20240826Staff 85-105 to IPC (Redacted).pdf

RECEIVED
Monday, August 26, 2024 10.58.29 AM
IDAHO PUBLIC
UTILITIES COMMISSION
CHRIS BURDIN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 9810
Street Address for Express Mail:
11331 W CHINDEN BLVD, BLDG 8, SUITE 201-A
BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )
OF IDAHO POWER COMPANY TO ) CASE NO. IPC-E-24-07
INCREASE RATES FOR ELECTRIC )
SERVICE TO RECOVER COSTS )
ASSOCIATED WITH INCREMENTAL ) REDACTED TWELVTH
CAPITAL INVESTMENTS AND CERTAIN ) PRODUCTION REQUEST OF
ONGOING OPERATIONS AND ) THE COMMISSION STAFF TO
MAINTENANCE EXPENSES ) IDAHO POWER COMPANY
Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Chris Burdin, Deputy Attorney General, requests that Idaho Power Company ("Company")
provide the following documents and information as soon as possible, but no later than
MONDAY, SEPTEMBER 9, 2024.'
This Production Request is to be considered as continuing, and the Company is requested
to provide,by way of supplementary responses, additional documents that it, or any person
acting on its behalf, may later obtain that will augment the documents or information produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name,job title, and telephone number of
1 Staff is requesting an expedited response. If responding by this date will be problematic,please call Staff s
attorney at(208)334-0314.
TWELVTH PRODUCTION REQUEST
TO IDAHO POWER COMPANY 1 AUGUST 26, 2024

the person preparing the documents. Please also identify the name,job title, location, and
telephone number of the record holder.
In addition to the written copies provided as response to the requests, please provide all
Excel spreadsheets and electronic files with formulas intact and enabled.
REQUEST NO. 85: In reference to the Company's response to Staff Production
Request No. 3 1 b—Attachment 4, for the bid scorecard for the Engineering Design Oxbow
Hatchery Renovation Project,please provide a detailed explanation and evidence for each of the
criteria to arrive at a final score for each of the bids. Please also provide the price for each of the
bids.
REQUEST NO. 86: In reference to the Company's response to Staff Production
Request No. 31(b)(i) for construction inspection work of the Oxbow Hathery Renovation Project,
please provide the bid price information, bid scorecard, and criteria and any other documentation
for the three vendors the Company contacted directly to perform the work.
REQUEST NO. 87: In reference to the Company's response to Production Request No.
31(d)—Confidential Attachment 4—COs—Engineering Design, please explain why Change
Order#2 is for work contracted with for construction support when the
engineering design was originally assigned to . Additionally,
please provide a detailed breakdown (i.e. engineering staff rate and hours, subcontractors' work,
etc.) of the_ increase.
REQUEST NO. 88: In reference to the Company's response to Staff Production
Request No. 31(d)—Confidential Attachment 5 —COs—Construction for the Oxbow Hatchery
Renovation Project, please explain attributed to
the
), even though
TWELVTH PRODUCTION REQUEST
TO IDAHO POWER COMPANY 2 AUGUST 26, 2024

