Loading...
HomeMy WebLinkAbout20251118Direct Donn English .pdf RECEIVED November 18, 2025 IDAHO PUBLIC BEFORE THE UTILITIES COMMISSION IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF IDAHO POWER ) COMPANY'S APPLICATION FOR ) CASE NO. IPC-E-25-16 AUTHORITY TO INCREASE ITS ) RATES AND CHARGES FOR ) ELECTRIC SERVICE IN THE STATE ) OF IDAHO ) DIRECT TESTIMONY OF DONN ENGLISH IN SUPPORT OF THE STIPULATION AND SETTLEMENT IDAHO PUBLIC UTILITIES COMMISSION NOVEMBER 18, 2025 I Q. Please state your name and business address . 2 A. My name is Donn English. My business address is 3 11331 W. Chinden Blvd. , BLDG 8, STE 201-A, Boise, Idaho 4 83714 . 5 Q. By whom are you employed and in what capacity? 6 A. I am employed by the Idaho Public Utilities 7 Commission ("Commission") as the Deputy Division 8 Administrator overseeing the Utilities Division. 9 Q. Please describe your educational background and 10 professional experience . 11 A. I was hired by the Commission in 2003 and I have 12 provided testimony in numerous proceedings . My educational 13 background and professional experience are provided in more 14 detail in Exhibit No . 101 . 15 Q. What is the purpose of your testimony in this 16 proceeding? 17 A. The purpose of my testimony is to describe the 18 Application filed by Idaho Power Company ("Idaho Power" or 19 "Company") to increase its rates and charges for electric 20 service in Idaho and to implement certain measures to 21 mitigate the impact of regulatory lag, describe the 22 proposed comprehensive Stipulation and Settlement 23 ("Settlement") as it pertains to the stipulated revenue 24 requirement; and explain Staff' s support for the 25 settlement . Staff Witness Mike Louis, Engineering Program CASE NO. IPC-E-25-16 ENGLISH, D. (Stip) 1 11/18/25 STAFF 1 Manager, provides testimony in support of the stipulated 2 rate spread and the rationale behind the forthcoming cost 3 of service case docket as called for in the proposed 4 Settlement . Staff Witness Matt Seuss, Engineer, provides 5 testimony detailing the impact of new large load customers 6 on the stipulated revenue requirement . 7 Q. How is your testimony organized? 8 A. My testimony is subdivided under the following 9 headings : 10 Background Page 2 11 Staff Investigation Page 5 12 Settlement Evaluation Page 6 13 Settlement Overview Page 8 14 Background 15 Q. Please describe Idaho Power' s original filing. 16 A. Idaho Power filed its Application to increase 17 rates and charges for electric service in Idaho on May 30, 18 2025 . The Company requested authority to increase its 19 electric base revenue in Idaho by $199 . 1 million, or 20 13 . 090, with an anticipated effective date of January 1, 21 2026 . The Company' s requested increases were based on a 22 test period ending December 31, 2025, consisting of pro 23 forma adjustments through 2025 . Recovery of forecasted 24 capital additions through December 31, 2025, were included 25 in the Company' s proposed revenue requirement and CASE NO. IPC-E-25-16 ENGLISH, D. (Stip) 2 11/18/25 STAFF 1 calculated on an End-of-Period ("EOP") basis . 2 The Company proposed a capital structure 3 comprised of 51% equity and 49% debt, with a 10 . 4% return 4 on equity ("ROE") for an overall rate of return of 7 . 820 . 5 Additionally, the Company requested to increase 6 its monthly Service Charges . For residential customers, 7 the Company proposed to increase its Service Charge from 8 $15 . 00 per month to $25 . 00 per month for all residential 9 schedules . For Small General Service customers receiving 10 service under Schedules 7 and 8, the Company proposed to 11 increase the Service Charge from $25 . 00 per month to $30 . 00 12 per month. The Service Charge and/or Demand Charge 13 proposed for the other customer classes are detailed in 14 Exhibit No . 44 sponsored by Company Witness Grant Anderson. 