation structure, technicalrequirements, and the application process can be found at idahopower.com/customergeneration.More information about the case and the order can be found at www.puc.idaho.gov.
If you have questions, about the on-site generation tariff and requirements, please contact theCustomer Care Team at 800-632-6605.
We appreciate the opportunity to serve you.
Sincerely,
Your Idaho Power Customer Generation [e-mail]
Idaho PowerAttn: Customer GenerationP.O. Box 70, Boise, ID 83707

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ATTACHMENT 6

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IDAHO POWER COMPANY

ATTACHMENT 7
From:VM_CG
To:VM_CG
Cc:VM_CG
Subject:On-Site Generation System Documentation
Date:Friday, January 31, 2020 9:32:00 AM
Hello,

Thank you for your timely submission of requested documentation. Under the Idaho Public Utilities
Commission Order 34509, if you made a binding financial commitment to install an on-site
generation system, such as solar panels, prior to or on December 20, 2019 you may be eligible to be
“grandfathered” under the current compensation structure for on-site generation. We have
received your documentation showing a financial commitment for your system was made prior to
December 20, 2019.

Per the commission’s order, to be eligible for grandfathering, systems must also be installed and
interconnected by December 20, 2020.

More information about customer generation, including compensation structure, technical
requirements, and the application process can be found at idahopower.com/customergeneration.
More information about the case and the order can be found at www.puc.idaho.gov.
If you have additional questions, you can call our Customer Care team at [phone] or send usan email at [e-mail].

Sincerely,

Your Idaho Power Customer Generation Team

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IDAHO POWER COMPANY

ATTACHMENT 8
From:Best, Patti
To:[e-mail]
Subject:Cashmore project
Date:Friday, May 15, 2020 10:27:00 AM
Hi. In May of 2019 we received an application for Cathy Cashmore, 5169 W Yarrow Rd in Pocatello.
Can you provide a status update?
Thanks.
Patti Best
Idaho Power

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IDAHO POWER COMPANY

ATTACHMENT 9
From:Best, Patti
To:[e-mail]
Cc:[e-mail]
Subject:Solar PV System
Date:Tuesday, October 20, 2020 9:07:00 AM
Hi Cathy,
I wanted to follow up with you about your application to expand your solar PV system, submitted in
May 2019.
Our records show a 7.9 kW 28 panel system was installed in 2016. This system is grandfathered
under the 1 to 1 kWh compensation structure.

In May 2019, we received an application to add an additional 10 panels (3 kW). We also received
proof that a financial commitment was made for this expansion prior to December 20, 2019. Under a
PUC order, if the expansion is complete by December 20, 2020, it will qualify for grandfathering too.
If not, the expansion must be metered separately to preserve the grandfathered status of your
original system.

I wanted to check with you on the status of this expansion.

Did you decide to move forward with it?

Thank you,
Patti Best
Idaho Power

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IDAHO PUBLIC UTILITIES COMMISSION

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IDAHO POWER COMPANY

ATTACHMENT 10
From:VM_CG
To:Catherine Cashmore
Cc:[e-mail]
Subject:Solar PV System Additional Action Needed
Date:Monday, November 30, 2020 12:08:00 PM
Hi Cathy,

I wanted to follow up with you again about your solar PV system. I am glad you got your system
installed. However, it has not yet finished our interconnection process. To complete the
interconnection process, we need a System Verification Form certifying the expansion meets all
codes and has passed the state/city electrical inspection. Here is a link to that form.
https://docs.idahopower.com/pdfs/BusinessToBusiness/CRR197.01.pdf

It looks like we did receive proof that a financial commitment was made for the system prior to
December 2019. If the expansion interconnection process is complete by December 20, 2020, it
too will qualify for grandfathering. If it is not completed, the entire system could lose
grandfathering status.

Please submit the System Verification form as soon as possible so that we may conduct our
inspection and complete the interconnection process.

Let us know if you have any questions.
Patti Best
Idaho Power

From: Catherine Cashmore <[e-mail]>
Sent: Tuesday, October 20, 2020 9:11 AM
To: Best, Patti <[e-mail]>
Subject: [EXTERNAL]Re: Solar PV System

KEEP IDAHO POWER SECURE! External emails may request information or contain malicious links or
attachments. Verify the sender before proceeding, and check for additional warning messages
below.
Hello,

Yes additional panels were installed.

Cathy

On Tue, Oct 20, 2020 at 9:07 AM Best, Patti <[e-mail]> wrote:
Hi Cathy,
I wanted to follow up with you about your application to expand your solar PV system, submitted
in May 2019.
Our records show a 7.9 kW 28 panel system was installed in 2016. This system is grandfathered
under the 1 to 1 kWh compensation structure.

