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HomeMy WebLinkAbout20240906IPC to Staff 69-73.pdf LISA D. NORDSTROM Lead Counsel lnordstrom@idahopower.com September 6, 2024 VIA ELECTRONIC FILING Commission 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-24-07 Application of Idaho Power Company for Authority to Increase Rates for Electric Service to Recover Costs Associated with Incremental Capital Investments and Certain Ongoing Operations and Maintenance Expenses Dear Commission Secretary: Attached for electronic filing, please find Idaho Power Company’s Response to the Tenth Production Request of the Commission Staff to Idaho Power Company. Due to the collectively voluminous confidential and non-confidential information provided in response to data requests in this case, the Company is posting the attachments to these requests to the secure FTP site to allow parties to view the requested information remotely unless otherwise noted in the response. Because certain attachments contain confidential information, the FTP site is divided between confidential and non-confidential information. The login information for the non-confidential portion of the FTP site has been provided to all parties that have intervened to date. The login information for the confidential portion of the FTP site will be provided to the parties that execute the Protective Agreement in this matter. If you have any questions about the attached filing, please do not hesitate to contact me. Very truly yours, Lisa D. Nordstrom LDN:sg Enclosures ' a1DA11> POWER . RECEIVED Friday, September 06, 2024 IDAHO PUBLIC UTILITIES COMMISSION CERTIFICATE OF ATTORNEY ASSERTION THAT INFORMATION CONTAINED IN AN IDAHO PUBLIC UTILITIES COMMISSION FILING IS PROTECTED FROM PUBLIC INSPECTION Case No. IPC-E-24-07 Idaho Power Company’s Application for Authority to Increase Rates for Electric Service to Recover Costs Associated with Incremental Capital Investments and Certain Ongoing Operations and Maintenance Expenses The undersigned attorney, in accordance with Commission Rules of Procedure 67, believes that some of the attachments to Request Nos. 69, 71, and 73 to Idaho Power Company’s Response to the Tenth Production Request of the Commission Staff dated September 6, 2024, contains information that Idaho Power Company and/or a third party claim are trade secrets or business records of a private enterprise required by law to be submitted to or inspected by a public agency as described in Idaho Code § 74-101, et seq., and/or § 48-801, et seq. As such, it is protected from public disclosure and exempt from public inspection, examination, or copying. DATED this 6th day of September 2024. LISA D. NORDSTROM Attorney for Idaho Power Company IDAHO POWER COMPANY’S RESPONSE TO THE TENTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER - 1 LISA D. NORDSTROM (ISB No. 5733) DONOVAN E. WALKER (ISB No. 5921) MEGAN GOICOECHEA ALLEN (ISB No. 7623) Idaho Power Company 1221 West Idaho Street (83702) P.O. Box 70 Boise, Idaho 83707 Telephone: (208) 388-5825 Facsimile: (208) 388-6936 lnordstrom@idahopower.com dwalker@idahopower.com mgoicoecheaallen@idahopower.com Attorneys for Idaho Power Company BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE APPLICATION OF IDAHO POWER COMPANY TO INCREASE RATES FOR ELECTRIC SERVICE TO RECOVER COSTS ASSOCIATED WITH INCREMENTAL CAPITAL INVESTMENTS AND CERTAIN ONGOING OPERATIONS AND MAINTENANCE EXPENSES. ) ) ) ) ) ) ) ) ) CASE NO. IPC-E-24-07 IDAHO POWER COMPANY’S RESPONSE TO THE TENTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMES NOW, Idaho Power Company (“Idaho Power” or “Company”), and in response to the Tenth Production Request of the Commission Staff (“Commission” or “Staff”) to Idaho Power Company dated August 16, 2024, herewith submits the following information: IDAHO POWER COMPANY’S RESPONSE TO THE TENTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER - 2 REQUEST FOR PRODUCTION NO. 69: Please provide an excel spreadsheet with formulas intact listing all buyer construction costs incurred to date for the Franklin BESS project. This information should include date, amount, purpose, and payee. RESPONSE TO REQUEST FOR PRODUCTION NO. 69: See the Response to Request for Production No. 69 – Confidential Attachment 1 for all Franklin BESS project charges incurred through July 31, 2024, including a description of the