20231101Request for Exemption.pdf

MEGAN GOICOECHEA ALLEN
Corporate Counsel
[e-mail]

LISA NORDSTROM
Lead Counsel
[e-mail]

October 31, 2023

Jan Noriyuki, Secretary
Idaho Public Utilities Commission
11331 W. Chinden Boulevard
Building 8, Suite 201-A
Boise, Idaho 83714

Re: Case No. IPC-E-07-02, Order No. 30274
Exemption from the Company’s Rule C Provisions Regarding Aggregating
Meter Reading

Dear Ms. Noriyuki:

Pursuant to Order No. 30274 in Case No. IPC-E-07-02, Idaho Power Company
("Company") hereby requests to add a customer to the list of customers exempt from Rule
C's aggregated meter reading provisions. As outlined in the abbreviated procedure
approved by the Idaho Public Utilities Commission ("Commission") in Order No. 30274, the
Company is providing the customer's name, city location, and an explanation of why
aggregation is appropriate for review prior to aggregating meter readings. In its order, the
Commission envisioned that the Commission Staff will notify the Commission if it has an
objection to the customer proposed for aggregation (Order No. 30274, p. 3).

The Commission recently approved a Special Contract for the Lamb Weston
manufacturing facility in American Falls in conjunction with expansion of its operations to
exceed 20,000 kilowatts of energy requirement.1 The expansion includes reconfiguration of
the customer’s site to include electric service to three buildings which will be served by three
feeders and three primary metering packages. In developing the Special Contract rates for
service to the American Falls facility, the load service was evaluated on a combined basis
for all three buildings served from a dedicated substation, and metering expense allocation
included the cost of three primary metering packages. This configuration is the most

1 In the Matter of Idaho Power Company’s Approval of Special Contract and Tariff Schedule 34 to Provide
Electric Service to Lamb Weston, Inc., Case No. IPC-E-23-18, Order No. 35929, issued September 21,
2023.
CASE NO. IPC-E-23-29
RECEIVED
Wednesday, November 1, 2023 11:38:38 AM
IDAHO PUBLIC
UTILITIES COMMISSION
Jan Noriyuki, Secretary
October 31, 2023
Page 2

economical to provide service and the aggregation will ensure the Customer is appropriately
billed for the services received.

While the customer has not yet exceeded 20MW, the Company respectfully requests a
response to this request for exemption at the Commission’s earliest convenience. If the
Lamb Weston facility in American Falls is granted an exemption, the Company will submit
an updated list of Customers exempt from Rule C's aggregated meter reading provisions to
the Commission.

If you have any questions regarding this filing, please contact Regulatory Consultant
Paul Goralski at [phone] or [e-mail].

Sincerely,

Megan Goicoechea Allen

MGA:sg

cc: Connie Aschenbrenner
Dave Spillett
Matthew Stucki
Lewis McKillop
Ashley Herrera
Megan Poshka