In May 2019, we received an application to add an additional 10 panels (3 kW). We also received
proof that a financial commitment was made for this expansion prior to December 20, 2019.
Under a PUC order, if the expansion is complete by December 20, 2020, it will qualify for
grandfathering too. If not, the expansion must be metered separately to preserve the
grandfathered status of your original system.

I wanted to check with you on the status of this expansion.

Did you decide to move forward with it?

Thank you,
Patti Best
Idaho Power

IDAHO POWER LEGAL DISCLAIMER
This transmission may contain information that is privileged, confidential and/or
exempt from disclosure under applicable law. If you are not the intended recipient, you
are hereby notified that any disclosure, copying, distribution, or use of the information
contained herein (including any reliance thereon) is STRICTLY PROHIBITED. If you
received this transmission in error, please immediately contact the sender and destroy
the material in its entirety, whether in electronic or hard copy format. Thank you.

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ATTACHMENT 11
From:VM_CG
To:[e-mail]; [e-mail]
Cc:VM_CG
Subject:Expiration of Idaho Power Net Metering/Onsite Generation application for ID 889
Date:Tuesday, December 22, 2020 6:47:44 AM
Cathy A Cashmore,

On 5/6/2019, Idaho Power received an application to install an on-site generation system at 5169 W
Yarrow Rd. According to our records, that system has not been completed and the application is now
Interconnections to Non-Utility Generation:
Applications that are not completed within one year of the initial Feasibility
Review are considered expired. Customers requesting connection or approval of expired
applications are required to resubmit a completed application form and $100 application fee,
and are subject to the full application process.
The purpose of the Feasibility Review is to ensure the components of the electrical grid in your area can
handle the energy load of the proposed on-site generation system. In a 12-month period, much can
change to increase the demand on the electrical grid, such as population growth or existing customers
using more of the system. A new feasibility review ensures the current demands of the electrical grid can
support an on-site generation system safely.
If you have any questions, you can reach us at 208-388-2559 or by email at [e-mail].
Sincerely,
Idaho Power
Customer Generation Team

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IDAHO POWER COMPANY

ATTACHMENT 12
1
Goicoechea Allen, Megan
From:Office Team <[e-mail]>
Sent:Wednesday, December 30, 2020 11:16 AM
To:VM_CG
Cc:[e-mail]
Subject:[EXTERNAL]Cashmore ID
Attachments:Cashmore SVF ID.pdf
KEEP IDAHO POWER SECURE! External emails may request information or contain malicious links or attachments. Verify 
the sender before proceeding, and check for additional warning messages below. 

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ATTACHMENT 13
Customer Generation System Verification Form
Solar PV Projects
Instructions:
This System Verification Form is required after the proposed onsite renewable generation system is installed and after successful
completion of a state or city electrical inspection. Idaho Power prefers that this form be completed by a licensed electrician, solar
installer, NABCEP certified individual or an engineer or other qualified persons as accepted by Idaho Power. In lieu of professional
certification, documentation may be required including cut sheets and/or invoices for installed components. If invoices are provided,
financial information is not required and can be excluded if desired.
For rates 01 & 07 (Residential and Small General Service): upon receipt, Idaho Power will conduct a site visit within 10 business days
to check for compliance with Schedule 72, Interconnections to Non-Utility Generation and change the meter. It is not necessary to
be present for this visit. For Rates 09, 19, and 24, Idaho Power will contact you to discuss next steps.
1. Project Information All Fields Required
Account Holder Account Number
Must be the customer/account holder on the Idaho Power account
Project Location: Meter Number
Address City, State Zip
Electrical Permit Number Final Electrical Inspection Completion Date
Are there any access issues to the meter (unsecured dogs, etc.)?______________________________________________________
2. Final Installation Information All Fields Required
Project Nameplate Capacity ___________kW DC ___________ kW AC  Single Phase  Three Phase
Maximum System Size: 25 kW AC Residential and Small General Service; 100 kW AC Large Commercial, Industrial, Irrigation
Solar: # of Modules_______ Watts/module (DC)_______