purpose of the charge. Note, the costs exclude Allowance for Funds Used During Construction (“AFUDC”) and overheads. The response to this Request is sponsored by Eric Hackett, Projects and Resource Development Director, Idaho Power Company. IDAHO POWER COMPANY’S RESPONSE TO THE TENTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER - 3 REQUEST FOR PRODUCTION NO. 70: Please provide a copy of the Interconnection Agreement for the Franklin BESS project. RESPONSE TO REQUEST FOR PRODUCTION NO. 70: Please see the Response to Request for Production No. 70 – Attachments 1 through 3 for a copy of the Large Generator Interconnection Agreement and subsequent amendments. The response to this Request is sponsored by Eric Hackett, Projects and Resource Development Director, Idaho Power Company. IDAHO POWER COMPANY’S RESPONSE TO THE TENTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER - 4 REQUEST FOR PRODUCTION NO. 71: Please provide the following for each of the BESS projects listed in Larkin workpaper 3 – incremental plant determination at 11. a. Please provide the AURORA long-term capacity expansion model results showing the cost-effectiveness of the Company’s BESS resource compared to the resource Staff used to establish the soft cap, as described in Hackett Direct at 13. b. Please provide the forecasted portfolio capacity positions for the life of each project at time of the associated CPCN filing. c. Please indicate if the system is stand-alone or if it is paired with a renewable generation facility. For any system paired with renewable generation, please explain if the BESS resource is connected in series or in parallel to the generation facility. d. Please provide the actual build capacity excluding any overbuild or augmentation. e. Please provide any overbuild capacity, associated costs, and describe if the overbuild costs were included in the resource bid. f. Please provide a timeline showing planned augmentation, associated cost, and the augmentation amount. g. Please indicate the battery technology type, the associated maximum depth-of- discharge specification, the amount of reserved capacity, the assumed degradation for each year of plant life, the rated number of discharge cycles per year, and the source for each of these metrics (i.e. Company assumption, manufacturer warranty, etc.) IDAHO POWER COMPANY’S RESPONSE TO THE TENTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER - 5 h. Please explain the effect that the additional overbuild capacity will have on battery degradation and maximum dispatch time. i. Please provide a total project cost breakdown showing total project budget, total current spend, amounts already being recovered, ITC amounts received, and total budget previously closed. Please separate these project costs by AFUDC, overhead, and customer contribution categories. RESPONSE TO REQUEST FOR PRODUCTION NO. 71: a. As described in the Direct Testimony of Mr. Hackett in Case No. IPC-E-23-05, for which the Commission granted a Certificate of Public Convenience and Necessity (“CPCN”) for the 60 megawatt (“MW”) Franklin BESS, the bids received in response to Idaho Power’s 2022 All Source Request for Proposals (“RFP”) for Peak Capacity and Energy Resources issued on December 30, 2021 (“2022 RFP”) were evaluated through a qualitative and quantitative evaluation and ranking process to ultimately determine the least-cost, least-risk resource necessary to fill the 2024 capacity deficiency. The long-term capacity expansion (“LTCE”) modeling was performed as part of the quantitative evaluation process, identifying those projects that would move to the final shortlist following the qualitative evaluation. Under the LTCE modeling approach, the levelized cost of capacity (“LCOC”) of the 17 eligible projects were input into AURORA as potential resource additions, along with their project specific operating characteristics. The LTCE model optimized these potential resource selections based on the performance of each resource within Idaho Power’s zone, optimizing for the cost function while meeting the Company’s IDAHO POWER COMPANY’S RESPONSE TO THE TENTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER - 6 identified capacity deficiency. The following presents the projects selected through the indicative AURORA modeling scenarios as least-cost, least-risk projects necessary for meeting the