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HomeMy WebLinkAbout20120320Exergy 8-40 to IPC.pdf,1', Peter J. Richardson Gregory M. Adams Richardson & O'Lear, PLLC 515 N. 27th Street P.O. Box 7218 Boise, Idaho 83702 Telephone: (208) 938-7901 Fax: (208) 938-7904 peter~chardsonandolear.com gregc$richardsonandolear.com RECE iUI2 KAR 20 PH 4: 08 Attorneys for Exergy Development Group of Idaho, LLC BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE COMMISSION'S ) REVIEW OF PURP A QFCONTRACT ) PROVISIONS INCLUDING THE ) SURROGATE AVOIDED RESOURCE ) PLANING (IRP) METHODOLOGIES FOR ) CALCULATING PUBLISHED AVOIDED ) COST RATES ) ) CASE NO. GNR-E-II-03 SECOND PRODUCTION REQUEST OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY Pursuant to Rule 225 of the Rules of Procedure of the Idaho Public Utilties Commission (the "Commssion"), Exergy Development Group of Idaho, LLC hereby requests that Idaho Power Company ("Idaho Power" or "Company") provide responses to the following with supporting documents, where applicable, as soon as possible, but no later than April 10, 2012. This production request is to be considered as continuing, and Idaho Power is requested to provide by way of supplementa responses additional documents that it or any person acting on its behalf may later obtain that will augment the responses or documents produced. Please provide one physical copy of your responses to the address above, and electronic copies, if available, to Mr. Richardson and Mr. Adams at the addresses noted above, and one , ' copy to Dr. Reading at 6070 Hil Road, Boise, Idaho 83703. Please provide Dr. Reading's copy in electronic format, if available, to dreading~dsprig.com. Please begin each response on a separate page and provide page numbers on responses longer than one page. For each item, please indicate the name of the person(s) preparng the answers, along with the job title of such person(s) and the witness at hearing who can sponsor the answer. REQUEST FOR PRODUCTION NO.8: For the PowerPoint presentation the Company made at the meeting to present and discuss IRP Models at the Idaho Public Utilties Commssion on December l5, 2011, and attached as Exhibit No.3, to Mark Stokes's Direct Testimony, please provide all work papers, spreadsheets in electronic format with formulas intact, and model outputs used in producing Exhbit 3. REQUEST FOR PRODUCTION NO.9: Reference the four QF confgurations analyzed in Exhibit NO.3 of Mark Stokes's Direct Testimony. Please list for each of Company's gas-fired generation plants the anual capacity factor, by year, beginning in 2013 through the end of the 20 year analysis period. REQUEST FOR PRODUCTION NO. 10: Reference the Company's 2011 IRP's near-term action plan milestones (Table 1.2, p. 8), stating plans to secure an 83 MW PPA for the sumer of2015 from the east side. Please provide the prices the Company would offer a QF (at 80 MW) that would provide power in the same configuration sought by Idaho Power. REQUEST FOR PRODUCTION NO. 11: According to the Commission's accepted "IRP Methodology' (IPUC Order No. 26576, IPC-E- 95-9) and IPUC Staff Witness Rick Sterling's direct testimony Exhbit LOL, "the avoided cost of the QF project is the difference in the present value of the revenue requirements (PVRR) between the base case resource plan and a modified resource plan that includes the QF resource." (Exhbit 101, IPC-E-95-9, R. Sterling, page l4.) Under the existing IRP Methodology in place on the date of this request, please explain in detail how the Company incorporates the "revenue requiement" as it would in filing for a certificate of public convenience and necessity (CPCN, i.e. retur of and on investment, all taes, etc.), in the calculation of rates offered in contracts to QFs. Page 2 - SECOND PRODUCTION REQUEST OF EXERGY TO IDAHO POWER- GNR-E-II-03 REQUEST FOR PRODUCTION NO. 12: Reference the Direct Testimony of Tessia Park, p 18, discussing the Company's proposed Tarff Schedule 74 (Exhbit No.5). (a) Please identify the provision ofIdaho Power's proposed Tarff Schedule 74 that would compensate QFs for curailments occuring without providing the required notice, or where the basis for the curailment was not supported by the circumstances described in 18 C.F.R. § 292.304(t). Ifno such provision is