15 For Schedule 1, standard residential service, 16 which includes seasonal inclining block Energy Charges, the 17 Company proposed to reduce the differentials between the 18 current tiered prices, but it did not propose to eliminate 19 tiered pricing entirely. The Company also proposed to 20 implement a bill protection program for residential 21 customers who begin taking service under Schedule 5, 22 residential time-of-use ("TOU") pricing option, effective 23 January 1, 2026 . The purpose of bill protection is to 24 reduce the financial uncertainty for customers 25 transitioning from Schedule 1 to Schedule 5 to encourage CASE NO. IPC-E-25-16 ENGLISH, D. (Stip) 3 11/18/25 STAFF 1 participation in the optional TOU pricing by ensuring 2 customers will not pay more than $10 above what they would 3 have paid under Schedule 1 for their first 12 months of 4 service on Schedule 5 . 5 Finally, the Company proposed to implement a 6 depreciation and interest expense tracking mechanism, and 7 to designate additional accumulated deferred investment tax 8 credits ("ADITC") as eligible for accelerated amortization 9 under the terms of the currently approved ADITC/Revenue 10 Sharing Mechanism, with the addition of a $75 million 11 annual amortization cap. 12 Q. How was this case processed after the Company' s 13 Application was received? 14 A. The Commission issued a combined Notice of 15 Application, Notice of Intervention Deadline, and Notice of 16 Suspension of Proposed Effective Date ("Notice") on June 17 13, 2025, establishing an Intervention Deadline of July 5, 18 2025 . Intervenor status was subsequently granted to the 19 City of Boise City ("Boise City") ; Clean Energy 20 Opportunities for Idaho ("CEO") ; the Federal Executive 21 Agencies ("FEA") ; John Gannon, Deborah Fease, Amy Lorrance, 22 and Rany Morris ("Gannon, et al . ") ; Idaho Irrigation 23 Pumpers Association, Inc. ("IIPA") ; IdaHydro; the 24 Industrial Customers of Idaho Power ("ICIP") ; The Kroger 25 Co . ("Kroger") ; Micron Technology, Inc. ("Micron") ; and the CASE NO. IPC-E-25-16 ENGLISH, D. (Stip) 4 11/18/25 STAFF 1 Northwest Energy Coalition ("NWEC") . These entities are 2 collectively referred to as the "Parties . " Settlement 3 negotiations were held on September 9, September 29, and 4 October 6, 2025 . All Parties were given an opportunity, 5 whether in person or virtually, to participate in or be 6 apprised of the settlement discussions . 7 Staff Investigation 8 Q. What type of investigation did Staff conduct to 9 evaluate the Company' s base rate increase request? 10 A. Staff' s approach in any general rate case ("GRC") 11 is to extensively review the Company' s Application and 12 associated testimony and workpapers, identify adjustments 13 to the proposed revenue requirement, evaluate the Company' s 14 class cost of service studies and rate spread, and prepare 15 to file testimony for a fully-litigated proceeding. There 16 were 11 Staff members analyzing this case consisting of 17 auditors, engineers, utility analysts, and consumer 18 compliance investigators . Additionally, five supervisors 19 reviewed the results of all analysis and provided policy 20 direction to the assigned Staff. 21 Staff reviewed the Company' s historical results 22 of operations, pro forma capital budgets, capital spending 23 trends, operations and maintenance ("O&M") expenses and 24 trends, and verified all the Company' s calculations and 25 assumptions regarding the overall revenue requirement, cost CASE NO. IPC-E-25-16 ENGLISH, D. (Stip) 5 11/18/25 STAFF 1 of service, and rate design. The auditors reviewed 2 thousands of transactions, selected samples, and performed 3 transactional testing in accordance with standard audit 4 procedures . The auditors also reviewed the Company' s labor 5 expense, incentive plans, and employe benefits to ensure 6 the appropriate level of expenditures are included in 7 rates . 