identified 2024 capacity deficiency: Rank Resource 1 100 MW Solar + 100 MW BESS 2 100 MW Solar + 60 MW BESS 3 150 MW Standalone BESS 4 52 MW Standalone BESS 5 46 MW Standalone BESS Note, following evaluation of the bids, it was revealed that the first ranked project had deliverability concerns for meeting the June 2024 commercial operation date and therefore did not move forward to the final shortlist. The most cost- effective project able to meet the commercial operation date of June 1, 2024, was the 100 MW solar photovoltaic (“PV”) facility combined with the 60 MW BESS, which is the 60 MW Franklin BESS discussed on page 13 of Mr. Hackett’s Direct Testimony in this proceeding. Staff’s analysis of the final short list projects only captured the unit price associated with the BESS, failing to account for the benefit associated with the low Power Purchase Agreement (“PPA”) costs, and utilized the unit cost of the fifth ranked project for the soft cap determination. However, as a resource addition, AURORA continually selected the combined solar PV and battery storage in the LTCE analysis, indicating the low solar PPA price is contributing to the value the project provides as compared to the other final short list projects. In addition to being a lower cost resource, when compared to standalone battery storage systems, the combined solar PV plus energy storage better meets the IDAHO POWER COMPANY’S RESPONSE TO THE TENTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER - 7 Company’s capacity needs, resulting in a higher Effective Load Carrying Capability than would exist as a standalone energy storage system. b. Following clarification from Commission Staff, please see the first slide in the Response to Request for Production No. 71 – Attachment 1 for the 2024 capacity changes since the capacity deficiency was identified in the 2021 Integrated Resource Plan, including the resource additions for which Idaho Power received a Certificate of Public Convenience and Necessity, the 60 MW Franklin BESS (which was combined with the 100 MW solar PV facility) and the 36 MW Hemingway BESS. The second slide presents the same information but shows the impact to the capacity deficiency if a standalone 60 MW BESS project replaced the combined 100 MW solar PV facility combined with a standalone 60 MW BESS. Finally, the third slide presents the change in the capacity deficiency if the standalone 60 MW BESS is replaced with a standalone 46 MW BESS, the resource Staff used to calculate the soft cap in Case No. IPC-E-23-05. As evidenced on slides two and three, the Company would still have a 2024 capacity deficiency absent the combined 100 MW solar PV facility combined with the 60 MW Franklin BESS. c. Please see below for a description of each project configuration:  The 60 MW Franklin BESS is connected to a 100 MW solar PV facility. The BESS and the solar facilities are connected on the generator side of the Point of Interconnection as described in the Generator Interconnection Agreement and are connected at 34.5-kilovolt (“kV”) alternating current (“AC”). The BESS can be charged by the solar PV facility or grid-charged, as necessary. IDAHO POWER COMPANY’S RESPONSE TO THE TENTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER - 8  The 36 MW Hemingway BESS is a stand-alone facility and is charged by the grid.  The 40 MW Black Mesa BESS is connected to a 40 MW solar PV facility. The BESS and the solar facilities are connected on the generator side of the Point of Interconnection as described in the Generator Interconnection Agreement and are connected at 34.5-kV AC. The BESS can be charged by the solar PV facility or grid-charged as necessary. d. The nameplate capacity of each BESS facility at the beginning of life are as follows, which is the actual build capacity excluding any overbuild or augmentation: Project Contract Capacity 60 MW Franklin BESS 60 MW 36 MW Hemingway BESS 36 MW 40 MW Black Mesa BESS 40 MW e. Battery cells degrade over time. For example, a 100 MW BESS installation with no overbuild will supply 100 MW to the system on day one; however, assuming a 3 percent degradation rate, that same 100 MW BESS will only supply 97 MW to the system after one year. The degradation rate varies and is a function of time and throughput, or megawatt-hours (“MWh”). To mitigate the degradation, additional battery segments are