included, please explain why. (b) Please explain Idaho Power's basis for only proposing to provide QFs one-hour notice prior to such curailments. Is Idaho Power aware of any FERC or state commission order that has authorized advance notice of one hour or less to QFs in implementing 18 C.F.R. § 292.304(t)? (c) Does Idaho Power believe that it has the right to curtail QFs to under 18 C.F.R. 292.304(t) even when the applicable QF contract provides for no such curailment? If so, please explain the basis for this position. REQUEST FOR PRODUCTION NO. 13: Reference the Direct Testimony of Tessia Park, p. 11, stating, "Based upon the curent price of natural gas, dispatch costs of Langley Gulch will be approximately $22." (a) What is the curent price of gas used to calculate the $22 Langley Gulch dispatch cost? (b) What is the price of gas Idaho Power expects to pay when Langley Gulch comes on line the sumer of2012, and the expected dispatch cost at that gas price? (c) What price of gas does Idaho Power expect to pay for Langley Gulch, and what is the associated expected dispatch cost anualy over the next 20 years? (d) What is the fixed cost of Langley Gulch in $/MWh? What is the fixed cost of a QF to the Company? REQUEST FOR PRODUCTION NO. 14: Reference the Direct Testimony of Tessia Park, pp. 11-12, stating, "For example, the Company curently pays in the range of low-$50 per MWh up to $85 or more per MWh for PURP A generation." Please provide the rate ($/MWh) curently paid by Idaho Power, in electronic format, to its on-line PURPA projects. REQUEST FOR PRODUCTION NO. 15: Reference the Direct Testimony of Tessia Park, p. 23, stating, "The following example is based upon an actual generation day in October 2011." Please provide in electronic format: Page 3 - SECOND PRODUCTION REQUEST OF EXERGY TO IDAHO POWER - GNR-E- 1 1-03 (a) The date of the referenced day in the example, (b) The hourly (or less) load profile for the day, (c) The hourly (or less) output of each of the resources used to meet the load for the day, (d) The dispatch cost of each of the resources used to meet the load for the day, (e) The heavy load cost of purchase power for the day, (t) The cost of gas peakg unts, if they were to be used, for the day. REQUEST FOR PRODUCTION NO. 16: Reference the Direct Testimony of Tessia Park, p. 23, stating, "The Company is proposing to apply this policy to all PURP A contracts, both existing and new, that are projects which contain generator output control limiters ("GOCLs") and are 1 0 MW or larger in size." Please provide a list of all existing PUR A projects and identify those that have "GOCLs" and those that do not. REQUEST FOR PRODUCTION NO. 17: Reference the Direct Testimony of Tessia Park, p. 7, stating, the "limiting conditions on the amount of variable generation from PURP A resources which Idaho Power can accommodate are not apparent during periods of relatively high customer demand." (a) Please defie "relatively high customer demand" as used in ths statement. (b) Please estimate the level of demand at which Idao Power believes there wil be no limiting conditions for existing and contracted QFs. (c) For the years 2010 and 2011, please provide the hours and days of the year that Idaho Power's load fell below the level described in item (b). REQUEST FOR PRODUCTION NO. 18: Reference the Direct Testimony of Tessia Park, p. 14, stating, "Idaho Power has been working on an update to its wind integration study for some time. However, difficulties in modeling Idaho Power's electrcal system and generation resources in the model used by the consultat hired to pedorm the study, have delayed the completion of the study." (a) Please describe the modeling errors referenced. (b) Please provide any correspondence between Idaho Power and the consultant describing the modeling errors. REQUEST FOR PRODUCTION NO. 19: Reference the Direct Testimony of Tessia Park, p. 20, stating, "Pursuant to FERC licenses Idaho Power has for its ru-of-river hydro electrc projects, the Company is obligated to take whatever Page 4 - SECOND PRODUCTION REQUEST OF EXERGY TO IDAHO POWER - GNR-E-11-03 generation flows through them; it does not have the abilty to decrease or increase the generation. " (a) Please identify each of the ru-of-river hydro plants and provide the