20110113IPC to NIPPC 13-22.pdf

DONOVAN E. WALKER
Senior Counsel
dwalkertæidahopower.com
?ž11W~POR~
An IDACORP Company
January 12, 2011
VIA HAND DELIVERY
Jean D. Jewell, Secretary
Idaho Public Utilities 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 Third Production Request of the Northwest and Intermountain
Power Producers Coalition to Joint Utilties in the above matter.
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(ãidahopower.com
Inordstrom(ãidahopower.com
Attorneys for Idaho Power Company
Street Address for Express Mail:
1221 West Idaho Street
Boise, Idaho 83702
RCA,,,t '\ L,~v C": r f-..,;-;
ZOU JAN 12 PH~:49
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 THIRD
) 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 Third Production Request of the Northwest and Intermountain Power
Producers Coalition to Joint Utilties dated December 22, 2010, herewith submits the
following information:
IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION TO JOINT UTILITIES - 1
REQUEST NO. 13: Reference Avista's Initial Comments, page 3 (stating "Avista
is now receiving proposals for utility scale projects" under PURPA).
(a) Please admit or deny that Avista has submitted no evidence in this docket
supporting this claim.
(b) If Avista's response in (a) is to deny, please explain what evidence in the
record supports this claim.
(c) Please define "utilty scale."
RESPONSE TO REQUEST NO. 13: 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. 13.
The response to this Request was prepared by Donovan E. Walker, Senior
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION TO JOINT UTILITIES - 2
REQUEST NO. 14: Reference Avista's Initial Comments, page 5 (stating
"Today's published rates have attracted 450 MW of new development to Avista's
system; 90% was received over the past year, and nearly half over the past 3 months").
(a) Please admit or deny that Avista has submitted no evidence in this docket
supporting this claim. Please explain.
(b) Please admit or deny that Avista has not entered into any PURPA PPAs in
the time frame referenced.
(c) If Avista's response in (b) is to deny, please provide a copy of the PPA
and identify the IPUC case number where Avista sought approval.
(d) If Avista's response in (b) is to admit, please explain why none of the 350
MW of requested PURPA PPAs were executed.
(d) (sic)Please admit or deny that prior to filing of Avista's Initial Comments
on December 22, 2010, Avista and/or the Joint Utilties had not specified in a filing in
this docket any amount of PURPA development requests to Avista in the last year.
RESPONSE TO REQUEST NO. 14: 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. 14.
The response to this Request was prepared by Donovan E. Walker, Senior
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION TO JOINT UTILITIES - 3
REQUEST NO. 15: Reference Avista's Initial Comments, page 5 (stating that
the published avoided cost rates are $15/MWh higher than Avista's avoided costs).
(a) Does Avista believe this is an accurate estimate of the value of the
capacity not provided by wind projects?
(b) Please identify the pleading and Case number where the Joint Utilties
"proposed recently" that the Commission adopt this $15/MWh capacity reduction.
(c) Would this capacity reduction of $15/MWh include wind integration, or
would the utilties also reduce the avoided costs paid to wind QFs by wind integration in
addition to the $15/MWh capacity reduction.
(d) Does Avista believe that $15/MWh is an accurate estimate of the value of
RECs? Please provide supporting evidence.
RESPONSE TO REQUEST NO. 15: 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. 15.
The response to this Request was prepared by Donovan E. Walker, Senior
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION TO JOINT UTILITIES - 4
REQUEST NO. 16: Reference Avista's Initial Comments, page 6 (stating Avista
cannot guarantee system reliabilty at the levels of PURPA project output being offered).
(a) Please explain the level of wind output (nameplate MW) Avista believes it
could safely integrate with existing resources.
(b) Please explain the level of wind output Avista believes would require it to
obtain new generating resources. Please identify the type and amount (nameplate MW)
of resources needed at varying wind penetration levels (nameplate MWs).
(c) Please identify the page number(s) in Avista's most recent wind
integration study supporting the levels cited in (a) and (b). If none is available, please
explain the basis for the levels asserted in (a) and (b), and provide any supporting work
papers or other evidence.