8 Staff reviewed both completed and proposed 9 capital investments to determine the prudency of capital 10 additions . Expenditures including pension expense, 11 salaries, and 0&M expenses were also examined, along with 12 depreciation expense and taxes . Additionally, Staff 13 investigated the Company' s cost of capital, capital 14 structure, cost of service, and revenue normalization. In 15 total, Staff propounded over 216 production requests, many 16 of which contained multiple sub-parts . Staff performed an 17 audit of the Company' s books, met with Company personnel to 18 review the underlying accounting data and capital project 19 documentation, and conducted on-site visits of certain 20 transmission, distribution, battery security, and 21 communication projects . Staff also participated in several 22 virtual meetings with Company personnel as a part of its 23 comprehensive investigation. 24 Settlement Evaluation 25 Q. How did Staff determine that the overall CASE NO. IPC-E-25-16 ENGLISH, D. (Stip) 6 11/18/25 STAFF 1 Settlement was reasonable? 2 A. In every settlement evaluation, Staff and other 3 parties must examine the risks of losing positions at 4 hearing and determine if the settlement is a better overall 5 outcome . Staff must evaluate each individual adjustment 6 and determine the likelihood of the Commission accepting or 7 rejecting Staff' s rationale for the adjustment . All 8 parties must weigh the risks of the Commission decision 9 establishing perceived adverse precedent which creates a 10 willingness to negotiate a positive outcome in good faith. 11 Ultimately, Staff' s intent in every settlement conference 12 is to negotiate the best possible outcome for customers . 13 Q. Does Staff support the Settlement as fair, just, 14 and reasonable? 15 A. Yes, after a comprehensive review of the 16 Company' s Application, a thorough audit of the Company' s 17 books and records, an analysis of the Company' s class cost 18 of service study, and extensive negotiations with the 19 parties to the case, Staff supports the proposed 20 Settlement . The Settlement offers a reasonable balance 21 between the Company' s opportunity to earn a reasonable 22 return on its investment and affordable rates for 23 customers . Staff believes the Settlement is in the public 24 interest; is fair, just, and reasonable; and should be 25 approved by the Commission . CASE NO. IPC-E-25-16 ENGLISH, D. (Stip) 7 11/18/25 STAFF I Settlement Overview 2 Q. Would you please describe the terms of the 3 proposed Settlement as it related to the stipulated revenue 4 requirement? 5 A. If approved, the proposed Settlement provides a 6 reduction in the Company' s requested revenue requirement . 7 Instead of the Company' s proposed electric base rate 8 increase of $199 . 1 million (13 . 090) , electric base rates 9 for Idaho customers under the proposed Settlement will 10 increase by approximately $110 million, or 7 . 480, effective 11 January 1, 2026 . 12 Q. How was the stipulated revenue requirement 13 derived? 14 A. The stipulated revenue requirement was calculated 15 by starting with the Company' s requested revenue 16 requirement increase and subtracting the agreed upon 17 adjustments proposed by Staff and the other Parties . While 18 not all proposed adjustments were accepted by the Company, 19 concessions were made by each of the Parties to arrive at a 20 final revenue increase that was deemed acceptable to all 21 signing Parties . The calculation of the stipulated revenue 22 requirement is shown in the table on Page 5 of the signed 23 Stipulation and Settlement . 24 Q. Please explain the cost of capital and return on 25 equity components of the Settlement . CASE NO. IPC-E-25-16 ENGLISH, D. (Stip) 8 11/18/25 STAFF 1 A. In its Application, Idaho Power proposed a 510 2 common equity ratio and a 10 . 4% ROE . The proposed 3 Settlement maintains the Company' s proposed capital 4 structure and maintains the currently authorized 9 . 6% ROE . 5 A 9 . 6% ROE reduces the Company' s requested revenue 6 requirement by approximately $27 . 7 million. 7 Q. How does the Settlement account for the Company' s 8 capital investments included in net rate base? 9 A. In its Application, the Company proposed to 10 include forecasted capital investments through December 31, 11 2025, in its calculation of net rate base . The proposed 12 Settlement is based on an authorized Idaho jurisdictional 13 rate base of $4, 881, 563, 721, which reduces the Company' s 14 proposed revenue requirement by approximately $21 . 