capacity of each. (b) Please provide the FERC license for each project (in electronic format if available). (c) Please identify the provision (page number, section number, as applicable) in each FERC license that Idaho Power relies on to determine it does not have the abilty to decrease or increase the generation. (d) For each plant, please explain whether the plant has the operational capability to spil water without generating electrcity, and any restrctions on Idaho Power's abilty to do so. REQUEST FOR PRODUCTION NO. 20: Reference the Direct Testimony of Tessia Park, p. 23, stating, "the Company must maintain constat flows below Hells Canyon da for environmental compliance, thus limiting the abilty to curl generation out ofthe Hells Canyon Complex to no less than approximately 350 MW." (a) Please identify the individual plants/dams at the Hells Canyon Complex and the MW capacity of each. (b) Please explain the environmental compliance requirement for each that limits the abilty to curil generation and provide the minimum generation of each individual project. Please identify the governent agency imposing the compliance requirement. (c) For each plant, please explain whether the plant has the operational capabilty to spil water without generating electricity. Please explain why generation canot be curailed to 0 MW by spiling, or to any cumulative output below 350 MW for the Complex. REQUEST FOR PRODUCTION NO. 21: Reference the Direct Testimony of Tessia Park, p. 1, stating dispatch costs for the Company's coal units are approximately $30/MWh and for Langley Gulch are $22/MWh. (a) Please explain why the Company would not tae its coal plants offine and instead ru Langley Gulch during times when it expects to have light loading periods. (b) For Langley Gulch, the ru-of-river hydro projects, and the Hells Canyon Complex, please provide the minimum and maximum output for each that Idaho Power could reasonably expect to obtain durng periods of the year that Idaho Power expects to experience light loading events. Please explain the basis for the estimates for each category. Page 5 - SECOND PRODUCTION REQUEST OF EXERGY TO IDAHO POWER - GNR-E-II-03 REQUEST FOR PRODUCTION NO. 22: Reference the Direct Testimony of Tessia Park, p. 24, describing conditions where the Company has sufficient base load generation to service 1,100 MW of load. (a) For the years 2010 and 2011, please provide the hours and days of the year that Idaho Power's load was at or below 1,100 MW. (b) Please provide the number of hours, days, weeks, or months in advance that Idao Power can accurately predict that reachig loads ths low will occur. (c) For each such occurence, please provide the maximum load within the 7 days following the light loading event. REQUEST FOR PRODUCTION NO. 23: Reference the Direct Testimony of Tessia Park, p. 24, describing the minimum base generation (300 MW thermal, 817 MW hydro, and 50 MW non-intermittent PURP A) to be near 1,100 MW. Please explain why Idaho Power could not plan for an expected light loading period coinciding with possible excess QF generation by un-designating the network resource status of a specified quantity of this base generation, and using its fast-ramping, remaining Hells Canyon capacity to serve load in the event that intermittent QF generation did not occur as predicted. REQUEST FOR PRODUCTION NO. 24: Reference the Direct Testimony of Mark Stokes, p. 7, presenting a figue titled "Idaho Power Compared to Regional RPS Stadards." (a) Please explain which state or proposed federal RPS or RES standard Idaho Power used to determe whether the generation from the QFs included in the graph would quaify under the applicable standad. (b) Please provide Idaho Power's work papers used to generate the 19% RPS compliant generation figue. (c) Please list generation facilties that comprise the 19% RPS compliant generation, including their generation tye for each (wind, small hydropower, cogeneration, etc.), nameplate capacity, assumed anual generation, and whether the Company will receive any REC's from the QF. REQUEST FOR PRODUCTION NO. 25: Reference the Direct Testimony of Mark Stokes, p. 14, "Because a vast majority ofthe new PURP A contracts are for wind projects, Idaho Power will stil have to build new resources in order to