RESPONSE TO REQUEST NO. 16: 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. 16.
The response to this Request was prepared by Donovan E. Walker, Senior
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION TO JOINT UTILITIES - 5
REQUEST NO. 17: Reference Avista's Initial Comments, page 6 (stating that
projects above 100 kw can negotiate contract rates). This question is directed at all
three utilties individually. NIPPC requests that Idaho Power, RMP, and Avista each
provide separate answers to this request.
(a) Please identify each PURPA PPA containing negotiated rates entered into
in the last five years, including the case number for Commission approval of the PPA.
(b) Please identify and explain and document the average length of time of
negotiation from initial contact to final executed PPA for each PPA listed in response to
(a).
(c) Please explain how may QF requests for PPAs containing negotiated
rates have not resulted in an executed PPA during that same time period.
(d) Please identify all wind QF PPAs that were executed during the period of
the reduction in the eligibilty cap to 100 kw in Case No. IPC-E-05-22.
RESPONSE TO REQUEST NO. 17:
(a) In the last five years, Idaho Power has negotiated power purchase
agreements with Rockland Wind Project LLC, IPC-E-10-24, and Tuana Springs
Expansion and Cassia Gulch Wind Park, IPC-E-09-24.
(b) The time required to negotiate these agreements varies for each specific
project. One of the key items in any negotiation is the proposed energy pricing. In the
case of a negotiated-rate PURPA agreement, Idaho Power is required by the Idaho
Public Utilties Commission ("Commission") to develop an initial energy price by
executing the IRP/AURORA modeL. In order to run this model accurately, the project
must supply at least one yeats estimated hourly generation. Upon receipt of this
IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION TO JOINT UTILITIES - 6
generation data, Idaho Power executes the model and is typically able to supply an
energy value back to the proposed project within a couple weeks of when the data is
received.
In reviewing the two projects listed in item (a) above, there is no definitive point
in time when actual contract negotiations began. After initial contact from both parties,
various discussions and processes were initiated. This included discussion and work
related to the issues of transmission, interconnection, data requests, price modeling,
and other general contract concepts. As these discussions and processes moved
forward, draft agreements were exchanged between the parties. Many factors that
affect the length of time of negations are outside of Idaho Powets control (i.e., the
project's responsiveness to negotiations, project indecision, and unique circumstances
of the proposed project - to name a few).
(c) Idaho Power keeps no specific records of the information requested.
Based upon recollection, approximately 3 or 4 initial contacts interested in contracts
progressed to the point that energy pricing proposals were developed. For whatever
reason, none of those projects desired to move ahead with their proposed projects.
(d) The initial Application in Case No. IPC-E-05-22 was filed on June 17,
2005. The 100 kilowatt ("kW") eligibilty cap was put in place by Commission Order No.
29839, issued on August 4, 2005. The eligibilty cap was raised from 100 kW to 10
average megawatts ("aMW") by Commission Order No. 30488, issued on February 20,
2008. During the period of time that the 100 kW eligibilty cap was in place from August
4, 2005, thru February 20, 2008, the following wind contracts were executed: Lava
Beds, Milner Dam, Notch Butte, Salmon Falls, Cassia Gulch, Cassia Wind Farm, Magic
IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION TO JOINT UTILITIES - 7
Wind Park, Alkali, Bennett Creek, and Hot Springs. These contracts contained the
published avoided cost rates for projects less than 10 aMW.
The response to this Request was prepared by Randy C. Allphin, Senior Energy
Contracts Coordinator, Idaho Power Company, in consultation with Donovan E. Walker,
Senior Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION TO JOINT UTILITIES - 8
REQUEST NO. 18: Reference Avista's Initial Comments, page 7 (stating that
non-wind projects have the abilty to "break their facilties into smaller pieces with the
express intent of obtaining a rate that in many cases wil not equal avoided costs").