REQUEST NO. 89: In reference to the Company's response to Staff Production
Request No.31(d)- Confidential Attachment 6—COs—Construction Support for Construction
Support in the Oxbow Hatchery Project, please explain ) in
Change Order#2 and provide any additional information and documents to support the increase.
REQUEST NO. 90: In reference to the Company's response to Staff Production
Request No.3I(d)- Confidential Attachment 6—COs—Construction Support for the Oxbow
Hatchery Renovation Project,please explain the in Change Order#4 (i.e. RFI,
invoices, cost estimates from subconsultants, etc.) and provide any additional information and
documents to support the increase.
REQUEST NO. 91: In reference to the Company's response to Staff Production
Request No. 31(d)—Confidential Attachment 7—COs - Construction Inspection for the Oxbow
Hatchery Renovation Project,please justify the in cost in Change Order#1.
Please include any documentation showing a change in the Scope of Work and the incremental
cost from the original contract.
REQUEST NO. 92: In reference to the Company's response to Staff Production
Request No. 31(d)—Attachment I —WBS the total cost for the Oxbow Hatchery Renovation
Project is $25,506,884.63 and the cost of the remaining work is $3,807,331.62. However, in
Response to Production Request No. 3 Attachment 3 —Larkin Workpaper 3 —Incremental Plant
Determination, $26,209,352.45 is required for total projected closing. Please reconcile the
difference between the two amounts. Additionally, the total contract cost as shown in Response
to Production Request No. 31(d)—Confidential Attachments 4 through 7 is with
change orders, as shown in the below table. Please reconcile it with the total projected closing
cost reflected in Response to Production Request No. 3.
Categories Final Cost
TWELVTH PRODUCTION REQUEST
TO IDAHO POWER COMPANY 3 AUGUST 26, 2024

REQUEST NO. 93: Please provide the following information for the AFPR Controls
Modernization (AFPR140005)project referenced by Secondary Supplemental Response to
Production Request No. 5. Please include any available workpapers with formula intact. If any
of the information requested below cannot be provided or is not available, please explain why it
is not available or cannot be provided.
a. Please provide a detailed explanation for the need of the project including the analysis
justifying the need.
b. Please provide a list of all the potential alternatives the Company considered to fulfill
the need and explain why the project was selected among the alternatives supported
by the Company's economic analysis (costs and benefits) comparing them.
c. If a Request for Proposal ("REP") or Request for Quote ("RFQ") was submitted,
please provide the following information:
i. A copy of the RFP or RFQ that was submitted;
ii. A detailed explanation of the selection process including the scorecard and list
of the criteria used to select the project;
iii. The short-list bidder scorecard; and
iv. A copy of the winning bid.
d. Please provide the approved Initial Project Plan including the following:
i. Initial project scope;
ii. Initial project budget;
iii. Initial proposed schedule; and
iv. Evidence that the Initial Project Plan and budget were approved at the
appropriate level.
e. Please provide the following for the Baseline Construction Project Plan including the
following:
i. Baseline project scope;
ii. Baseline project budget broken down by Work-Breakdown Structure
("WBS");
iii. Baseline project schedule broken down by the WBS;
TWELVTH PRODUCTION REQUEST
TO IDAHO POWER COMPANY 4 AUGUST 26, 2024

iv. If the baseline construction project scope,budget, and/or schedule deviated
from the Initial Project Plan,please explain the differences, explain the reason
for the change, and provide evidence that the changes were approved at the
appropriate level;
V. Project status reports and action items; and
vi. Contractor change orders.
f. Please provide the following related to completion of the project:
i. Baseline construction budget-to-actual comparison by the WBS and by year;
ii. Baseline construction schedule-to-actual comparison by the WBS;
iii. For any budget-to-actual cost overages by major WBS category that is over
5%, please explain the reason for the differences and provide evidence that the
amount was approved at the appropriate level; and
iv. Please explain any deviations in schedule from the baseline construction
schedule.
REQUEST NO. 94: Please provide the following information for the HCPR Controls
Modernization—Unit 3, Unit 1, BOP, Unit 2 (HCPR190001)project referenced by
Secondary Supplemental Response to Production Request No. 5. Please include any
available workpapers with formula intact. If any of the information requested below cannot be
provided or is not available,please explain why it is not available or cannot be provided.
a. Please provide a detailed explanation for the need of the project including the analysis
justifying the need.
b. Please provide a list of all the potential alternatives the Company considered to fulfill
the need and explain why the project was selected among the alternatives supported
by the Company's economic analysis (costs and benefits) comparing them.
c. If a RFP or RFQ was submitted,please provide the following information:
i. A copy of the RFP or RFQ that was submitted;
ii. A detailed explanation of the selection process including the scorecard and list
of the criteria used to select the project;
iii. The short-list bidder scorecard; and
TWELVTH PRODUCTION REQUEST
TO IDAHO POWER COMPANY 5 AUGUST 26, 2024