meet projected growth in peak-hour demand." Please indicate the new resources, by type of resource, the Company assumes it will need to build, and the year it expects to need these resources. Page 6 - SECOND PRODUCTION REQUEST OF EXERGY TO IDAHO POWER - GNR-E-11-03 , , REQUEST FOR PRODUCTION NO. 25: Reference the Direct Testimony of Mark Stokes, p. 16, presenting a figure titled "Average PURPA Price Compared to Mid-C Index, 2002-2022." (a) Please provide the average anual energy cost and capacity cost ($/MWh) of each of the Company's thermal resources (Bridger, Valmy, Boardman, Danskin, Bennett Mountan, and Langley Gulch) over the same time frame. (b) Please provide the figues for the average Mid-C Index compared and the PURP A Price from 1980 to 2002, or as far back as available. Please also include the energy and capacity costs for the coal plants listed in item (a) for years where those are available prior to 2002. (c) Is the Mid-C Index price used in the figure a spot market price or the price of firm power? If it is a spot price, please provide an estimate in the difference in cost ($/MWh) of the Average Mid-C Index and the cost to secure firm market purchases from Mid-C, and explain the basis for the estimate. REQUEST FOR PRODUCTION NO. 26: Reference the Direct Testimony of Mark Stokes, p. 18, describing the differential between what Idaho Power will pay for PURPA generation in 2012 and the amount it would pay to purchase the same amount of generation as a "firm" product in the Mid-C market. (a) Please provide a detailed definition and an example of a "firm" product, including the maximum term (years and months) for which Idaho Power could secure a firm market purchase in 2012. Does this cost include the cost of firm transmission from Mid-C to Idaho Power's system? (b) Please estimate the amount of firm transmission (MW) Idaho Power possesses or could secure from Mid-C to Idaho Power's loads. (b) Using the same figures for the cost of firm market product used in the testimony, please provide the differential for the cost for Langley Gulch (including all varable and fixed costs passed onto customers through rates) for each year from 2012 to 2021, in dollars and in $/MWh. Please prorate the costs of market purchases for 2012 to account for the date Idaho Power estimates Langley Gulch costs will be incured by customers in that year. (c) Please provide a detaled explanation of the assumptions used in the calculation in the testimony and in the calculations in response to this request. REQUEST FOR PRODUCTION NO. 27: Reference the Direct Testimony of Mark Stokes, p. 21, stating, "There are several times when QF generation has and wil generate at or close to nameplate capacity. For example, on December 21,2011,. . . . Idaho Power received 7,028 MWh (293a aMW) from the 20 PURPA Page 7 - SECOND PRODUCTION REQUEST OF EXERGY TO IDAHO POWER - GNR-E-II-03 . . wind projects on-line (nameplate rating of398 MW)." Please provide the same figues and date where wind QFs have generated closest to nameplate capacity. REQUEST FOR PRODUCTION NO. 28: Reference the Direct Testimony of Mark Stokes, p. 21, comparng the cost of wind QF output on December 21,2011 to the cost of the short-term, daily average Mid-C market price. (a) Please provide the MWh output and capacity factors for each of the Company's thermal unts on December 21, 2011. (b) Please provide the MWh cost, including both energy and capacity of the Company's thermal resources on December 21, 2011. (c) Please provide the long-term, firm Mid-C market price for the same date, and please add to the cost for firm transmission from Mid-C to Idaho Power's system. Please explain any assumption used in providing these costs. REQUEST FOR PRODUCTION NO. 29: Reference the Direct Testimony of Mark Stokes, p. 39, stating, "The estimated 20-year, levelized cost of Langley Gulch is $68.55 per MWh using a 90 percent capacity factor assumption (to be consistent with the SAR capacity factor assumption), and Idaho Power's curent natual gas price forecast. " (a) Please provide work papers and all cost assumptions for the $68.55 per MWh figue for Langley Gulch, including interconnection and transmission costs, gas price and transportation/storage costs, heat rate, assumed heat rate degradation, equivalent