20110211IPC to NIPPC 55-66.pdf

HIIW~POR~
An IDACORP Company
DONOVAN E. WALKER
Lead Counsel
dwalkertãidahopower.com
February 11,2011
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 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 A VOIDED COST RA TE ELIGIBILITY CAP
Dear Ms. Jewell:
Enclosed for filng please find an original and three (3) copies of Idaho Power
Company's Response to the Fifth Production Request of the Northwest and Intermountain
Power Producers Coalition to the Joint Utilities in the above matter.
d:'fCl~
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]
dwalkercæidahopower.com
Inordstromcæidahopower.com
Attorneys for Idaho Power Company
Street Address for Express Mail:
1221 West Idaho Street
Boise, Idaho 83702
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ini I FEB , I PH f2: , 7
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE JOINT
PETITION OF IDAHO POWER
COMPANY, AVISTA CORPORATION,
ANDcPACIFICORP DBA ROCKY
MOUNTAIN POWERTOADDRESS
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 FIFTH
) PRODUCTION REQUEST OF THE
) NORTHWEST AND
) INTERMOUNTAIN POWER
) PRODUCERS COALITION TO THE
) JOINT UTILITIES
)
COMES NOW, Idaho Power Company ("Idaho Powet' or "Company"), and in
response to the Fifth Production Request of the Northwest and Intermountain Power
Producers Coalition to the Joint Utilties dated January 21, 2011, herewith submits the
following information:
'IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION REQUEST OF THE
NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION TO THE JOINT UTILITIES - 1
REQUEST NO. 55: Reference Dir. Test. of Bruce Griswold, p. 3, lines 7-9.
Please provide supporting documentation, with identities redacted to protect
confidentiality, of the "alternative offers which Rocky Mountain Power receives." For
each provided offer, please identify whether Rocky Mountain Power received the offer
through the RFP process or the IRP Methodology. Please also identify the location of
the offer, and costs necessary to transmit the power to loads for which Rocky Mountain
Power would otherwise serve with the Idaho QF projects discussed on page 8, lines 11-
18. If Rocky Mountain Power objects to providing a response to any component of this
request due to confidentiality concerns despite the protective agreement in this case,
please stil respond to the remaining components of the request.
RESPONSE TO REQUEST NO. 55: Answering hereto on behalf of Idaho Power
Company only, as this question is directed to Rocky Mountain Power, please see Rocky
Mountain Power's response to Northwest and Intermountain Power Producers
Coalition's ("NIPPC") Production Request No. 55.
The response to this Request was prepared by Donovan E. Walker, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION REQUEST OF THE
NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION TO THE JOINT UTILITIES - 2
REQUEST NO. 56: Reference Dir. Test. of Bruce Griswold, p. 3, lines 13-14.
(a) Please provide the most current documents or studies regarding the
maximum level of wind penetration Rocky Mountain Power can integrate. Please
include explanation of the maximum number of megawatts Rocky Mountain Power can
integrate.
(b) Please provide or identify with a website link, Rocky Mountain Powets
most recent wind integration study approved by the Idaho Commission.
(c) Please identify the upper limit of the level of wind penetration allowed for
in your wind integration study indentified in (b) of this request.
RESPONSE TO REQUEST NO. 56: Answering hereto on behalf of Idaho Power
Company only, as this question is directed to Rocky Mountain Power, please see Rocky
Mountain Powets response to NIPPC's Production Request No. 56.
The response to this Request was prepared by Donovan E. Walker, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION REQUEST OF THE
NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION TO THE JOINT UTILITIES - 3
REQUEST NO. 57: Reference Dir. Test. of Bruce Griswold, p. 4, lines 13-14.
What was the size (nameplate MW) of the single wind project bid into the RFP before
the developer applied for two 21.8 MW QF PPAs?
RESPONSE TO REQUEST NO. 57: Answering hereto on behalf of Idaho Power
Company only, as this question is directed to Rocky Mountain Power, please see Rocky
Mountain Power's response to NIPPC's Production Request No. 57.
The response to this Request was prepared by Donovan E. Walker, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION REQUEST OF THE
NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION TO THE JOINT UTILITIES - 4
REQUEST NO. 58: Reference Dir. Test. of Bruce Griswold, p. 5, lines 2-4.
