20101227IPC to NIPPC 5-12.pdf

e¿llW~POR~
An IDACORP Company
DONOVAN E. WALKER
Senior Counsel
dwalkercmidahopower.com
December 27,2010
VIA HAND DELIVERY
Jean D. Jewell, Secretary
Idaho Public Utilties Commission
472 West Washington Street
P.O. Box 83720
Boise, Idaho 83720-0074
Re: Case No. GNR-E-10-04
IN THE MA ITER OF THE JOINT PETITION OF IDAHO POWER COMPANY,
AVISTA CORPORATION, AND PACIFICORP DBA ROCKY MOUNTAIN
POWER TO ADDRESS AVOIDED COST ISSUES AND TO ADJUST THE
PUBLISHED AVOIDED COST RATE ELIGIBILITY CAP.
Dear Ms. Jewell:
Enclosed for filng please find an original and three (3) copies of Idaho Power
Company's Response to the Second Production Request of the Northwest and
Intermountain Power Producers Coalition to Joint Utilities in the above matter.
ZCf! c1rl
Donovan E. Walker
DEW:csb
Enclosures
1221 W. Idaho St. (83702)
P.O. Box 70
Boise, ID 83707
DONOVAN E. WALKER (ISB No. 5921)
LISA D. NORDSTROM (ISB No. 5733)
Idaho Power Company
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
dwalker(âidahopower.com
Inordstrom(ëidahopower.com
Attomeys for Idaho Power Company
Street Address for Express Mail:
1221 West Idaho Street
Boise, Idaho 83702
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t:. :
2010 DEC 27 PM 4= 46
\D i~ i""i ()
UT!L1TIES
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE JOINT
PETITION OF IDAHO POWER
COMPANY, AVISTA CORPORATION,
AND PACIFICORP DBA ROCKY
MOUNTAIN POWER TO ADDRESS
AVOIDED COST ISSUES AND TO
ADJUST THE PUBLISHED AVOIDED
COST RATE ELIGIBILITY CAP.
)
) CASE NO. GNR-E-10-04
)
) IDAHO POWER COMPANY'S
) RESPONSE TO THE SECOND
) PRODUCTION REQUEST OF THE
) NORTHWEST AND
) INTERMOUNTAIN POWER
) PRODUCERS COALITION TO JOINT
) UTILITIES
)
COMES NOW, Idaho Power Company ("Idaho Powet' or "Company"), and in
response to the Second Production Request of the Northwest and Intermountain Power
Producers Coalition to Joint Utilties dated December 6, 2010, herewith submits the
following information:
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION TO JOINT UTILITIES - 1
REQUEST NO.5: On what basis do the Joint Utilties include Avista Corporation
in the Joint Motion to reduce the eligibilty cap for published avoided cost rates?
RESPONSE TO REQUEST NO.5: Answering hereto on behalf of Idaho Power
Company only, Avista Corporation is included in the joint filng because they, just like
Idaho Power Company and Rocky Mountain Power, are public utilties under Idaho
Code § 61-129 subject to the jurisdiction, control, and regulation of the Idaho Public
Utilities Commission. As such, Sections 201 and 210 of PURPA, and pertinent
regulations of the Federal Energy Regulatory Commission, require that regulated
utilities, such as Avista Corporation, Idaho Power Company, and Rocky Mountain
Power, purchase power produced by cogenerators or small power producers that obtain
qualifying facilty ("QF") status.
The response to this Request was prepared by Donovan E. Walker, Senior
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION TO JOINT UTILITIES - 2
REQUEST NO.6: Please provide copies of all documentation relied upon by the
Joint Utilties in making the decision to include Avista Corporation in the Joint Motion.
Said documentation should include all studies, writings, documents, correspondence,
notes and memoranda used or referenced in the decision making process to include
Avista Corporation in the Joint Motion.
RESPONSE TO REQUEST NO.6: Answering hereto on behalf of Idaho Power
Company only, Idaho Power does not have this information. Please see Avista's
response to Northwest and Intermountain Power Producers Coalition's ("NIPPC")
Production Request NO.6.
The response to this Request was prepared by Donovan E. Walker, Senior
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION TO JOINT UTILITIES - 3
REQUEST NO.7: Does Avista have any wind QFs currently online? What is the
level (nameplate MWs) of wind (PURPA and non-PURPA) that Avista is currently
integrating on its system? What is Avista's peak, minimum and average load (in MWs)?
Please provide workpapers supporting the response.