iv. A copy of the winning bid.
d. Please provide the approved Initial Project Plan including the following:
i. Initial project scope;
ii. Initial project budget;
iii. Initial proposed schedule; and
iv. Evidence that the Initial Project Plan and budget were approved at the
appropriate level.
e. Please provide the following for the Baseline Construction Project Plan including the
following:
i. Baseline project scope;
ii. Baseline project budget broken down by the WBS;
iii. Baseline project schedule broken down by the WBS;
iv. If the baseline construction project scope,budget, and/or schedule deviated
from the Initial Project Plan,please explain the differences, explain the reason
for the change, and provide evidence that the changes were approved at the
appropriate level;
V. Project status reports and action items; and
vi. Contractor change orders.
f. Please provide the following related to completion of the project:
i. Baseline construction budget-to-actual comparison by the WBS and by year;
ii. Baseline construction schedule-to-actual comparison by the WBS;
iii. For any budget-to-actual cost overages by major WBS category that is over
5%, please explain the reason for the differences and provide evidence that the
amount was approved at the appropriate level; and
iv. Please explain any deviations in schedule from the baseline construction
schedule.
REQUEST NO. 95: Please provide the following information for the MLPR Units 1-2
AVR Upgrade (MLPR200001)project referenced by Secondary Supplemental Response to
Production Request No. 5. Please include any available workpapers with formula intact. If any
TWELVTH PRODUCTION REQUEST
TO IDAHO POWER COMPANY 6 AUGUST 26, 2024

of the information requested below cannot be provided or is not available, please explain why it
is not available or cannot be provided.
a. Please provide a detailed explanation for the need of the project including the analysis
justifying the need.
b. Please provide a list of all the potential alternatives the Company considered to fulfill
the need and explain why the project was selected among the alternatives supported
by the Company's economic analysis (costs and benefits) comparing them.
c. If a RFP or RFQ was submitted,please provide the following information:
i. A copy of the RFP or RFQ that was submitted;
ii. A detailed explanation of the selection process including the scorecard and list
of the criteria used to select the project;
iii. The short-list bidder scorecard; and
iv. A copy of the winning bid.
d. Please provide the approved Initial Project Plan including the following:
i. Initial project scope;
ii. Initial project budget;
iii. Initial proposed schedule; and
iv. Evidence that the Initial Project Plan and budget were approved at the
appropriate level.
e. Please provide the following for the Baseline Construction Project Plan including the
following:
i. Baseline project scope;
ii. Baseline project budget broken down by the WBS;
iii. Baseline project schedule broken down by the WBS;
iv. If the baseline construction project scope,budget, and/or schedule deviated
from the Initial Project Plan,please explain the differences, explain the reason
for the change, and provide evidence that the changes were approved at the
appropriate level;
V. Project status reports and action items; and
vi. Contractor change orders.
f. Please provide the following related to completion of the project:
TWELVTH PRODUCTION REQUEST
TO IDAHO POWER COMPANY 7 AUGUST 26, 2024