What was the unsuccessful price bid into the RFP for a 151 MW project? What was the
price provided for two 78 MW QFs through the IRP Methodology? How does the IRP
Methodology price compare to the winning bid price in the RFP? If Rocky Mountain
Power objects to providing a response to any component of this request due to
confidentiality concerns despite the protective agreement in this case, please stil
respond to the remaining components of the request.
RESPONSE TO REQUEST NO. 58: Answering hereto ,on behalf of Idaho Power
Company only, as this question is directed to Rocky Mountain Power, please see Rocky
Mountain Powets response to NIPPC's Production Request No. 58.
The response to this Request was prepared by Donovan E.Walker, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION REQUEST OF THE
NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION TO THE JOINT UTILITIES - 5
REQUEST NO. 59: Reference Dir. Test. of Bruce Griswold, p. 5, lines 20-21.
Did the developer ever formally request a PPA for a second project? Please explain
what is meant by "discussing the option" to break the municipal waste project into two
separate QFs. Please explain how two municipal waste QFs could be commonly
owned and separated by one mile to "disaggregate" their project over 1 0 aMW and stil
comply with Commission orders.
RESPONSE TO REQUEST NO. 59: Answering hereto on behalf of Idaho Power
Company only, as this question is directed to Rocky Mountain Power, please see Rocky
Mountain Power's response to NIPPC's Production Request No. 59.
The response to this Request was prepared by Donovan E. Walker, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION REQUEST OF THE
NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION TO THE JOINT UTILITIES - 6
REQUEST NO. 60: Reference Dir. Test. of Bruce Griswold, p. 6, lines 12-13.
(a) Please explain for which load center(s) Rocky Mountain Power would use
the proposed Idaho QF projects described on page 8, lines 11-18.
(b) Please explain the annual load profile and the hourly load profiles for the
load center(s) described in (a). What is the "off-peak" period of the year and day for the
load center(s)? What is the "minimum load." Please provide supporting documents or
studies if available.
RESPONSE TO REQUEST NO. 60: Answering hereto on behalf of Idaho Power
Company only, as this question is directed to Rocky Mountain Power, please see Rocky
Mountain Power's response to NIPPC's Production Request No. 60.
The response to this Request was prepared by Donovan E. Walker, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION REQUEST OF THE
NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION TO THE JOINT UTILITIES - 7
REQUEST NO. 61: Reference Dir. Test. of Bruce Griswold, p. 7, line 1. Please
admit or deny that Rocky Mountain Powets Idaho PURPA PPAs give Rocky Mountain
Power the right to curtail a QF wind project if necessary to ensure system reliabilty. If
deny, please identify the Idaho PURPA PPA which does not allow for such curtailment.
RESPONSE TO REQUEST NO. 61: Answering hereto on behalf of Idaho Power
Company only, as this question is directed to Rocky Mountain Power, please see Rocky
Mountain Power's response to NIPPC's Production Request No. 61.
The response to this Request was prepared by Donovan E. Walker, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION REQUEST OF THE
NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION TO THE JOINT UTILITIES - 8
REQUEST NO. 62: Reference Dir. Test. of Bruce Griswold, p. 9, lines 2-7.
(a) Please provide the work papers supporting this calculation.
(b) Please admit or deny that, for one 78 MW project included in the
calculation of the $12 milion annual difference between IRP Methodology rates and
published rates, the developer has only requested IRP Methodology rates, and not
published rates. Please explain the basis for including this project in the calculation.
Does Rocky Mountain Power believe this project could be split into separate 10 aMW
projects and stil be a cumulative 78 MW project?
(c) Please provide the calculation without the 78 MW.project.
(d) Please explain why Rocky Mountain Power used the IRP Methodology
rates instead of rates bid into its RFPs adjusted for the cost to transmit the output to the
applicable load centers that would otherwise be served by the Idaho QF projects.
RESPONSE TO REQUEST NO. 62: Answering hereto on behalf of Idaho Power
Company only, as this question is directed to Rocky Mountain Power, please see Rocky
Mountain Powets response to NIPPC's Production Request No. 62.
The response to this Request was prepared by Donovan E. Walker, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION REQUEST OF THE
NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION TO THE JOINT UTILITIES - 9
REQUEST NO. 63: Reference Reply Comments of Idaho Power, p. 13, stating
"in researching the AURORA modeling capabilties, the softare provider has advised
that there may be some issues with the softare producing dependable results for
projects that are less that 2 MW." And "If the project is small enough that it does not
trigger changes in the base model operations, Le., it is lost in the rounding to MWs or
MWhs, then the base model results could be identical to the modeled results that
include the project. This would result in an AURORA pricing of zero."