availabilty factor, capital cost, varable O&M, fixed O&M, O&M escalation rates, and inflation, as well as any other cost assumptions. Please provide the basis for each assumption for each of the listed items. (b) Please provide the levelized $/MWh cost of Langley Gulch for both energy and capacity at the 84% capacity the Company expects the facility will have available for planng puroses. Reference IPUC Order 30392, p. 17. (c) Please provide the levelized $/MWh cost of Langley Gulch for both energy and capacity at the 20 year average 49% capacity factor provided in Karl Bokenkamp's Direct Testimony, p. 23. (d) Please explain ifIdaho Power wil commit to pass onto its customers a 20-year levelized cost for Langley Gulch that will not exceed the estimates above (allowing for adjustment to customers' rates only to account for different capacity factors). REQUEST FOR PRODUCTION NO. 30: Please provide all of the curent assumptions for the gas SAR model for all inputs used to generate the 20-year levelized, non-fueled, published avoided cost rate of $70.92 per MWh, discussed in Mr. Stokes' Direct Testimony, p. 39. Page 8 - SECOND PRODUCTION REQUEST OF EXERGY TO IDAHO POWER- GNR-E-11-03 REQUEST FOR PRODUCTION NO. 31: Reference the Direct Testimony of Mark Stokes, p. 32, lines 5-8. . Please provide the solar integration study relied upon by Idaho Power. If no such study exists, please explain the basis for the assumptions regarding solar integration, and steps the Company plans to take to accurately compute that alleged cost. REQUEST FOR PRODUCTION NO. 32: Reference the Direct Testimony of Mark Stokes, p. 45, recommending implementation of "a PURP A QF contraction process and negotiation tarff schedule." Please provide Idaho Power's proposed negotiation tariff. If no proposed taff exists, please describe the procedures Idaho Power recommends, and when Idaho Power plans to file the taff. REQUEST FOR PRODUCTION NO. 33: Reference the Direct Testimony of Karl Bokenkamp, p. 25, describing Idaho Power's proposed assumption that each thermal unit will assigned an incremental cost based on full load operation. (a) Is it true that when a thermal unit is operated at less than full load that the incremental cost per MWh increases? (b) For each of the Company's thermal unts, please provide: (1) heat rate at maximum output, (2) heat rate at minimum operating output, (3) incrementa energy cost at the heat rate in (1) and (2). (c) For each ofthe Company's thermal units, please provide the number of hours per year in the years 2008 through 2011 that the unit operated at ful load operation. REQUEST FOR PRODUCTION NO. 34: Reference the Direct Testimony of Karl Bokenkamp, p. 15, stating, "As an example, out of a total of 157,776 hours in an AURORA simulation for a 22 megawatt ("MW") wind project, the new methodology assigned an avoided cost of $O/MWh in 1,563 hours. This works out to about 1 percent of the time, or 87 hours per year." Please provide the complete AURORA output from this simulation ru along with a full explanation of the how the new methodology is implemented. REQUEST FOR PRODUCTION NO. 35: Reference the Direct Testimony of Karl Bokenkamp, p. 15, stating, Idaho Power can look at several different hypothetical cases to ilustrate how the methodology wil assign incremental costs. For example, in case 1 load is 2,000 MW, the system is balanced, Idaho Power has one or more thermal unts in operation, and there are Page 9 - SECOND PRODUCTION REQUEST OF EXERGY TO IDAHO POWER - GNR-E-I1-03 no purchases; in case 2, identical conditions exist with the following exception, a "new" QF generates and delivers one MWh of energy to Idaho Power's system. One of two thngs must happen for the system to remai balanced either Idaho Power's resources must reduce output by one MWh or one MWh is sold into the market. Please provide the complete AURORA outputs from the case 1 and case 2 rus along with a ful explanation of the how the new methodology is implemented to produce the values reported for each case in Mr. Bokenkamp's testimony. REQUEST FOR PRODUCTION NO. 36: Reference the Direct Testimony of Karl Bokenkamp, p. 24, proposing to continue using the peak-hour capacity factor calculation that is curently utilzed. Please explain fully the "peak- hour capacity factor" and