Inverter(s)
Nameplate Capacity (VA):________ Manufacturer_______________ Model #_____________ Voltage______
Nameplate Capacity (VA):________ Manufacturer_______________ Model #_____________ Voltage_____
Are inverters UL 1741 or IEEE1547 listed? Yes No If no, what protection type? _______________________________
3.Professional Certification All Fields Required
I, the undersigned, certify the above information is correct and the system meets the requirements of Idaho Schedule 72
Interconnections to Non-Utility Generation. I also certify that:
 System meets all required codes and has passed the city/state electrical inspection.
 System is operational, breaker and inverter are on. If applicable, the inverter is programmed.
 The AC disconnect is in the open or off position.
 Required placards are in place. If disconnect is more than 10 feet or not visible from the meter, permanent directions to the
disconnect have been placed next to the meter.
Name (Type or Print) Signature
Phone*(xxx) xxx-xxxx Email Date
I am: (check all that apply)  Electrician
 Engineer
 NABCEP certified
 Solar Company/Installer
 Other:
 If Other, documentation is included per instructions.
Once completed, please email or mail this form to: [e-mail]
U.S. Postal Idaho Power Company
Delivery: Attn: Customer Generation, CHQ 8
P.O. Box 70 Boise, ID 83707
(04/2020) CRR197.01
Express Idaho Power Company
Delivery Attn: Customer Generation, CHQ 8
1221 West Idaho Street Boise, ID 83702
Questions? Call 208-388-2559 or email
[e-mail]
Cathy Cashmore
5169 W. Yarrow Road Pocatello, ID 83201
WEB2010-05164 12/29/2020
NO
X
1 Enphase
801-888-2996
Thomas Simms
[e-mail] 12/29/2020
JKM 310Jinko Solar10310
IQ7
3.1 3.1
2403500
(04/2020) CRR000
Complete for multiple inverter models
Inverter Details
Manufacturer: Model #:
Total number of inverters: Inverter watt size (each):
Is inverter UL 1741 or IEEE 1547 listed?  Yes  No If no, what protection type?
Manufacturer: Model #:
Total number of inverters: Inverter watt size (each):
Is inverter UL 1741 or IEEE 1547 listed?  Yes  No If no, what protection type?
Manufacturer: Model #:
Total number of inverters: Inverter watt size (each):
Is inverter UL 1741 or IEEE 1547 listed?  Yes  No If no, what protection type?

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ATTACHMENT 14
From:VM_CG
To:Office Team; VM_CG
Cc:[e-mail]
Subject:RE: [EXTERNAL]Cashmore ID
Date:Wednesday, December 30, 2020 11:42:35 AM
Attachments:Expiration of Idaho Power Net MeteringOnsite Generation application for ID 889.msgimage002.jpg
Hello CR Solar,
Thank you for submitting the system verification form for this expansion project. This project
application expired on 12/20/2020 and you received an email on 12/22/2020 (attached)
This project will require a new application and $100 application fee. Once we receive that via mail,
we can proceed with the completion of this project.
If you have any other questions, please feel free to respond to this email.
Thanks
CG Team

From: Office Team <[e-mail]>
Sent: Wednesday, December 30, 2020 11:16 AM
To: LOC. CG <[e-mail]>
Cc: [e-mail]
Subject: [EXTERNAL]Cashmore ID

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attachments. Verify the sender before proceeding, and check for additional warning messages
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ATTACHMENT 15

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ATTACHMENT 16
From:Catherine Cashmore
To:Best, Patti
Subject:Re: [EXTERNAL]5169 W Yarrow Rd Additional Panels
Date:Wednesday, June 02, 2021 4:57:43 PM
KEEP IDAHO POWER SECURE! External emails may request information or contain
malicious links or attachments. Verify the sender before proceeding, and check for additionalwarning messages below.
Hi Patti,
Yes please withdraw the application dated January 21 2021 to separately meter the additionalpanels as long as this leaves the grandfathering of our additional panels intact.
Thanks,
Cathy
On Tue, Jun 1, 2021 at 3:29 PM Best, Patti <[e-mail]> wrote:
Hi Catherine,
Thank you for the update.
I’d like to confirm that you would like to withdraw the application submitted on January 21,2021 to separately meter these panels.
Please let us know.
Thank you
Patti Best
Idaho Power

From: Catherine Cashmore <[e-mail]> Sent: Wednesday, May 26, 2021 9:41 AMTo: Best, Patti <[e-mail]>; [e-mail]: [EXTERNAL]5169 W Yarrow Rd Additional Panels

KEEP IDAHO POWER SECURE! External emails may request information or contain
malicious links or attachments. Verify the sender before proceeding, and check for
additional warning messages below.
Hello,
The additional 10 solar panels installed at 5169 W Yarrow in June of 2019 have now beenisolated in order to power our backup battery system exclusively.

This should resolve our appeal filed with the PUC and eliminate the need for a net meter on
the 2019 addition.Please let us know if there is anything else that needs to be done.

Sincerely,

Thain and Catherine Cashmore
IDAHO POWER LEGAL DISCLAIMER
This transmission may contain information that is privileged, confidential and/or
exempt from disclosure under applicable law. If you are not the intended recipient, you
are hereby notified that any disclosure, copying, distribution, or use of the information
contained herein (including any reliance thereon) is STRICTLY PROHIBITED. If you
received this transmission in error, please immediately contact the sender and destroy
the material in its entirety, whether in electronic or hard copy format. Thank you.