(a) Please provide copies of all communications with the softare provider
that relates to the use of AURORA model for setting avoided cost rates including the
communication referenced above.
(b) Please provide all documents and studies including work papers used by
the softare provider regarding modeling for smaller projects.
(c) Please explain what is meant by "lost in rounding". Please quantify the
amount(s) that are lost in rounding and identify the rounding errors that are expected in
running the softare for projects that are 2 MW, 5 MWand 10 MW in size respectively.
(d) Please explain the circumstances by which the softare provider made
Idaho Power aware of the "issues" referenced in Idaho Power Reply Comments quoted
above. Include date(s) and please identify the individuals who were made aware of the
"issues."
(e) In light of AURORA's inabilty to estimate avoided cost rates for projects 2
MW and smaller, please explain whether Idaho Power now believes the AURORA
model is a reliable estimate of Idaho Powets avoided cost rates for projects greater that
2MW.
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION REQUEST OF THE
NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION TO THE JOINT UTILITIES - 10
(f) To Idaho Powets knowledge has the softare provider made the "issues"
with the model known to other utilty customers that use the AURORA model for setting
avoided cost rates? If so what other utilties were made aware of the "issues" and
please explain how Idaho Power learned that information.
(g) Please explain the circumstances that caused the softare provider to
begin the process of "researching the AURORA modeling capabilties." Was the
referenced research done at Idaho Powets request? If so what was the purpose of the
research? Please provide supporting documentation.
RESPONSE TO REQUEST NO. 63:
(a) The communication referenced above was a verbal communication via
telephone. No documents were exchanged and there are no "copies" of the
communications with the softare provider.
(b) No documents were provided by the softare provider.
(c) The initial concern and reference to "lost in rounding" was that a 100
kilowatt unit may not produce enough energy in relation to the larger, multiple megawatt
resources and units that are part of AURORA's analysis to enable AURORA to value
the smaller project such that there would be a measurable difference between the base
model results and the modeled results containing the project. Idaho Power had not
conducted avoided cost AURORA runs on projects of this size before, and disclosed
what Idaho Power was told by the softare provider upon its initial inquiry to them
regarding this issue at the time that reply comments were filed. As further disclosed at
the time of oral argument, subsequent to the filing of reply comments, Idaho Power had
further communications with Avista, who does have experience running AURORA for
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION REQUEST OF THE
NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION TO THE JOINT UTILITIES - 11
projects of this size, and Idaho Power made its own AURORA test run to verify that
AURORA does in fact work for projects of this size, and the results are not "lost in the
rounding."
(d) The circumstances by which the softare provider communicated the
information to Idaho Power that Idaho Power then disclosed in its Reply Comments
were that the softare provider responded to a telephone inquiry from an Idaho Power
Power Supply Analyst. The analyst from Idaho Power was Richard Pagoaga and the
call was on or about January 18, 2010.
(e) In Idaho Powets Reply Comments, Idaho Power does not state that
AURORA was unable to estimate avoided costs for smaller projects as suggested by
this question. As stated in the Company's Response to NIPPC's Production Request
No. 63(c) above, Idaho Power had not conducted avoided cost AURORA runs on
projects of this small size before, and disclosed what Idaho Power was told by the
softare provider upon its initial inquiry to them regarding this issue at the time that
reply comments were filed. As further disclosed at the time of oral argument,
subsequent to the filng of reply comments, Idaho Power had further communications
with Avista, who does have experience running AURORA for projects of this size, and
Idaho Power made its own AURORA test run to verify that AURORA does in fact work
for projects of this size. Idaho Power is confident that the AURORA model can be used
to produce avoided cost values for small projects. For projects of any size, Idaho Power
continues to be confident that the AURORA model provides a reliable estimate of Idaho
Power's avoided costs in the IRP-based avoided cost methodology previously approved
by the Idaho Public Utilties Commission ("Commission") and, further, that it is a much
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION REQUEST OF THE
NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION TO THE JOINT UTILITIES - 12
better methodology than the Surrogate Avoided Cost methodology for establishing the
Company's avoided cost for PURPA.
(f) Idaho Pôwer has no knowledge as to the softare providets discussions
or communications with other parties.