RESPONSE TO REQUEST NO.7: Answering hereto on behalf of Idaho Power
Company only, Idaho Power does not have this information. Please see Avista's
response to NIPPC's Production Request No.7.
The response to this Request was prepared by Donovan E. Walker, Senior
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION TO JOINT UTILITIES - 4
REQUEST NO.8: Reference Joint Petition and Joint Motion, at p. 4, stating
Rocky Mountain Power has 358 MW of new wind contract requests. Reference the
Joint Petition and Joint Motion at p. 4 stating Idaho Power has over 570 MW of new
wind contract requests.
a. What is the equivalent number for Avista Corporation?
b. Please provide a list of all such requests, including the name of the
requesting entity, nameplate capacity of the wind project, point of initial contact with
Avista Corporation, and date and nature of the last communication between the Utilties.
c. For each requesting entity, please provide supporting evidence that the
project is stil being pursued. Such evidence may include a recent correspondence from
the requesting entity requesting a contract.
d. If the documents and information requested in items (a) and (b) are
unavailable, please explain the basis for the response to No. 7(a) above.
RESPONSE TO REQUEST NO.8: Answering hereto on behalf of Idaho Power
Company only, Idaho Power does not have this information. Please see Avista's
response to NIPPC's Production Request NO.8.
The response to this Request was prepared by Donovan E. Walker, Senior
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION TO JOINT UTILITIES - 5
REQUEST NO.9: Reference Joint Petition and Joint Motion Attachment NO.1.
a. Please provide equivalent data for Avista Corporation and Rocky
Mountain Power.
b. Please provide, in electronic format where possible, all work papers,
spreadsheets, and data used in the response to No. 8(a).
c. Please state the name of the person who can sponsor this attachment at a
hearing.
RESPONSE TO REQUEST NO.9: Answering hereto on behalf of Idaho Power
Company only, Idaho Power does not have this information. Please see Avista's and
Rocky Mountain Powets responses to NIPPC's Production Request NO.9.
The response to this Request was prepared by Donovan E. Walker, Senior
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION TO JOINT UTILITIES - 6
REQUEST NO. 10: Reference Joint Petition and Joint Motion at p. 7 stating,
"When the utilty is forced to buy QF power in excess of its true avoided cost or in
excess of its minimum loads, customers are no longer indifferent."
a. Is it the position of each of the Joint Utilties that its avoided cost rates are,
in fact, in excess of its true avoided costs?
b. If the answer to 9(a) is yes, please provide documentation of each of the
Joint Utilties' "true avoided cost" and in electronic format where possible, all work
papers, spreadsheets and data used in response to 9(a).
c. If the answer to No. 9(a) is no, please explain the relevance of the
assertion relative to "true avoided cost" to the Joint Utilities' pleading.
RESPONSE TO REQUEST NO. 10:
a. Answering hereto on behalf of Idaho Power Company only, yes.
b. Answering hereto on behalf of Idaho Power Company only, current
published avoided cost rates are calculated by the Idaho Public Utilties Commission
based on a model that uses a combined-cycle combustion turbine as a surrogate
resource. Idaho Power does not believe this model is providing accurate avoided cost
rates. While the model may be reasonably accurate in capturing capital costs, it does
not reflect the benefits derived from a utilty-owned resource that can be dispatched,
when compared to a PURPA project that is anything but dispatchable.
Idaho Power believes the "true avoided cost" should take into account the
operational and other unique characteristics of the type of resource being considered,
such as dispatch capabilty, generation of renewable energy certificates ("REC"),
eligibilty for federal production tax credits ("PTC") or treasury department tax grants in
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION TO JOINT UTILITIES - 7
lieu of PTCs, current market prices for the generation technology, accelerated
depreciation, etc. The methodology currently being used by Idaho Power for PURPA
projects larger than 10 average megawatts ("aMW"), while not a perfect representation
of the "true avoided cost," if Idaho Power were to develop and own the resource, is
much closer to the "true avoided cost" than the published avoided cost rates produced
via the Surrogate Avoided Resource methodology. This methodology involves using
the AURORA model to determine both the energy and capacity value of the resource
and is specific to the type of resource. As such, the requested "documentation" only
exists to the extent that it has been utilized for a specific project, such as the Rockland
project below. The AURORA model is also used as the primary analysis tool for
preparing the Integrated Resource Plan ("IRP") and Idaho Power uses AURORA and
this specific methodology to evaluate potential utilty-owned resources between IRP
planning cycles.