i. Baseline construction budget-to-actual comparison by the WBS and by year;
ii. Baseline construction schedule-to-actual comparison by the WBS;
iii. For any budget-to-actual cost overages by major WBS category that is over
5%, please explain the reason for the differences and provide evidence that the
amount was approved at the appropriate level; and
iv. Please explain any deviations in schedule from the baseline construction
schedule.
REQUEST NO. 96: Please provide the following information for the Grand View
Sprinkler Conversion Capital Early Implementation (CHQB190001)project referenced by
Secondary Supplemental Response to Production Request No. 5. Please include any
available workpapers with formula intact. If any of the information requested below cannot be
provided or is not available,please explain why it is not available or cannot be provided.
a. Please provide a detailed explanation for the need of the project including the analysis
justifying the need.
b. Please provide a list of all the potential alternatives the Company considered to fulfill
the need and explain why the project was selected among the alternatives supported
by the Company's economic analysis (costs and benefits) comparing them.
c. If a RFP or RFQ was submitted,please provide the following information:
i. A copy of the RFP or RFQ that was submitted;
ii. A detailed explanation of the selection process including the scorecard and list
of the criteria used to select the project;
iii. The short-list bidder scorecard; and
iv. A copy of the winning bid.
d. Please provide the approved Initial Project Plan including the following:
i. Initial project scope;
ii. Initial project budget;
iii. Initial proposed schedule; and
iv. Evidence that the Initial Project Plan and budget were approved at the
appropriate level.
TWELVTH PRODUCTION REQUEST
TO IDAHO POWER COMPANY 8 AUGUST 26, 2024

e. Please provide the following for the Baseline Construction Project Plan including the
following:
i. Baseline project scope;
ii. Baseline project budget broken down by the WBS;
iii. Baseline project schedule broken down by the WBS;
iv. If the baseline construction project scope,budget, and/or schedule deviated
from the Initial Project Plan,please explain the differences, explain the reason
for the change, and provide evidence that the changes were approved at the
appropriate level;
V. Project status reports and action items; and
vi. Contractor change orders.
f. Please provide the following related to completion of the project:
i. Baseline construction budget-to-actual comparison by the WBS and by year;
ii. Baseline construction schedule-to-actual comparison by the WBS;
iii. For any budget-to-actual cost overages by major WBS category that is over
5%, please explain the reason for the differences and provide evidence that the
amount was approved at the appropriate level; and
iv. Please explain any deviations in schedule from the baseline construction
schedule.
REQUEST NO. 97: Please provide the following information for the HCC Rockfall
Mitigation Program (OBSP180003)project referenced by Secondary Supplemental Response
to Production Request No. 5. Please include any available workpapers with formula intact. If
any of the information requested below cannot be provided or is not available, please explain
why it is not available or cannot be provided.
a. Please provide a detailed explanation for the need of the project including the analysis
justifying the need.
b. Please provide a list of all the potential alternatives the Company considered to fulfill
the need and explain why the project was selected among the alternatives supported
by the Company's economic analysis (costs and benefits) comparing them.
c. If a RFP or RFQ was submitted,please provide the following information:
TWELVTH PRODUCTION REQUEST
TO IDAHO POWER COMPANY 9 AUGUST 26, 2024

i. A copy of the RFP or RFQ that was submitted;
ii. A detailed explanation of the selection process including the scorecard and list
of the criteria used to select the project;
iii. The short-list bidder scorecard; and
iv. A copy of the winning bid.
d. Please provide the approved Initial Project Plan including the following:
i. Initial project scope;
ii. Initial project budget;
iii. Initial proposed schedule; and
iv. Evidence that the Initial Project Plan and budget were approved at the
appropriate level.
e. Please provide the following for the Baseline Construction Project Plan including the
following:
i. Baseline project scope;
ii. Baseline project budget broken down by the WBS;
iii. Baseline project schedule broken down by the WBS;
iv. If the baseline construction project scope,budget, and/or schedule deviated
from the Initial Project Plan,please explain the differences, explain the reason
for the change, and provide evidence that the changes were approved at the
appropriate level;
V. Project status reports and action items; and
vi. Contractor change orders.
f. Please provide the following related to completion of the project:
i. Baseline construction budget-to-actual comparison by the WBS and by year;
ii. Baseline construction schedule-to-actual comparison by the WBS;
iii. For any budget-to-actual cost overages by major WBS category that is over
5%, please explain the reason for the differences and provide evidence that the
amount was approved at the appropriate level; and
iv. Please explain any deviations in schedule from the baseline construction
schedule.
TWELVTH PRODUCTION REQUEST
TO IDAHO POWER COMPANY 10 AUGUST 26, 2024