(g) The reference to "researching the AURORA modeling capabilties" in
Idaho Power's Reply Comments was meant to refer to Idaho Powets inquiry, or
research, into AURORA's capabilities, and not the softare providers "research." As
stated above, Idaho Power made an inquiry of the softare provider as to the ability of
AURORA to produce reasonable results for small projects. The softare provider
responded to this inquiry in a phone conversation. No documentation was provided.
The response to this Request was prepared by Randy C. Allphin, Senior Energy
Contracts Coordinator, Idaho Power Company, in consultation with Donovan E. Walker,
Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION REQUEST OF THE
NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION TO THE JOINT UTILITIES -13
REQUEST NO. 64: Reference Reply Comments of Idaho Power, p. 13, stating
"in researching the AURORA modeling capabilties, the softare provider has advised
that there may be some issues with the softare producing dependable results for
projects that are less that 2 MW." And "If the project is small enough that it does not
trigger changes in the base model operations, Le., it is lost in the rounding to MWs or
MWhs, then the base model results could be identical to the modeled results that
include the project. This would result in an AURORA pricing of zero."
(a) Did Avista know about the "issues" referenced above?
(b) If the answer to (a) above is yes, please explain the circumstances
surrounding its learning of the identified issues. Please provide copies of all
communications regarding the "issues" between the softare provider (or other entity)
and Avista, and please explain the circumstances by which the softare provider (or
other entity) made Avista aware of the "issues" referenced in Idaho Power Reply
Comments quoted above. Include date(s) and please identify the individuals who were
made aware of the "issues."
(c) If the answer to (a) above is yes, please explain why Avista did not inform
the Commission of the referenced "issues."
(d) If the answer to (a) above is no, then in light of Idaho Powets admission
that AURORA is incapable of estimating avoided cost rates for projects 2 MW and
smaller, please explain whether Avista now believes the AURORA model is a reliable
estimate of Avista's avoided cost rates for projects greater than 2 MW and please
document how Avista came to that belief.
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION REQUEST OF THE
NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION TO THE JOINT UTILITIES - 14
(e) Please provide all communications between AURORA and any entity
related to AURORA and Avista dealing with AURORA's capabilties in setting avoided
cost rates.
RESPONSE TO REQUEST NO. 64: Answering hereto on behalf of Idaho Power
Company only, as this question is directed to Avista, please see Avista's response to
NIPPC's Production Request No. 64.
The response to this Request was prepared by Donovan E. Walker, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION REQUEST OF THE
NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION TO THE JOINT UTILITIES -15
REQUEST NO. 65: Reference Reply Comments of Idaho Power, p. 13, stating
"in researching the AURORA modeling capabilties, the softare provider has advised
that there may be some issues with the softare producing dependable results for
projects that are less that 2 MW." And "If the project is small enough that it does not
trigger changes in the base model operations, Le., it is lost in the rounding to MWs or
MWhs, then the base model results could be identical to the modeled results that
include the project. This would result in an AURORA pricing of zero."
(a) Has Rocky Mountain Power investigated its Grid Model to determine if it
suffers from the same infirmities as the AURORA model? If yes, please explain under
what circumstances the investigation took place and provide copies of the results with
supporting work papers. If no, then in light of Idaho Powets admission that AURORA is
incapable of calculating avoided cost rates for smaller projects, whether Rocky
Mountain Power plans to conduct such an investigation and provide the time line for the
same.
(b) In light of Idaho Powets admission regarding the infirmities with AURORA
please explain why the Idaho Commission should have continued confidence in the Grid
Model as an accurate measure of avoided cost rates.
RESPONSE TO REQUEST NO. 65: Answering hereto on behalf of Idaho Power
Company only, as this question is directed to Rocky Mountain Power, please see Rocky
Mountain Powets response to NIPPC's Production Request No. 65.
The response to this Request was prepared by Donovan E. Walker, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION REQUEST OF THE
NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION TO THE JOINT UTILITIES - 16
REQUEST NO. 66: Reference Idaho Powets Reply Comments at p. 8, stating,
''Thus, this Commission has both the statutory authority and well-established precedent
from the state and federal judiciary to invoke the Commission's authority to annul,
supersede, or reform contracts with public utilties so that the public interest is served."
And at p. 7, stating, "to invoke and authorize the Commission - in the exercise of its
legislative, state police power and authority to protect the public in the contractual rates
that it sets and the public utilty contracts that it reviews for the purchase of energy from
QF projects under PURPA"
(a) Does Idaho Power intend to ask the Commission to annul, supersede or
reform any contracts it has executed with a PURPA developer?