6 15 million. The stipulated rate base amount is calculated 16 based on 2025 average of monthly averages ("AMA") utilizing 17 actual plant additions through July 31, 2025, and updated 18 forecasted capital from August 1, 2025, through December 19 31, 2025 . The signing Parties agree that, except as 20 otherwise noted in the Settlement, all capital additions 21 placed in service prior to July 31, 2025, are presumed to 22 be prudently incurred. To the extent that the Parties 23 identify potential prudence concerns with capital 24 investments after July 2025, the Parties reserve the right 25 to address those concerns in the Company' s next GRC. CASE NO. IPC-E-25-16 ENGLISH, D. (Stip) 9 11/18/25 STAFF 1 Q. Were there additional adjustments to the 2 Company' s rate base included in the proposed Settlement? 3 A. Yes, the proposed Settlement reduces the filed 4 revenue requirement by approximately $1 . 4 million to 5 reflect higher actual customer advance balances as of July 6 2025 compared to the forecasted balances included in the 7 Company' s original filing. Additionally, the proposed 8 Settlement reduces the Company' s request by another 9 $967, 816 to include the Boardman to Hemingway seller' s 10 security deposit received from the Bonneville Power 11 Administration, which serves as an offset to plant-in- 12 service . 13 Q. Please describe the Settlement' s terms related to 14 the Company' s revenue forecast . 15 A. The proposed Settlement reduces the Company' s 16 filed request by approximately $9 . 1 million to reflect an 17 update to the revenue forecast based on actual revenue 18 through July 2025 . 19 Q. Please describe the Settlement' s terms related to 20 the Company' s operating expenses . 21 A. In total, the proposed Settlement reduces the 22 Company' s revenue requirement by nearly $6 . 5 million for 23 operating expenses . Adjustments were made to the Company' s 24 filed request for certain executive compensation, training, 25 and travel expenses ($3 . 9 million) ; Board of Director' s CASE NO. IPC-E-25-16 ENGLISH, D. (Stip) 10 11/18/25 STAFF 1 compensation and Board of Director' s expenses ($1 . 3 2 million) ; and miscellaneous expenses ($1 .2 million) such as 3 corporate jet flights and maintenance, advertising, legal 4 fees, and injuries and damages . 5 Q. Please describe the Settlement' s terms related to 6 Wildfire Operations & Maintenance ("O&M") expense and the 7 Wildfire 0&M deferral mechanism. 8 A. The proposed Settlement removes from the 9 Company' s filed revenue requirement one-time wildfire 0&M 10 expenditures that will not continue in the future, which 11 reduces the Company' s request by $211, 884 . The proposed 12 Settlement also reduces the Company' s requested revenue 13 requirement by $736, 780 for expenses associated with the 14 Company' s standby helicopter service and the aerial drone 15 inspection pilot program. Additionally, the filed request 16 was reduced by approximately $9 . 8 million to maintain the 17 Company' s 3-year vegetation management cycle based on 2024 18 actual expenditures . The net effect of these adjustments 19 decreases the overall revenue requirement by approximately 20 $10 . 7 million. 21 A Wildfire 0&M Base of $33, 418, 421 (total system) 22 was established in the proposed Settlement . This reduced 23 base provides for a decrease of $10 . 7 million in the 24 Company' s filed request . Any prudently incurred incremental 25 expenses above the Wildfire 0&M Base for (1) vegetation CASE NO. IPC-E-25-16 ENGLISH, D. (Stip) 11 11/18/25 STAFF 1 management, (2) Enhanced Practices for Red and Yellow Risk 2 Zones, (3) Internal Vegetation Management Crew Pilot, and 3 (4) The Standby Helicopter Service and Aerial Drone 4 Inspection Pilot are eligible for deferral through the 5 earlier of Idaho Power' s next GRC or 2027 . 