added. Most degradation mitigation plans the Company has observed through project submittals during the recent RFP processes include an overbuild with a plan to add battery segments in the future when capacity drops below the desired level. Note, BESS systems are often expressed in units of MWh. For example, a 4-hour 100 MW BESS would supply IDAHO POWER COMPANY’S RESPONSE TO THE TENTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER - 9 400 MWh in a cycle whereas a 100 MW BESS with a 20 percent overbuild would supply 480 MWhs. If one bidder overbuilds 25 percent and another has a 0 percent overbuild and their price per MW was equal excluding the overbuild, the cost of the project with the overbuild would be 25 percent higher than the project with no overbuild. The results would indicate the overbuild project is more costly. However, the project without the overbuild would need to add batteries during year one, year two, year three, and so on to mitigate degradation. Another approach to degradation mitigation is to enter into a battery augmentation agreement with the manufacturer of the battery cells. Under an augmentation agreement, the manufacturer might require the buyer to pay a fixed annual fee over the 20-year life of the project and the manufacturer would then add batteries as necessary to get back to the original agreed upon MW capacity. For project evaluation purposes and to ensure bids of varying overbuild sizes are comparable, the Company adjusts the overbuild back to zero for each project, and then adds annual augmentation costs through the life of the project. This puts projects with varying overbuild sizes on a comparable basis and assumes capacity output stays flat over the life of the project. The following summarizes the installed BESS capacity, including any overbuild and associated project costs:  60 MW Franklin BESS: the total installed MW AC measured after losses is 65.93 MW. The Company has included $125.47 million in total costs associated with the project in the request in this case. IDAHO POWER COMPANY’S RESPONSE TO THE TENTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER - 10  36 MW Hemingway BESS: the total installed MW AC measured after losses is 42.65 MW. Total project costs of $68.79 million have been included in Idaho Power’s request in this case.  40 MW Black Mesa BESS: the total installed MW AC measured after losses is 46.56 MW. Idaho Power estimates total project costs to be $58.98 million. f. Idaho Power has not entered into battery augmentation agreements, therefore potential planned augmentation for each project is unknown. The time, scale, and costs of any future augmentation will require analysis of then-current operational characteristics. Prior to making any determination related to expenditures associated with augmentation, the Company will review the current operational capacity of each project, future identified deficits, and costs compared to alternative resources. Augmentation is dependent on past usage including cycle counts, total MWh throughput, and longevity. Therefore, Idaho Power has eliminated prescriptive obligations on the Company to purchase future augmentation and has instead elected to analyze the future decision based on then-current operational and price characteristics. g. Each of the BESS facilities utilizes Lithium Iron Phosphate battery cells. The scope of work, technical specifications, and anticipated degradation for each project are included as Response to Request for Production No. 71 – Confidential Attachments 2 through 4. h. Battery cells within a BESS degrade over time and more rapidly in the first year of use. For example, a BESS installation providing 100 MWh will supply 100 MWh to the system on day one; however, assuming the below degradation IDAHO POWER COMPANY’S RESPONSE TO THE TENTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER - 11 curve, that same BESS installation will only supply 93 MWh to the system after one year. The degradation rate varies and is a function of time and throughput, or megawatt-hours. Year Beginning of Year MWhs Degradation MWhs End of Year MWhs 1 100 6.9 93.1 2 93.1 2.3 90.8 3 90.8 1.8 89.0 4 89.0 1.5 87.5 5 86.1 1.4 86.1 To mitigate the degradation, additional battery segments are added. By including additional battery segments at the beginning of life, Idaho Power can ensure reliable operation at