REQUEST NO. 98: The Company's Second Supplemental Response to Staff
Production Request No. 5 lists the following Transmission project: "T404200001 - T404 LNDN
Convert Source From a Tap to a Loop Feed" for a total plant-in-service amount of$1,162,731.
Please provide the following information regarding this project:
a. Please provide an explanation of the need for the project including the analysis
justifying the need;
b. Please list all potential alternatives the Company considered and explain why the
Company selected this solution;
c. Please provide the approved Initial Project Plan including the following:
i. Initial project scope, including maps and/or drawings depicting the scope;
ii. Initial project budget;
iii. Initial proposed schedule; and
iv. Evidence that the plan and budget were approved at the appropriate level; and
d. Please provide a comparison of the actual expenditures to the budget, by budget line
item.
REQUEST NO. 99: The Company's Second Supplemental Response to Staff
Production Request No. 5 lists the following Transmission project: "LNDN190001 -ADD
138KV BREAKERS" for a total plant-in-service amount of$3,954,411. Please provide the
following information regarding this project:
a. Please provide an explanation of the need for the project including the analysis
justifying the need;
b. Please list all potential alternatives the Company considered and explain why the
Company selected this solution;
c. Please provide the approved Initial Project Plan including the following:
i. Initial project scope, including maps and/or drawings depicting the scope;
ii. Initial project budget;
iii. Initial proposed schedule; and
iv. Evidence that the plan and budget were approved at the appropriate level; and
TWELVTH PRODUCTION REQUEST
TO IDAHO POWER COMPANY 11 AUGUST 26, 2024

d. Please provide a comparison of the actual expenditures to the budget, by budget line
item.
REQUEST NO. 100: The Company's Second Supplemental Response to Staff
Production Request No. 5 lists the following Transmission project: "T409210001 - 10-YEAR
INSPECTION REPAIRS, BRADY-FREMONT-KINPORT" for a total plant-in-service amount
of$1,383,573. Please provide the following information regarding this project:
a. Please provide an explanation of the need for the project including the analysis
justifying the need;
b. Please list all potential alternatives the Company considered and explain why the
Company selected this solution;
c. Please provide the approved Initial Project Plan including the following:
i. Initial project scope, including maps and/or drawings depicting the scope;
ii. Initial project budget;
iii. Initial proposed schedule; and
iv. Evidence that the plan and budget were approved at the appropriate level; and
d. Please provide a comparison of the actual expenditures to the budget, by budget line
item.
REQUEST NO. 101: The Company's Second Supplemental Response to Staff
Production Request No. 5 lists the following Transmission project: "GINT240629 -
INTERCONNECT FOR 36 MW BESS AT HMWY" for a total plant-in-service amount of
$782,813. Please provide the following information regarding this project:
a. Please provide an explanation of the need for the project including the analysis
justifying the need;
b. Please list all potential alternatives the Company considered and explain why the
Company selected this solution;
c. Please provide the approved Initial Project Plan including the following:
i. Initial project scope, including maps and/or drawings depicting the scope;
ii. Initial project budget;
iii. Initial proposed schedule; and
TWELVTH PRODUCTION REQUEST
TO IDAHO POWER COMPANY 12 AUGUST 26, 2024