6 The current wildfire deferral balance as of June 7 30, 2025, will be amortized over a 7-year period, which 8 reduces revenue requirement by approximately $2 . 6 million. 9 Q. Please describe the proposed Settlement' s terms 10 related to the Insurance Base . 11 A. The signing Parties agree to reduce the Company' s 12 requested revenue requirement by approximately $5 . 3 million 13 to reflect insurance actuals for 2024 compared to 2025 14 forecasted amount included in the Company' s filing. 15 Incremental insurance expense above the 2024 actual amount 16 of $20, 164, 472 (total system) will continue to be deferred 17 through the earlier of the Company' s next GRC or 2027 . 18 Q. Please describe the proposed Settlement as it 19 relates to the Company' s Net Power Supply Expenses 20 ("NPSE") . 21 A. Two adjustments were made to the Company' s NPSE 22 in the proposed Settlement which reduce the Company' s 23 requested revenue requirement by approximately $3 .2 24 million. The first adjustment updates the modeling 25 assumption related to natural gas prices and reduces filed CASE NO. IPC-E-25-16 ENGLISH, D. (Stip) 12 11/18/25 STAFF 1 system NPSE by $45 .2 million. Net of the Power Cost 2 Adjustment ("PCA") transfer adjustment, this results in a 3 net reduction of $2, 186, 414 to the Company' s revenue 4 requirement . 5 The second NPSE adjustment incorporates an 6 estimate of the Energy Imbalance Market ("EIM") benefits 7 which reduces filed system NPSE by $20 . 6 million. Net of 8 the PCA transfer adjustment, this results in a net 9 reduction of $995, 491 to the Company' s revenue requirement . 10 Q. What is the impact of all revenue requirement 11 adjustments included in the proposed Settlement . 12 A. The stipulated revenue requirement increase 13 included the proposed Settlement is $110, 040, 145, which is 14 approximately $89 . 1 million less than the original filing. 15 The signing Parties agree that the $110 million net revenue 16 increase should be recovered by implementing tariffs in 17 conformance with Exhibit No . 1 to the Settlement and 18 Stipulation. Staff witness Louis provides greater detail 19 and justification for the revenue allocation in his 20 testimony. 21 Q. Are there additional elements to the proposed 22 Settlement that you would like to explain? 23 A. Yes . The Company has a revenue sharing mechanism 24 approved by the Commission in Order No . 30978 (Case No . 25 IPC-E-09-30) and modified in subsequent orders (Order Nos . CASE NO. IPC-E-25-16 ENGLISH, D. (Stip) 13 11/18/25 STAFF 1 33149, 34071, and 36042) that includes provisions for the 2 accelerated amortization of Accumulated Deferred Investment 3 Tax Credits ("'ADITC") to help Idaho Power achieve a minimum 4 9 . 12% Idaho jurisdictional ROE . When Idaho Power earns 5 greater than a 9 . 6% Idaho jurisdictional ROE, excess 6 earnings are shared with customers . Under the proposed 7 Settlement, the maximum allowed amount of annual 8 accelerated amortization of ADITC will be $55 million for 9 calendar year 2026 and thereafter. 10 The proposed Settlement also calls for numerous 11 workshops to explore unresolved issues brought up in the 12 settlement negotiations and calls for a separate single 13 issue Class Cost of Service ("CCOS") docket to address the 14 Parties' concerns and associated policy issues . Staff 15 witnesses Louis and Seuss discuss the CCOS docket in 16 greater detail in their testimony. 17 Q. The Company' s Application included a depreciation 18 and interest tracking mechanism. How does the proposed 19 Settlement address the Company' s request for the new 20 mechanism. 21 A. While Staff was supportive of exploring the 22 possibility of a capital tracking mechanism, Staff did not 23 agree with the Company' s proposal as filed. Staff could 24 have supported some type of mechanism with a finite 25 expiration, provided that the Company agreed to not file an CASE NO. IPC-E-25-16 ENGLISH, D. (Stip) 14 11/18/25 STAFF 1 application to increase base rates for a specified period 2 of time . Ultimately, with the Parties' concerns 3 surrounding the Company' s CCOS methodology and other 4 unresolved issues, the Parties did not want to delay the 5 Company' s next GRC. 6 Q. Do you have any other comments on the proposed 7 Settlement? 