full nameplate capacity for a minimum of 4 hours beyond the first year of operation before necessitating a decision to augment the BESS if the then-current capacity is below the nameplate contract capacity. If the BESS system is not cycled daily, the longevity and assurance of performing above the nameplate capacity beyond the performance guarantee is likely and thus deferral of future augmentation investments can occur. The overbuild is necessary as it provides for the most efficient plant balancing and cell utilization, extending the guaranteed performance of the entire system and ensuring the Company has the capacity necessary to meet customer demand. Absent overbuild, immediately upon the BESS being placed in service, Idaho Power would be placed in a resource deficit relative to the required capacity. Additional benefits exist by having capacity above the nameplate contract capacity at the beginning of life including the operational flexibility to discharge the nameplate capacity over a longer duration. As discussed, a IDAHO POWER COMPANY’S RESPONSE TO THE TENTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER - 12 BESS is often measured in total throughput, or MWh, thus a facility that has slightly more capacity could be discharged over a duration greater than four hours. The additional battery cells result in additional time the BESS can discharge at its nameplate capacity given operational needs. For example, a 100 MW capacity battery would typically discharge for four hours, or 400 MWh. However, the additional battery cells would allow for 4.5 hours of discharging, or 450 MWh. i. Please see the Response to Request for Production No. 71 – Confidential Attachment 5 for the cost data associated with each of the BESS. Investment Tax Credits (“ITCs”) are not earned until a project is placed in-service and the Company cannot realize a benefit until utilized on a tax return. For the battery storage projects, Idaho Power anticipates earning the 30 percent ITC. The response to this Request is sponsored by Eric Hackett, Projects and Resource Development Director, Idaho Power Company. IDAHO POWER COMPANY’S RESPONSE TO THE TENTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER - 13 REQUEST FOR PRODUCTION NO. 72: Paragraphs 31 and 32 of the Company's Application explain the method used to estimate the incremental costs of the hypothetical distribution line approved in the 2017 CPCN. Application at 12. Please explain the following: a. Please explain why the Company removed "most of the distribution poles," rather than all the poles; and b. Please explain why the Company added the following two items: i. The replacement of a portion of the existing wood poles with taller, steel poles; and ii. Distribution intersect poles. RESPONSE TO REQUEST FOR PRODUCTION NO. 72: a. In order to estimate the incremental costs associated with the modified distribution line configuration, a cost estimate was prepared of what the distribution costs would be if it were underbuilt on planned overhead transmission poles. As such, the primary costs are equipment such as cross-arms, insulators, conductor/wire, and distribution equipment such as transformers. As a result, very few distribution poles are required for an underbuilt distribution line. However, transmission line routing and pole placement are designed to minimize transmission poles, thus leaving potential gaps where distribution equipment may be required. In this scenario, a distribution “intersect” pole may be required (for example to install a transformer for a customer that is not otherwise able to be accommodated on the transmission pole). The modified distribution line configuration accounts for some intersect poles. IDAHO POWER COMPANY’S RESPONSE TO THE TENTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER - 14 b. Replacement of wood poles with taller, steel poles and the addition of intersect poles is described in part (a). Specifically, in an “all overhead” transmission line design with accommodations for distribution underbuild, the height of the conductor likely would have required some distribution intersect poles to accommodate equipment where applicable and the intersect poles are assumed to be taller steel poles compared to the existing overhead distribution. The response to this Request is sponsored by Mitch Colburn, Vice President of