iv. Evidence that the plan and budget were approved at the appropriate level; and
d. Please provide a comparison of the actual expenditures to the budget, by budget line
item.
REQUEST NO. 102: The Company's Second Supplemental Response to Staff
Production Request No. 5 lists the following Transmission project: "T215210001 10-year
inspection repairs, Ontario-Weiser 69kV" for a total plant-in-service amount of$1,073,384.
Please provide the following information regarding this project:
a. Please provide an explanation of the need for the project including the analysis
justifying the need;
b. Please list all potential alternatives the Company considered and explain why the
Company selected this solution;
c. Please provide the approved Initial Project Plan including the following:
i. Initial project scope, including maps and/or drawings depicting the scope;
ii. Initial project budget;
iii. Initial proposed schedule; and
iv. Evidence that the plan and budget were approved at the appropriate level; and
d. Please provide a comparison of the actual expenditures to the budget, by budget line
item.
REQUEST NO. 103: The Company's response to Staff Production Request No. 20
included several attachments in which the total Transmission Line 423 project budget and
completion date is different from the costs and dates identified in Colburn's Direct at 6. Please
answer the following:
a. Please provide actual spend to date by year and total in-service expenditures by year
for this project.
b. Please explain if any of this project was recovered in the previous rate case. If so,
please provide the amount that was recovered.
c. Please identify the total cost of the project that the Company is seeking recovery of
this project in this rate case.
d. Please reconcile the project budget from the following:
i. Colburn Direct at 6: $15 million;
TWELVTH PRODUCTION REQUEST
TO IDAHO POWER COMPANY 13 AUGUST 26, 2024

ii. Response to Request No. 20(e) -Variance Notes: $29,150,509;
iii. Response to Request No. 20(e)—WBS: $29,323,195; and
iv. Response to Request No. 17(a)—Confidential Attachment 2
e. Please identify each component of the budget to include each winning RFP bids,
materials, AFUDC, etc. Additionally, please identify the updated costs of
construction, design, steel poles, labor, etc. from the latest Change Orders.
f. Please reconcile the following two expected project completion dates with Colbum's
testimony of October 2024:
i. Response to 20(e)—Attachment 1 WBS: 1/17/25; and
ii. Response to 20(c) - Confidential Attachment 12- Construction Winning Bid—
Schedule:_.
REQUEST NO. 104: The Company's response to Staff Production Request No. 21
included several attachments in which the total Transmission Line 902 project budget and
completion date is different from the costs and dates identified in Colbum's Direct at 9. Please
answer the following:
a. Please provide actual spend to date by year and total in-service expenditures by year
for this project in excel format.
b. Please explain if any of this project was recovered in the previous rate case. If so,
please provide the amount that was included as recovered.
c. Please identify the total cost that the Company is seeking recovery of this project in
this rate case.
d. Please reconcile the project budget from the following:
i. Colburn Direct at 9: $21.2 million;
ii. Response to Request No. 20(e) -Variance Notes: $20,514,727; and
iii. Response to Request No. 17(a) Confidential Attachment 2
e. Please identify each component of the budget to include each winning RFP bids,
materials, AFUDC, etc. Additionally, please identify the updated costs of
construction, design, steel poles, labor, etc. from the latest Change Orders.
f. Please reconcile the following two expected project completion dates with Colbum's
testimony of December 2024:
TWELVTH PRODUCTION REQUEST
TO IDAHO POWER COMPANY 14 AUGUST 26, 2024

i. Response to 20(e)—Attachment 1- WBS: 12/29/26; and
ii. Response to 20(c) - Confidential Attachment 6- Winning Bid—MPE
Construction Schedule:_
REQUEST NO. 105: Please provide copies of all invoices and other supporting
documentation, such as contracts, incentive requests, approvals, and calculations for the
expenses listed on "Capital Project Data Request June 2024 pt 2"(Confidential Attachment No.
1). Please also provide the following data in Excel format for each individual expense for the
projects:
a. Invoice date;
b. Invoice number;
c. Invoice amount; and
d. Invoice purpose(Services performed and/or materials purchased, etc.).
DATED at Boise, Idaho, this 261h day of August 2024.
uv4r
Chris Burdin
Deputy Attorney General
L\Utility\UMISC\PRDREQ\IPC-E-24-07 PR#12.doex
TWELVTH PRODUCTION REQUEST
TO IDAHO POWER COMPANY 15 AUGUST 26,2024