In November 2010, the Idaho Public Utilties Commission approved a firm energy
sales agreement between Idaho Power and Rockland Wind Project LLC for the
generation from the 80 megawatt ("MW") Rockland Wind Project. The energy price
contained in this contract was determined using the AURORA model ($56.21 levelized);
however, the actual levelized price Idaho Power wil pay is $71.29 per megawatt-hour
("MWh") based on other terms negotiated in the contract, including REC ownership,
security and damage provisions, wind forecasting data, and the right of first offer for
ownership or future expansion.
While this rate only applies to this particular project, Idaho Power believes it is a
more reasonable representation of the "true avoided cost" rate and it takes into account
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION TO JOINT UTILITIES - 8
the distinct operational characteristics of the project. Additional details regarding the
Rockland wind contract can be found on the Idaho Public Utilties Commission's website
at: http://ww.puc.idaho.gov/internetlcases/summary/IPCE1024.html.
c. Answering hereto on behalf of Idaho Power Company only, not applicable.
The response to this Request was prepared by M. Mark Stokes, Manager of
Power Supply Planning, Idaho Power Company, in consultation with Donovan E.
Walker, Senior Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION TO JOINT UTILITIES - 9
REQUEST NO. 11: Reference Joint Petition and Joint Motion at p. 7 as quoted
in Request NO.9.
a. What is each of the Joint Utilties' minimum load? Please explain how
that number is derived and provide documentation of each of the Joint Utilties' answer.
b. Please provide your response to No. 10(a) on both a system wide and an
Idaho jurisdictional basis.
c. Please document the number of hours each year that each of the Joint
Utilties' total generation exceeds minimum load. Please provide this information on
both a system wide basis and an Idaho jurisdictional basis
d. Please document the number of hours each year that generation (by type
of resource e.g. hydro, coal, natural gas, etc) exceeds minimum load. Please provide
this information on both a system wide basis and an Idaho jurisdictional basis.
e. Please explain, on both engineering and a financial basis, each of the
Joint Utilties' response to a situation where total generation exceeds minimum load.
RESPONSE TO REQUEST NO. 11:
a. Answering hereto on behalf of Idaho Power Company only, Idaho Power's
minimum hourly average load for 2010 year to date (through December 20, 2010) is
1,033 aMW, which was recorded on May 31,2010. Idaho Powets Energy Management
System collects data which is then stored and accessed through a softare application.
The minimum load referenced in the Joint Petition is based on hourly average system
load data.
b. Answering hereto on behalf of Idaho Power Company only, on a system-
wide basis, Idaho Powets minimum hourly average load for 2010 year to date (through
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION TO JOINT UTILITIES -10
December 20, 2010) is 1,033 aMW, which was recorded on May 31, 2010. The
collected data is not captured on a jurisdictional basis; however, Idaho Powets Oregon
customers typically represent 4.6 percent of total system load on an annual basis.
Therefore, on that basis, Idaho jurisdictional minimum hourly average load would be
985 aMW.
c. Answering hereto on behalf of Idaho Power Company only, for 2010 year
to date (through December 20, 2010) Idaho Powets total company-owned generation
has exceeded hourly average load for 4,054 hours. For the same period, Idaho Powets
total company-owned generation has exceeded Idaho jurisdictional hourly average load
for 5,103 hours.
d. Answering hereto on behalf of Idaho Power Company only, for 2010 year
to date (through December 20, 2010) Idaho Powets hydro generation has exceeded
hourly average load for 38 hours (77 hours for Idaho jurisdictional load). Neither coal
nor gas generation has exceeded average hourly system load or Idaho jurisdictional
load year to date.
e. Answering hereto on behalf of Idaho Power Company only, on an
engineering basis, any time generation exceeds load, Idaho Power must either have
transmission capacity available to make off-system sales or generation resources must
be curtailed. In order to integrate wind, Idaho Power must have other resources
operating that can provide operating reserves. If total wind generation exceeds load
and transmission capacity is constrained, Idaho Power may not be able to have other
resources on-line necessary to integrate the wind generation.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION TO JOINT UTILITIES - 11
On a financial basis, the impact results from having to take energy at a time
when it is not needed to serve load and must be sold into the market at a substantial
loss.
The response to this Request was prepared by M. Mark Stokes, Manager of
Power Supply Planning, Idaho Power Company, in consultation with Donovan E.