demonstrate how it is used in the calculation of avoided costs. REQUEST FOR PRODUCTION NO. 37: Reference the Direct Testimony of Karl Bokenkamp, p. 29, "Idaho Power proposes that any QFs with signed contracts and any 'queued' QFs be included in Idaho Power's resource portfolio for puroses of calculating futue avoided costs because they can impact futue avoided costs. For puroses of calculating avoided costs, Idaho Power proposes that upon its receipt of a wrtten request from a QF for contract pricing, the QF is designated as 'queued.''' (a) For the years 2008 through 2012, please identify the QFs from whom Idaho Power has received a written request for contract pricing with IRP methodology rates (using numbers or other identifiers to preserve confdentiality if necessar). (b) For each of the projects listed in response to (a), please provide the date of the request for pricing, and whether the QF executed a PPA with Idaho Power for the project, and whether the IPUC has approved the PPA for which pricing was requested. REQUEST FOR PRODUCTION NO. 38: Reference the Direct Testimony of Karl Bokenkamp, pp. 12-13, discussing Idaho Power's proposal to include Longer-term firm purchases such as the PPL EnergyPlus Power Purchase Contract in the IRP Methodology calculations as a must ru resource. Please identify each ofthe Longer-term firm purchases, and for each please provide: (a) Quantify of energy supplied to Idaho Power; (b) Term; (c) The basis to assume that the resource is "must ru," with explanation of applicable contractul requirements. Page 10 - SECOND PRODUCTION REQUEST OF EXERGY TO IDAHO POWER - GNR-E-I1-03 REQUEST FOR PRODUCTION NO. 39: Reference the Direct Testimony of Karl Bokenkamp, p. 22, proposing that an SCCT replace a CCCT for purposes of calculating the capacity component of the IRP Methodology calculation. (a) For the years 2008 through 2011, please provide the number of days per year that Idaho Power operated its gas peakers (Bennett Mountain or Danskin) to meet load. (b) Please provide the number of days per year that Idaho Power forecasts to use Langley Gulch to meet load requirements, as assumed in Idaho Power's load and resource balance from its IRP. REQUEST FOR PRODUCTION NO. 40: Reference the Direct Testimony of Karl Bokenkamp, p. 21, describing Idaho Power's proposed IRP Methodology's focus on the incremental cost from Idaho Power's generating resources. (a) Is Idaho Power proposing to not consider projected market prices as the possible next incremental unit used to meet load in its IRP Methodology? (b) Please provide the number of days per year that Idaho Power engaged in market purchases in 2009,2010, and 2011. DATED:March 20,2012 QJ Peter J. Richardson Gregory M. Adams RICHARDSON & O'LEARY PLLC Page 11 - SECOND PRODUCTION REQUEST OF EXERGY TO IDAHO POWER-GNR-E-11-03 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 20th day of March, 2012, a tre and correct copy of the within and foregoing SECOND PRODUCTION REQUESTS OF EXERGY DEVELOPMENT GROUP OF IDAHO, LLC. TO IDAHO POWER COMPANY was served as shown to: Jean D. Jewell, Secreta Idaho Public Utilties Commission 472 West Washington Boise, Idaho 83702 iean.jewellc$puc.idaho. gov X. Hand Delivery _U.S. Mail, postage pre-paid Facsimile X Electronic Mail Donald Howell Krs Sasser Idaho Public Utilities Commission 472 West Washington Boise, Idaho 83702 donald.howellc$puc.idaho.gov krsine.sasserc$puc.idaho. gov X. Hand Delivery _U.S. Mail, postage pre-paid Facsimile -X Electronic Mail Donovan E. Walker Lisa D. Nordstrom Idaho Powe Company POBox 70 Boise, ID 83707-0070 dwalkerc$idahopower.com lnordstromc$idahopower.com _ Hand Delivery _U.S. Mail, postage pre-paid Facsimile -X Electronic Mail Michael G. Andrea Avista Corporation P.O. Box 3727 Spokane, W A 99220 michael. andreac$avistacorp. com _ Hand Delivery _U.S. Mail, postage pre-paid Facsimile -X Electronic Mail Electronic Copies Only: Ken Kaufman Lovinger Kaufan LLP 825 NE Multnomah Ste 925 Portland, OR 97232 Kaufanc$lklaw.com _ Hand Delivery _U.S. Mail, postage pre-paid Facsimile -X Electronic Mail Daniel So lander PacifiCorp/dba Rocky Mountain Power 201 S Mai St Ste 2300 Salt Lake City, UT 84111 danel.solanderc$pacificorp.com _ Hand Delivery _U.S. Mail, postage pre-paid Facsimile -X Electronic Mail Dean