Confidential Attachment No. 1
Case No. IPC-E-24-07
Production Request No. 12
August 26, 2024

Confidential Attachment No. 1
Case No. IPC-E-24-07
Production Request No. 12
August 26, 2024

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS .LW DAY OF AUGUST 2024,
SERVED THE FOREGOING REDACTED TWELVTH PRODUCTION REQUEST OF
THE COMMISSION STAFF TO IDAHO POWER COMPANY, IN CASE NO. IPC-E-
24-07, BY E-MAILING A COPY THEREOF TO THE FOLLOWING:
LISA D. NORDSTROM TIMOTHY TATUM
DONOVAN E WALKER CONNIE ASCHENBRENNER
MEGAN GOICOECHEA ALLEN MATT LARKIN
IDAHO POWER COMPANY IDAHO POWER COMPANY
PO BOX 70 PO BOX 70
BOISE ID 83707-0070 BOISE ID 83707-0070
E-MAIL: Inordstromaidahopower.com E-MAIL: ttatum(i'tidahopower.com
dwalker c idahopower.com caschenbrenner a;idahopower.com
mgoicoecheaallen(ciidahopower.com mlarkin c idahopower.com
dockets sidahopower.com
ERIC L OLSEN LANCE KAUFMAN PhD
ECHO HAWK& OLSEN PLLC 2623 NW BLUEBELL PLACE
PO BOX 6119 CORVALLIS OR 97330
POCATELLO ID 83205 E-MAIL: lance(aacgisinsiaht.com
E-MAIL: elo�q,echolwN k.com
PETER J RICHARDSON DR DON READING
RICARDSON ADAMS PLLC 280 S SILVERWOOD WAY
515 N 27TH STREET EAGLE ID 83616
BOISE ID 83702 E-MAIL: dreadinglamindsprin .com
E-MAIL: peterLtrichardsonadams.com
MATTHEW NYKIEL BRAD HEUSINKVELD
ID CONSERVATION LEAGUE ID CONSERVATION LEAGUE
710 N 6TH STREET 710 N 6TH STREET
BOISE ID 83702 BOISE ID 83702
E-MAIL: matthew.nykielLgmail.coin E-MAIL:
heusinkveld(i,idahoconservation.org
PETER MEIER EMILY W MEDLYN
US DEPT OF ENERGY US DEPT OF ENERGY
1000 INDEPENDENCE AVE SW 1000 INDEPENDENCE AVE SW
WASHINGTON DC 20585 WASHINGTON DC 20585
E-MAIL: peter.mcicr a hd.due.ov E-MAIL: t niilv.medlvn((chy.doe.gov
CERTIFICATE OF SERVICE

JIM SWIER AUSTIN RUESCHHOFF
MICRON TECHNOLOGY INC THORVALD A NELSON
8000 S FEDERAL WAY AUSTIN W JENSEN
BOISE ID 83707 KRISTINE A.K. ROACH
E-MAIL: jswier(c micron.com HOLLAND &HART LLP
555 17TH ST STE 3200
DENVER CO 80202
E-MAIL: darueschhoE cc�thollandhart.com
tnelson uhollandhart.com
awicnsenLt,hol landhart.com
karoach,c hollandhart.com
acleeCc%hollandhart.com
[e-mail]
ED JEWELL STEVEN HUBBLE
DEPUTY CITY ATTORNEY BOISE CITY DEPT OF PUBLIC WORKS
BOISE CITY ATTORNEY'S PO BOX 500
PO BOX 500 BOISE ID 83701-0500
BOISE ID 83701-0500 E-MAIL: shubble!a;citvofboise.or�
E-MAIL: e*ewcIILtcityofboise.ora
boisecityattorney c citvofboise.ora
PATRICIA JORDAN, ECRETARY
CERTIFICATE OF SERVICE