Walker, Senior Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION TO JOINT UTILITIES -12
REQUEST NO. 12: Reference Joint Petition and Joint Motion at p. 7 stating "It is
also important that this change in eligibilty for published avoided cost rates be applied
equally to the Utilties, as exclusion of one may act as a "magnet" attracting a
disproportionate number of proposals for that utilty."
a. For Avista Corporation, please identify all possible firm transmission paths
into its balancing area from the other two Joint Utilties' Idaho balancing areas upon
which renewable resources could schedule energy and capacity to Avista.
b. For each such transmission path please identify the available firm
transmission capacity that renewable resources may use for delivery of energy and
capacity to Avista.
c. Please identify and estimate all costs to a renewable resource located in
each of the other two Joint Utilties' balancing area for delivery of energy and capacity to
Avista.
d. Please provide responses to 11(a) - (c) with regard to delivery to Idaho
Power from the balancing area of the other Joint Utilties.
e. Please provide responses to 11(a) - (c) with regard to delivery to Rocky
Mountain Power from the balancing area of the other Joint Utilties.
RESPONSE TO REQUEST NO. 12:
a. Answering hereto on behalf of Idaho Power Company only, Idaho Power
does not have this information. Please see Avista's response to NIPPC's Production
Request No. 12.a.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION TO JOINT UTILITIES -13
b. Answering hereto on behalf of Idaho Power Company only, Idaho Power
does not have this information. Please see Avista's response to NIPPC's Production
Request No. 12.b.
c. Answering hereto on behalf of Idaho Power Company only, Idaho Power
does not have this information. Please see Avista's response to NIPPC's Production
Request No. 12.c.
d. Assuming that NIPPC's Production Request 12.d. was meant to refer to
"12 (a) - (c)" and not "11 (a) - (c)" the answer on behalf of Idaho Power Company only
is as follows:
a. For .i~Nista Corporation Idaho Power Company, please
identify all possible firm transmission paths into its balancing
area from the other two Joint Utilties' Idaho balancing areas
upon which renewable resources could schedule energy and
capacity to Avista Idaho Power Company.
The transmission path from the Avista balancing area to the Idaho
Power balancing area is the Oxbow-Lolo (located near Lewiston, Idaho) 230 kilovolt
("kV") line, which is part of the Idaho to Northwest Path.
The transmission paths from PacifiCorp's Idaho balancing area to
Idaho Powets balancing area are the:
Blackfoot-Goshen 161 kV line;
Bridger West Path - 345 and 230 kV lines west of Jim
Bridger Power Plant; and
Path C - Borah-Ben Lomond 345 kV, Brady Treasureton
230 kV, and American Falls Malad 138 kV lines.
b. For each such transmission path please identify the
available firm transmission capacity that renewable
resources may use for delivery of energy and capacity to
Avista Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION TO JOINT UTILITIES - 14
The available firm transmission capacity from the Avista balancing
area through the Oxbow-Lolo 230 kV line is zero.
The available firr transmission capacities from PacifiCorp's Idaho
balancing area are:
Transmission Path Available Transmission
Capacity
Blackfoot - Goshen 161 kV line 0
Bridger West Path 0
Path C 0
(due to Borah West constraint)
c. Please identify and estimate all costs to a renewable
resource located in each of the other two Joint Utilties'
balancing area for delivery of energy and capacity to Avista
Idaho Power Company.
Summary information of the transmission service request studies
performed in the past three years is posted on Idaho Power's OASIS. This file does not
contain any studies for transmission capacity additions to provide capacity from the
other two Joint Utilities. Therefore, Idaho Power does not have any improvements or
cost estimates developed for delivering renewable resources located in the other two
Joint Utilities' balancing areas to Idaho Powets balancing area.
e. Answering hereto on behalf of Idaho Power Company only, Idaho Power
does not have this information. Please see Rocky Mountain's response to NIPPC's
Production Request No. 12.e.
The response to this Request was prepared by Dave Angell, Manager of Delivery
Planning, Idaho Power Company, in consultation with Donovan E. Walker, Senior
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION TO JOINT UTILITIES - 15
DATED at Boise, Idaho, this 2ih day of December 2010.