(b) If the answer to (e) (sic) is yes, please identify each such contract Idaho
Power wil seek to have annulled or superseded. For each contract Idaho Power wil
seek to have reformed please identify said contract and the manner in which Idaho
Power wil seek to have it reformed.
RESPONSE TO REQUEST NO. 66:
(a) No. Idaho Power intends to ask the Commission to review,each contract
that it executes with PURPA qualifying facilties ("QF"). Idaho Power has historically
filed, and wil continue to file, each contract that it executes with a PURPA QF with the
Commission for its review, as such contracts are not effective, and are not valid,
enforceable contracts unless and unti the Commission approves all terms and
provisions therein without change or condition, and declares that all payments to be
made to the PURPA QF thereunder shall be allowed as prudently incurred expenses for
ratemaking purposes.
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION REQUEST OF THE
NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION TOTHE JOINT UTILITIES -17
(b) Not applicable.
The response to this Request was prepared by Donovan E. Walker, Lead
Counsel, Idaho Power Company.
DATED at Boise, Idaho, this 11th day of February 2011.
NOVAN E. W LKER
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION REQUEST OF THE
NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION TO THE JOINT UTILITIES -18
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 11 th day of February 2011 I served a true and
correct copy of the IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH
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 A. Sasser
Deputy Attorneys General
Idaho Public Utilties Commission
472 West Washington
P.O. Box 83720
Boise, Idaho 83720-0074
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~ Email don.howeiicæpuc.idaho.gov
kris.sassercæpuc. 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
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~ Email michael.andreacæavistacorp.com
c1int.kalichcæavistacorp.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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~ Email daniel.solandercæpacificorp.com
ted. westoncæpacificorp.com
Kenneth Kaufmann
LOVINGER KAUFMANN, LLP
825 NE Multnomah, Suite 925
Portland, Oregon 97232
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~ Email kaufmanncælklaw.com
Bruce Griswold
PacifiCorp
825 NE Multnomah
Portland, Oregon 97232
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~ Email bruce.griswoldcæpacifiCorp.com
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION REQUEST OF THE
NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION TO THE JOINT UTILITIES - 19
Exergy, Grand View Solar, J. R. Simplot,
Northwest and Intermountain Power
Producers Coalition, & Board of
Commissioners of Adams County, Idaho
Peter J. Richardson
Gregory M. Adams
RICHARDSON & O'LEARY, PLLC
515 North 2¡th 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 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
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~ Email peter(Çrichardsonandoleary.com
greg(Çrichardsonandoleary.com
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~ Email jcarkulis(Çexergydevelopment.com
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~ Email robertapaul08(Çgmail.com
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~ Email don.sturtevant(Çsimplot.com
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~ Email rkahn(Çnippc.org
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~ Email nelson(Çthnelson.com
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION REQUEST OF THE
NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION TO THE JOINT UTILITIES - 20
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
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~ Email scott(Çwesternenergy.us
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~ Email dzentz(Çsummitpower.com
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~ Email wthomas(Çdynamisenergy.com
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~ Email glenni(ÇEnvisionWind.com
Margaret(ÇEnvisionWind .com
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~ Email greg(Çmimuralaw.com
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION REQUEST OF THE
NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION TO THE JOINT UTILITIES - 21
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(Çcableone.net
Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
~ Email joe(Çmcdevitt-miler.com
Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
~ Email paulmartin(Çintermountainwind.com
Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
~ Email smd(Çidahowaters.com
Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
~ Email olmstead(Çtfcanal.com
Hand Delivered
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_ Overnight Mail
FAX
~ Email nscanal(Çcableone.net
Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
~ Email bdbrown(Çfrontiernet.net
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION REQUEST OF THE
NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION TO THE JOINT UTILITIES - 22
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(Çtsorenson.net
Blue Ribbon Energy LLC
M. J. Humphries
Blue Ribbon Energy LLC
4515 South Ammon Road
Ammon, Idaho 83406
Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
~ Email blueribbonenergy(Çgmail.com
Arron F. Jepson
Blue Ribbon Energy LLC
10660 South 540 East
Sandy, Utah 84070
Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
~ Email arronesg(Çaol.com
~7WCcDonovan E. Walker
IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION REQUEST OF THE
NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION TO THE JOINT UTILITIES - 23