8 A. Yes . Staff believes that the proposed Settlement 9 provides the Company with necessary rate relief during a 10 time of increased capital spending and uncertain 11 inflationary pressures . The $89 . 1 million reduction to the 12 Company' s filed request is significant and is the result of 13 give and take compromises by all the Parties . The rate 14 relief provides a balance between affordable rates for 15 customers while also maintaining the financial viability of 16 the Company. The reduced revenue requirement along with 17 identified paths to resolve outstanding issues creates a 18 Settlement that represents a fair, just, and reasonable 19 compromise of the positions put forth by the Parties and is 20 in the public interest . Therefore, Staff recommends that 21 the Commission approve the Settlement, inclusive of all 22 attachments, without material changes or modifications . 23 Q. Does this conclude your testimony in this 24 proceeding? 25 A. Yes, it does . CASE NO. IPC-E-25-16 ENGLISH, D. (Stip) 15 11/18/25 STAFF Professional Qualifications of Donn English Deputy Division Administrator - Utilities Division Idaho Public Utilities Commission EDUCATION Mr. English graduated from Boise State University in 1998 with a Bachelor of Business Administration degree in Accounting. His studies concentrated on corporate finance and taxation. He was a member of the Alpha Beta Psi honor society for Accounting students . He completed the Annual Regulatory Studies Program, the Advanced Regulatory Studies Program, and the Accounting and Ratemaking Course offered through the Institute of Public Utilities at Michigan State University. Additionally, he regularly attends meetings and conferences sponsored by the National Association of Regulatory Commissioners (NARUC) and the Society of Utility and Regulatory Financial Analysts . In 2001, Mr. English became a designated member of the American Society of Pension Professionals and Actuaries (ASPPA) and was awarded the professional designation of Qualified Pension Administrator (QPA) and Qualified 401 (k) Administrator (QKA) . Mr. English was also a member of the Association of Certified Fraud Examinators . BUSINESS EXPERIENCE Prior to joining the Idaho Public Utilities Commission (IPUC) , Mr. English was a Trust Accountant with a pension administration, actuarial, and consulting firm in Boise, Idaho . In 1999, he was promoted to Pension Administrator, and in 2001 he was promoted to Pension Consultant . In that capacity, Mr. English performed actuarial calculations and the required non- discrimination calculations for hundreds of qualified retirement plans . He completed and filed Form 5500s and represented clients during audits by the Department of Labor and the Internal Revenue Service . He also participated on the task force that wrote questions for the ASPPA administrator and actuarial exams . Exhibit No . 101 Case No . IPC-E-25-16 D. English, Staff 11/18/25 Page 1 of 2 Mr. English joined the IPUC in 2003 as a Staff Auditor. In 2016, he was promoted to Audit Team Lead, and in 2018 he became the Program Manager for the Accounting and Finance Department within the Utilities Division. From September 2020 - March 2022, Mr. English also accepted the responsibility of supervising the Technical Analysis and Energy Efficiency team and was the Program Manager for that team until 2022 . In July 2025, Mr. English was promoted to Deputy Division Administrator overseeing the Utilities Division where he is responsible for Staff positions in all cases filed with the IPUC. At the Commission, Mr. English has audited numerous utilities including electric, water, and natural gas companies, and provided comments and testimony in numerous cases that deal with general rates, tax issues, pension issues, depreciation