~p~~WALKER
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION TO JOINT UTILITIES -16
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 2ih day of December 2010 I served a true and
correct copy of the IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE NORTHWEST AND INTERMOUNTAIN POWER
PRODUCERS COALITION TO JOINT UTILITIES upon the following named parties by
the method indicated below, and addressed to the following:
Commission Staff
Donald L. Howell, II
Kristine Sasser
Deputy Attorney General
Idaho Public Utilties Commission
472 West Washington
P.O. Box 83720
Boise, Idaho 83720-0074
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.- Email don.howell(ëpuc.idaho.gov
kris.sasser(ëpuc. idaho.gov
Avista Corporation
Michael Andrea
Clint Kalich
Avista Corporation
1411 East Mission Avenue - MSC-23
P.O. Box 3727
Spokane, Washington 99220-3727
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clint. kalich(ëavistacorp. com
PacifiCorp d/b/a Rocky Mountain Power
Daniel E. Solander
J. Ted Weston
Rocky Mountain Power
201 South Main Street, Suite 2300
Salt Lake City, Utah 84111
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Bruce Griswold
PacifiCorp
825 NE Multnomah
Portland, Oregon 97232
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IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION TO JOINT UTILITIES -17
Exergy, Grand View Solar, J. R. Simplot,
Northwest and Intermountain Power
Producers Coalition, & Board of
Commissioners of Adams County, Idaho
Peter J. Richardson
Greg Adams
RICHARDSON & O'LEARY, PLLC
515 North 2ih Street
P.O. Box 7218
Boise, Idaho 83702
Exergy Development Group
James Carkulis, Managing Member
Exergy Development Group of Idaho, LLC
802 West Bannock Street, Suite 1200
Boise, Idaho 83702
Grand View Solar II
Robert A. Paul
Grand View Solar II
15960 Vista Circle
Desert Hot Springs, California 94221
J.R. Simplot Company
Don Sturtevant, Energy Director
J.R. Simplot Company
One Capital Center
999 Main Street
P.O. Box 27
Boise, Idaho 83707-0027
Northwest and Intermountain Power
Producers Coalition
Robert D. Kahn, Executive Director
Northwest and Intermountain Power
Producers Coalition
1117 Minor Avenue, Suite 300
Seattle, Washington 98101
Renewable Energy Coalition
Thomas H. Nelson, Attorney
Renewable Energy Coalition
P.O. Box 1211
Welches, Oregon 97067-1211
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greg(ërichardsonandoleary.com
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IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION TO JOINT UTILITIES - 18
John R. Lowe, Consultant
Renewable Energy Coalition
12050 SW Tremont Street
Portland, Oregon 97225
Cedar Creek Wind, LLC
Ronald L. Willams
WILLIAMS BRADBURY, P.C.
1015 West Hays Street
Boise, Idaho 83702
Scott Montgomery, President
Cedar Creek Wind, LLC
668 Rockwood Drive
North Salt Lake, Utah 84054
Dana Zentz, Vice President
Summit Power Group, Inc.
2006 East Westminster
Spokane, Washington 99223
Idaho Windfarms, LLC
Glenn Ikemoto
Margaret Rueger
Idaho Windfarms, LLC
672 Blair Avenue
Piedmont, California 94611
Interconnect Solar Development, LLC
R. Greg Ferney
MIMURA LAW OFFICES, PLLC
2176 East Franklin Road, Suite 120
Meridian, Idaho 83642
Bil Piske, Manager
Interconnect Solar Development, LLC
1303 East Carter
Boise, Idaho 83706
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Margaret(ëEnvisionWind .com
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IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION TO JOINT UTILITIES -19
Intermountain Wind LLC
Dean J. Miler
McDEVITT & MILLER LLP
420 West Bannock Street
P.O. Box 2564
Boise, Idaho 83701
Paul Martin
Intermountain Wind LLC
P.O. Box 353
Boulder, Colorado 80306
Dynamis Energy, LLC
Ronald L. Wiliams
WILLIAMS BRADBURY, P.C.
1015 West Hays Street
Boise, Idaho 83702
Wade Thomas, General Counsel
Dynamis Energy, LLC
776 East Riverside Drive, Suite 15
Eagle, Idaho 83616
North Side Canal Company and Twin
Falls Canal Company
Shelley M. Davis
BARKER ROSHOLT & SIMPSON, LLP
1010 West Jefferson Street, Suite 102
P.O. Box 2139
Boise, Idaho 83701-2139
Brian Olmstead, General Manager
Twin Falls Canal Company
P.O. Box 326
Twin Falls, Idaho 83303
Ted Diehl, General Manager
North Side Canal Company
921 North Lincoln Street
Jerome, Idaho 83338
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IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION TO JOINT UTILITIES - 20
Board of Commissioners of Adams
County, Idaho
Bil Brown, Chair
Board of Commissioners of
Adams County, Idaho
P.O. Box 48
Council, Idaho 83612
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Birch Power Company
Ted S. Sorenson, P.E.
Birch Power Company
5203 South 11 th East
Idaho Falls, Idaho 83404
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etp¿Donovan E. Walker
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION TO JOINT UTILITIES - 21