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IDAHO POWER COMPANY

ATTACHMENT 17

1/24/2023
Cathy Cashmore
5169 W Yarrow Rd
Pocatello, ID 83201-9028

Subject: On-Site Generation: Exceedance of Nameplate Capacity / NMID: 889

Dear Cathy Cashmore,
We are writing about your Solar PV system located at 5169 W Yarrow Rd, Pocatello, ID.
In 2016, Idaho Power approved a 28 panel, 7.98 kW system for interconnection. The system
came online in June 2016. In 2019, Idaho Power received an application to expand that system.
The system expansion did not complete the interconnection process and it is our understanding
that those additional panels were reconfigured as an off-grid system. The system remains
approved at 28 panels and 7.98 kW.
A solar system size determines the maximum amount of power it can produce and push back to
the grid when the home has zero usage. In order for a solar system to export more than what it is
rated to produce (7.98 kw for your system) there must be additional generation (inverters and
modules) connected. In the months of April, May, and June of 2022, Idaho Power noted that the
on-site Solar generation system pushed excess generation to Idaho Power beyond the approved
nameplate capacity of 7.98 KW.

An exceedance of approved capacity indicates that system modifications have been made,
increasing the capacity of the system.

Under the rules for on-site generation (Schedule 68 Interconnections to Customer Distributed
Energy Resources), customer’s modifying existing systems must submit a new application and
complete the interconnection process. Modifications include additional solar panels, new
inverters and adding batteries. Modifications that have not completed the interconnection process
are considered unauthorized installations and expansions. These systems generate electricity and
can feed that electricity back onto the electrical grid. The rules for interconnection help ensure
the integrity of Idaho Power’s system and the safety of Idaho Power crews that are working in
the area.
We would like to work with you to get this situation remedied as soon as possible. Under the
terms of Schedule 68, unauthorized installations and expansions must be disconnected at the AC
disconnect or at the breaker until the situation is resolved. You have until January 26, 2024 to
either complete the interconnection process or permanently disable the unauthorized installation.
Failure to do so may result in termination of service.
Page 2 of 2
To interconnect the system, please complete the following steps:
1. Fill out a Customer Generation application and submit along with the $100 application
fee. Applications are available at www.idahopower.com/customergeneration Idaho Power
will review the application to ensure it is complete, and then conduct an engineering
review of the Idaho Power equipment servicing the property. You will receive
notification when the review is complete.
3. Assuming no upgrades are needed, ensure the installation complies with Schedule 68.
This tariff can be found at www.idahopower.com/customergeneration.
4. Pass a state electrical inspection of the installation.
5. Notify Idaho Power upon successful completion of the state electrical inspection by
submitting a System Verification Form. Idaho Power will then conduct a separate
inspection to ensure compliance with Schedules 68.
Please note: If additional panels, beyond the approved 28, have been connected in parallel, you
risk losing legacy (grandfathered ) status of the original system. If panels have been added, there
are two options:
• Retain legacy status by separately metering or removing the additional panels. If the
additional panels are separately metered, the original system will retain legacy status.
The additional panels will not receive legacy treatment. Information about setting up
a separate service can be found in the installation and testing requirements section of
our website at idahopower.com/customergeneration.
• Keep the additional panels behind the existing net meter and forfeit legacy status for
the original system.
As a reminder, please disconnect any modifications until you have completed the interconnection
process or they have been permanently removed.
The rules for onsite generation, including Schedule 68, the application forms and information
about separately metering systems can be found at idahopower.com/customergeneration. If you
have any questions, please do not hesitate to contact us at 208-388-2559. Sincerely,
Idaho Power Customer Generation Team

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IDAHO POWER COMPANY

ATTACHMENT 18
Print
Permit
Number
Permit
Type
Site
Address Site City Zip
Code
Site
Number
Applicant
Name
Owner
Name
Contractor
Name
Contractor
License #
Job
Value
Permit
Fee Status Issued
Date
Expiration
Date
WEB2010-
05164 ELECTRICAL
5169 W
YarrowRoad POCATELLO 83201 TMP286882
CRLIGHTING &
ELECTRIC
INC
Cathy
Cashmore
CRLIGHTING &
ELECTRIC
INC
C:035239 12400 284 FINALED 10/27/2020 1/22/2021



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Screenshots of Inspection Notes, Permit # WEB2010-05164
Obtained from Idaho Division of Building Safety Website, accessed Mar. 28, 2023
Permit Search available at: eTRAKiT (idaho.gov)