and other accounting issues, and other regulatory policy decisions . Mr. English participated in the Energy Efficiency Advisory Groups and External Stakeholder Advisory Committees for Idaho Power, Avista Utilities, Rocky Mountain Power, and Intermountain Gas Company. He is a member of several of the National Association of Regulatory Utility Commissioners (NARUC) working groups including the NARUC State Working Group on Performance- Based Regulation, the NARUC State Working Group on Electric Vehicles, and the NARUC State Working Group on Grid-Interactive Efficient Buildings in collaboration with the National Association of State Energy Officials (NASEO) . Mr. English is the Chair of the NARUC Staff Subcommittee on Education and Research and the Vice Chair of the NARUC Staff Subcommittee of Accounting and Finance . Mr. English is also a faculty member of NARUC Rate School . Exhibit No . 101 Case No . IPC-E-25-16 D. English, Staff 11/18/25 Page 2 of 2 CERTIFICATE OF SERVICE I HEREBY CERTIFY THAT I HAVE THIS 181h DAY OF NOVEMBER 2025, SERVED THE FOREGOING DIRECT TESTIMONY OF DONN ENGLISH IN SUPPORT OF THE STIPULATION AND SETTLEMENT , IN CASE NO. IPC-E-25-16, BY E- MAILING A COPY THEREOF, TO THE FOLLOWING: DONOVAN E. WALKER TIMOTHY TATUM MEGAN GOICOECHEA ALLEN CONNIE ASCHENBRENNER IDAHO POWER COMPANY MATT LARKIN PO BOX 70 1221 WEST IDAHO STREET BOISE ID 83707-0070 P.O.BOX 70 E-MAIL: BOISE,ID 83707 dwalkergidahopower.com E-MAIL: mfzoicoecheaallenkidahopower.com ttatumkidahopower.com dockets(kidahopower.com caschenbrenner(kidahopower.com mlarkin(kidahopower.com CLEAN ENERGY OPPORTUNITIES: CLEAN ENERGY OPPORTUNITIES: KELSEY JAE COURTNEY WHITE 920 N. CLOVER DRIVE MIKE HECKLER BOISE, ID 83703 CLEAN ENERGY OPPORTUNITIES FOR E-MAIL: kelsey(kkelseyjae.com IDAHO 3778 PLANTATION RIVER DR., STE 102 BOISE,ID 83703 EMAIL: courtneykcleanenergyopportunities.com mike c(r�,,cleanenergyopportunities.com IIPA: IIPA: ERIC L. OLSEN LANCE KAUFMAN,PH.D. ECHO HAWK&OLSEN,PLLC 2623 NW BLUEBELL PLACE P.O. BOX 6119 CORVALLIS, OR 97330 505 PERSHING AVE., STE. 100 E-MAIL: lance(kae.isg insi hg t.com POCATELLO, ID 83205 E-MAIL: elokechohawk.com BOISE CITY.• BOISE CITY.• Ed Jewell Katie O'Neil Deputy City Attorney Energy Program Manager Boise City Attorney's Office Boise City Attorney's Office P.O. Box 500 P.O. Box 500 Boise,ID 83701-0500 Boise, ID 83701-0500 eiewellkcityofboise.org koneil(kcityofboise.org BoiseCityAttorney(kcityofboi se.org CERTIFICATE OF SERVICE - PAGE 1 FEA: FEA: Emily W. Medlyn Dwight Etheridge Jelani A. Freeman Exeter Associates,Inc. U.S. Department of Energy 10480 Little Patuxent Parkway, Ste. 300 1000 Independence Ave., S.W. Columbia,MD Washington,D.C. 20585 detheridgekexeterassociates.com emily.medlyn(khq.doe.gov j elani.freeman(khq.doe.gov ICIP: PETER J. RICHARDSON RICHARDSON ADAMS, PLLC 515 N. 27"' STREET BOISE,ID 83702 E-MAIL: peter(cr�richardsonadams.com MICRON: MaHydro: Austin Rueschhoff C. Tom Arkoosh Thorvald A.Nelson Nicholas J. Erekson Austin W.Jensen Arkoosh Law Offices Kristine A.K. Roach P.O. Box 2900 Holland&Hart,LLP Boise, ID 83701 555 17"' St., Ste. 3200 tom.arkooshkarkoosh.com Denver,CO 80202 nick.erekson(karkoosh.com darueschhoffkhollandhart.com erin.cecil(c_r�,arkoosh.com tnelsonkhollandhart.com awj ensenkho llandhart.com (cr�,�karoachhollandhart.com ELECTRONIC SERVICE ONLY: acleekhollandhart.com tlfriel(khollandhart.com Gannon, et al.,pro se: Korger: John Gannon Kurt J.Boehm johngannon200(kgmail.com Jody Keyle Cohn Randy Morris occidentalpacifickhotmail.com Boeham,Kurtz&Lowry Deborah Fease and Amy Lorrance 425 Walnut Street, Suite 2400 feased854(kgmail.com Cincinnati, OH 45202 kboelunkbkllawfirm.com jkylercohn ckbkllawfirm.com Northwest Energy Coalition (NWEC) Northwest Energy Coalition (NWEC) Benjamin J. Otto Lauren McCloy Attorney for NWEC Utility Regulatory Director 1407 W. Cottonwood Court lauren(knwenergy.org Boise,ID 83702 Derek Goldman benknwenergyy.org Policy Associate derek(knwenergy.org PATRICIA JORDA14, SECRETARY CERTIFICATE OF SERVICE - PAGE 2