Planning, Engineering, and Construction, Idaho Power Company. IDAHO POWER COMPANY’S RESPONSE TO THE TENTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER - 15 REQUEST FOR PRODUCTION NO. 73: Please provide invoices for the sample selected in the confidential attachment titled "Jan-May Capital Project Invoice Sample". For selections not linked to specific invoices, please explain the accounting method used to determine the amount and provide calculations that determine the amount in Excel format. RESPONSE TO REQUEST FOR PRODUCTION NO. 73: Please see the Response to Request for Production No. 73 – Confidential Attachment 1 for the “Jan-May Capital Project Invoice Sample” file with an additional column providing a description of whether an invoice is available or a reference to the calculation and accounting method used. The Response to Request for Production No. 73 – Confidential Attachments 2 through 10 provide further support for either the invoice or the calculations and accounting method used, as referenced in the description included in the updated invoice sample file. The response to this Request is sponsored by Matt Larkin, Revenue Requirement Senior Manager, Idaho Power Company. IDAHO POWER COMPANY’S RESPONSE TO THE TENTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER - 16 DATED at Boise, Idaho, this 6th day of September 2024. LISA D. NORDSTROM Attorney for Idaho Power Company DONOVAN E. WALKER Attorney for Idaho Power Company MEGAN GOICOECHEA ALLEN Attorney for Idaho Power Company IDAHO POWER COMPANY’S RESPONSE TO THE TENTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER - 17 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 6th day of September 2024, I served a true and correct copy of Idaho Power Company’s Response to the Tenth Production Request of the Commission Staff to Idaho Power upon the following named parties by the method indicated below, and addressed to the following: Commission Staff Chris Burdin 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 Chris.Burdin@puc.idaho.gov Industrial Customers of Idaho Power Peter J. Richardson Richardson Adams, PLLC 515 N. 27th Street Boise, Idaho 83702 Hand Delivered U.S. Mail Overnight Mail FAX FTP Site X Email peter@richardsonadams.com Dr. Don Reading 280 Silverwood Way Eagle, Idaho 83616 Hand Delivered U.S. Mail Overnight Mail FAX FTP Site X Email dreading@mindspring.com Idaho Irrigation Pumpers Association, Inc. Eric L. Olsen ECHO HAWK & OLSEN, PLLC 505 Pershing Avenue, Suite 100 P.O. Box 6119 Pocatello, Idaho 83205 Hand Delivered U.S. Mail Overnight Mail FAX FTP Site X Email elo@echohawk.com Lance Kaufman, Ph.D. 2623 NW Bluebell Place Corvallis, OR 97330 Hand Delivered U.S. Mail Overnight Mail FAX FTP Site X Email lance@aegisinsight.com IDAHO POWER COMPANY’S RESPONSE TO THE TENTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER - 18 Idaho Conservation League Brad Heusinkveld 710 N. 6th Street Boise, Idaho 83702 Hand Delivered U.S. Mail Overnight Mail FAX FTP Site X Email bheusinkveld@idahoconservation.org Micron Technology, Inc. Austin Rueschhoff Thorvald A. Nelson Austin W. Jensen Kristine A.K. Roach Holland & Hart LLP 555 17th Street, Suite 3200 Denver, CO 80202 Hand Delivered U.S. Mail Overnight Mail FAX FTP Site X Email darueschhoff@hollandhart.com tnelson@hollandhart.com awjensen@hollandhart.com karoach@hollandhart.com aclee@hollandhart.com mamcmillen@hollandhart.com Jim Swier Micron Technology, Inc. 8000 South Federal Way Boise, ID 83707 Hand Delivered U.S. Mail Overnight Mail FAX FTP Site X Email jswier@micron.com City of Boise Ed Jewell Deputy City Attorney Boise City Attorney’s Office 150 N. Capitol Blvd. P.O. Box 500 Boise, Idaho 83701 Hand Delivered U.S. Mail Overnight Mail FAX FTP Site X Email BoiseCityAttorney@cityofboise.org ejewell@cityofboise.org IDAHO POWER COMPANY’S RESPONSE TO THE TENTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER - 19 Steven Hubble Boise City Dept. of Public Works 150 N. Capitol Blvd. P.O. Box 500 Boise, Idaho 83701-0500 Hand Delivered U.S. Mail Overnight Mail FAX FTP Site X Email shubble@cityofboise.org Federal Executive Agencies Peter Meier Emily W. Medlyn U.S. Department of Energy 1000 Independence Ave., S.W. Washington, DC 20585 Hand Delivered U.S. Mail Overnight Mail FAX FTP Site X Email peter.meier@hq.doe.gov emily.medlyn@hq.doe.gov Stacy Gust Regulatory Administrative Assistant ~ ~