(a) Please explain how the following resources would break their facilties into
smaller pieces, as described in the filng: (i) small hydropower, (ii) biomass, (iii), co-
generation, (iv) anaerobic digester, (v) solar. Does Avista believe these pieces of larger
facilties for each of these resource types could have generation equipment separated
by one mile yet remain financially viable? Please provide examples of projects that
have done so or other evidence supporting the claim that any of these resources could
do so.
(b) If none of these resources listed in (a) could be split into smaller pieces
separated by one mile, please explain what non-wind QF resources could do so and
explain how.
RESPONSE TO REQUEST NO. 18: Answering hereto on behalf of Idaho Power
Company only, as this question is directed to Avista only, please see Avista's response
to NIPPC's Production Request No. 18.
The response to this Request was prepared by Donovan E. Walker, Senior
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION TO JOINT UTILITIES - 9
REQUEST NO. 19: Reference Avista's Initial Comments, page 7 (stating that
QF resources do not provide capacity).
(a) Please explain how much Avista would pay to a QF for capacity through
the current published rates.
(b) Please explain whether Avista's current published rates would
compensate a QF at times when it is not delivering energy.
(c) Does Avista provide capacity payments to any QFs at times when no
energy is delivered? Please explain.
(d) In the past five years, has Avista made capacity payments to any
generation resources owned by independent producers at times when no energy is
delivered? If yes, please provide the contract under which such payments were made.
(e) Please provide the Lancaster Plant agreement effective January 1, 2010,
referenced in Direct Testimony of Randy Lobb, Commission Staff, Case Nos. AVU-E-
09-1 and AVU-G-09-1, pp. 17-18 (May 29,2009).
(f) Are the cost estimates to ratepayers for the Lancaster plant agreement in
that case stil accurate? If not please provide updated estimates with supporting work
papers. Reference Direct Testimony of Randy Lobb, Case Nos. AVU-E-09-1 and AVU-
G-09-1, at p. 22 (estimating 2010 fixed costs of $20.87 per MWh, and a projected
generation cost range of from $58 to $72 per MWh).
RESPONSE TO REQUEST NO. 19: 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. 19.
IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION TO JOINT UTILITIES - 10
The response to this Request was prepared by Donovan E. Walker, Senior
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION TO JOINT UTILITIES - 11
REQUEST NO. 20: Reference Avista's Initial Comments, footnote 3 (stating
Avista is concerned about non-wind variable resources for which the wind integration
charge would not apply).
(a) Please identify the resource type(s) that would be non-wind and impose
integration costs on Avista's system.
(b) Please provide supporting evidence for Avista's concern regarding this
resource type(s), such as requests or inquiries for PURPA PPAs from developers of
such resource types in the last year.
RESPONSE TO REQUEST NO. 20: 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. 20.
The response to this Request was prepared by Donovan E. Walker, Senior
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION TO JOINT UTILITIES - 12
REQUEST NO. 21: Reference Avista's Initial Comments, page 9 (stating that
QF wind projects taking the published rates wil force ratepayers to pay higher rates
than they would for similar projects built by utilties).
(a) Please explain the construction status of Avista's Reardon wind farm. Wil
the project be online in 2012 as projected in the most recent IRP? When wil the project
be online, and what wil its nameplate capacity be at that time.
(b) If the Reardon project wil not achieve the online date projected in the IRP,
wil Avista's customers incur damages? Please estimate those damages and explain
the basis for the estimate. Does Avista believe that $45/kw is an accurate estimate of
potential damages? If so, wil Avista issue a ratepayer refund in that amount?
(b) (sic)Please provide an accounting of the amounts Avista has spent on
the project to date.
(c) (sic)Please explain the amount Avista wil charge to its ratepayers for
the Reardon project.
(d) (sic)Please provide a cost estimate (of $/MWh) to ratepayers for the
future output of this project. Please provide supporting work papers.
(e) (sic)Please explain whether Avista selected the Reardon project in an
RFP. If the RFP included a PPA template, please provide it. Did the IPUC approve the
RFP? Please explain. Has the IPUC authorized any activity related to Reardon. Please
explain.
RESPONSE TO REQUEST NO. 21: 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. 21.
IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION TO JOINT UTILITIES - 13
The response to this Request was prepared by Donovan E. Walker, Senior
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION TO JOINT UTILITIES - 14
REQUEST NO. 22: If Avista is permitted to negotiate the avoided cost rate with
QFs larger than 100 kw, what role wil the current SAR methodology play in determining
that rate?
RESPONSE TO REQUEST NO. 22: 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. 22.
The response to this Request was prepared by Donovan E. Walker, Senior
Counsel, Idaho Power Company.
DATED at Boise, Idaho, this 12th day of Jan
DONOVAN E. WALKER
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION TO JOINT UTILITIES - 15
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 12th day of January 2011 I served a true and
correct copy of the IDAHO POWER COMPANY'S RESPONSE TO THE THIRD
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, "
Kristine Sasser
Deputy Attorneys General
Idaho Public Utilties Commission
472 West Washington
P.O. Box 83720
Boise, Idaho 83720-0074
-- Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
-- Email don.howell(ãpuc.idaho.gov
kris.sasser((puc. idaho.gov
Avista Corporation
Michael G. Andrea
Clint Kalich
Avista Corporation
1411 East Mission Avenue - MSC-23
P.O. Box 3727
Spokane, Washington 99220-3727
Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
-- Email michael.andrea((avistacorp.com
clint. kalich((avistacorp .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
Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
-- Email daniel.solander((pacificorp.com
ted. weston((pacificorp.com
Bruce Griswold
PacifiCorp
825 NE Multnomah
Portland, Oregon 97232
Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
-- Email bruce.griswold((pacifiCorp.com
IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION TO JOINT UTILITIES - 16
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 27th 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"
15960 Vista Circle
Desert Hot Springs, California 92241
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
P.O. Box 1211
Welches, Oregon 97067-1211
Hand Delivered
-- U.S. Mail
_ Overnight Mail
FAX
-- Email peter((richardsonandolearv.com
greg((richardsonandoleary.com
Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
-- Email jcarkulis((exergydevelopment.com
Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
-- Email robertapauI08((gmail.com
Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
-- Email don.sturtevant((simplot.com
Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
-- Email rkahn((nippc.org
Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
-- Email nelson((thnelson.com
IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION TO JOINT UTILITIES -17
John R. Lowe, Consultant
Renewable Energy Coalition
12050 SW Tremont Street
Portland, Oregon 97225
Cedar Creek Wind, LLC, & Dynamis
Energy, LLC
Ronald L. Wiliams
WILLIAMS BRADBURY, P.C.
1015 West Hays Street
Boise, Idaho 83702
Cedar Creek Wind, LLC
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
Dynamis Energy, LLC
Wade Thomas, General Counsel
Dynamis Energy, LLC
776 East Riverside Drive, Suite 15
Eagle, Idaho 83616
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
Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
-- Email jravenesanmarcos((yahoo.com
Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
-- Email ron((willamsbradbury.com
Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
-- Email scott((westernenergy.us
Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
-- Email dzentz((summitpower.com
Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
-- Email wthomas((dynamisenergy.com
Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
-- Email glenni((EnvisionWind.com
Margaret((EnvisionWind .com
Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
-- Email greg((mimuralaw.com
IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION TO JOINT UTILITIES -18
Bil Piske, Manager
Interconnect Solar Development, LLC
1303 East Carter
Boise, Idaho 83706
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
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
Board of Commissioners of Adams
County, Idaho
Bil Brown, Chair
Board of Commissioners of
Adams County, Idaho
P.O. Box 48
Council, Idaho 83612
Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
-- Email bilpiske((cableone.net
Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
-- Email joe((mcdevitt-miler.com
Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
-- Email paulmartin((intermountainwind.com
Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
-- Email smd((idahowaters.com
Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
-- Email olmstead((tfcanal.com
Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
-- Email nscanal((cableone.net
Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
-- Email bdbrown((frontiernet.net
IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION TO JOINT UTILITIES - 19
Birch Power Company
Ted S. Sorenson, P.E.
Birch Power Company
5203 South 11 th East
Idaho Falls, Idaho 83404
Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
-- Email ted
IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION TO JOINT UTILITIES - 20