J. Miler McDevitt & Miler, LLP 420 W. Banock St. Boise, ID 83702 joetßcdevitt-miler .com _ Hand Delivery _U.S. Mail, postage pre-paid Facsimile -X Electronic Mail Thomas H. Nelson Renewable Energy Coalition PO Box 1211 Welches, OR 97067-1211 nelsonc$thelson.com _ Hand Delivery _U.S. Mail, postage pre-paid Facsimile -X Electronic Mail JohnR. Lowe Consultat Renewable Energy Coalition 12050 SW Tremont St Portland, OR 97225 j ravenesanarosc$yahoo. com _ Hand Delivery _U.S. Mail, postage pre-paid Facsimile -X Electronic Mail R. Greg Ferney Mimura Law Offices PLLC Interconnect Solar Development, LLC 2176 E Franin Rd Ste 120 Meridian, ID 83642 gre gtßimuralaw. com _ Hand Delivery _U.S. Mail, postage pre-paid Facsimile -X Electronic Mail Bil Piske, Manager Interconnect Solar Development, LLC 1303 E. Carer Boise, ID 83706 bilpiskec$cableone.net _ Hand Delivery _U.S. Mail, postage pre-paid Facsimile -X Electronic Mail Ronald L. Willams Wiliams Bradbur, PC 1015 W. Hays Street Boise, ID 83702 ronc$willamsbradbur.com _ Hand Delivery _U.S. Mail, postage pre-paid Facsimile -X Electronic Mail Wade Thomas General Counsel Dynamis Energy, LLC 776 W. Riverside Dr., Ste 15 Eagle, ID 83616 wtomasc$dynamisenergy.com _ Hand Delivery _U.S. Mail, postage pre-paid Facsimile -X Electronic Mail Shelley M. Davis Barker Rosholt & Simpson LLP 1010W. Jefferson St (83702) PO Box 2139 Boise, ID 83701 smdc$idahowaters.com Brian Olmstead General Manager Twin Falls Canal Company PO Box 326 Twin Falls, ID 83303 olmsteadc$tfcanal.com Robert A. Paul Grand View Solar II 15690 Vista Circle Desert Hot Springs, CA 92241 robertpaul08c$gmail.com James Carkuis Exergy Development Group of Idaho, LLC 802 W. Banock, Ste 1200 Boise, ID 83702 j carkulisc$exergydevelopment.com Arron F. Jepson Blue Ribbon Energy, LLC 10660 South 540 East Sandy, UT 84070 aronesgc$aol.com M.J. Humphres Blue Ribbon Energy, LLC 4515 S. Amon Rd. Amon, ID 83406 blueribbonenergyc$gmail.com Ted Diehl General Manager Nort Side Canal Company 921 N. Lincoln St. Jerome, il 83338 nscanal~cableone.net _ Hand Delivery _U.S. Mail, postage pre-paid Facsimile -X Electronic Mail _ Hand Delivery _U.S. Mail, postage pre-paid Facsimile -X Electronic Mail _ Hand Delivery _U.S. Mail, postage pre-paid Facsimile -X Electronic Mail _ Hand Delivery _U.S. Mail, postage pre-paid Facsimile -X Electronic Mail _ Hand Delivery _U.S. Mail, postage pre-paid Facsimile -X Electronic Mail _ Hand Delivery _U.S. Mail, postage pre-paid Facsimile -X Electronic Mail _ Hand Delivery _U.S. Mail, postage pre-paid Facsimile -X Electronic Mail l I , .. Bil Brown Adams County Board of Commissioners PO Box 48 Council, IT 83612 bdbrown~frontiernet.net _ Hand Delivery _U.S. Mail, postage pre-paid Facsimile -X Electronic Mail Ted S. Sorenson, PE Birch Poer Company 5203 South 11 th East Idaho Falls, ID 83404 ted(ßtsorenson.net _ Hand Delivery _U.S. Mail, postage pre-paid Facsimile -X Electronic Mail Glenn Ikemoto Margaret Rueger Idaho Windfars, LLC 6762 Blair Avenue Piedmont, CA 94611 glenn(ßenvisionwind.com margaret(ßenvisionwind.com _ Hand Delivery _U.S. Mail, postage pre-paid Facsimile -X Electronic Mail Megan Walseth Decker Senior Staf Counsel Renewable Nortwest Project 917 SW Oak Street Ste 303 Portand, OR 97205 megan(ßrnp.org _ Hand Delivery _U.S. Mail, postage pre-paid Facsimile -X Electronic Mail Benjamin J. Otto Idaho Conservation League 710 N. Sixth Street (83702) POBox 844 Boise, ID 83701 botto~idahoconservation.org _ Hand Delivery _U.S. Mail, postage pre-paid Facsimile -X Electronic Mail Ken Miler Snake River Alliance PO Box 1731 Boise, ID 83701 kmilerc$snakeriveralliance.org _ Hand Delivery _U.S. Mail, postage pre-paid Facsimile -X Electronic Mail .... # I Robert D. Kah Executive Director Nortwest & Intermountan Power Producers Coalition 1117 Minor Ave., Ste 300 Seattle, W A 98101 rkah(ßppc.org Don Stuevant Energy Director J.R. Simplot Company PO Box 27 Boise,ID 83707-0027 don.stuevant~simplot.com Mar Lewallen Clearater Paper Corporation 601 W Riverside Ave Ste 1100 Spokane WA 99201 mar. lewallen(ßclearaterpaper. com _ Hand Delivery _U.S. Mail, postage pre-paid Facsimile -X Electronic Mail _ Hand Delivery _U.S. Mail, postage pre-paid Facsimile -X Electronic Mail _ Hand Delivery _U.S. Mail, postage pre-paid Facsimile X Electronic Mail CJ dams