20120511IPC to Exergy 44-51.pdf

IDAHO
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REC Eli Er An IDACORP Company
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DONOVAN E WALKER
Lead Counsel .IDMO
dwalker(idahopower.com U
May 10, 2012
VIA HAND DELIVERY
Jean D. Jewell, Secretary
Idaho Public Utilities Commission
472 West Washington Street
Boise, Idaho 83702
Re: Case No. GNR-E-11-03
PURPA SAR and IRP Methodologies - Response to Exergy Development
Group of Idaho's Fourth Production Request
Dear Ms. Jewell:
Enclosed for filing please find an original and three (3) copies of Idaho Power
Company's Response to the Fourth Production Request of Exergy Development Group of
Idaho ("Exergy") to Idaho Power Company in the above matter.
Also, enclosed in a separate envelope are four (4) copies of a confidential
document provided in response to Exergy's Request for Production No. 44. Please handle
the confidential information in accordance with the Protective Agreement executed in this
matter.
Lastly, enclosed are four (4) copies of a non-confidential disk containing information
responsive to the Exergy's Request for Production No. 45.
Very yours,
Donovan E. Walker
DEW:csb
Enclosures
1221 W. Idaho St. (83702)
P.O. Box 70
Boise, ID 83707
DONOVAN E. WALKER (ISB No. 5921)
JASON B. WILLIAMS (ISB No. 8718)
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
dwaIker(äidahopower.com
iwilliamsäidahopower.com
?IHZ MAY IQ PM 5:01
IDAHO
UTLITI :3 -O mm,
Attorneys for Idaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE COMMISSION'S
REVIEW OF PURPA QF CONTRACT
PROVISIONS INCLUDING THE
SURROGATE AVOIDED RESOURCE
(SAR) AND INTEGRATED RESOURCE
PLANNING (IRP) METHODOLOGIES FOR
CALCULATING PUBLISHED AVOIDED
COST RATES.
CASE NO. GNR-E-11-03
IDAHO POWER COMPANY'S
RESPONSE TO THE FOURTH
PRODUCTION REQUEST OF
EXERGY DEVELOPMENT GROUP
OF IDAHO TO IDAHO POWER
COMPANY
COMES NOW, Idaho Power Company ("Idaho Power" or "Company"), and in
response to the Fourth Production Request of Exergy Development Group of Idaho
("Exergy") to Idaho Power Company dated April 19, 2012, herewith submits the
following information:
IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -1
REQUEST FOR PRODUCTION NO. 44: Please provide all documents
containing policies for implementing curtailment of QFs under Schedule 72. If no such
policy exists, please state so. If a policy exists, please indicate:
(a)How the policy was developed;
(b)Whether this policy has every been approved or reviewed by the
Idaho PUC;
(c)Whether this policy has been made publicly available;
(d)Whether this policy has been made available to affected QFs.
RESPONSE TO REQUEST FOR PRODUCTION NO. 44:
(a)Please see the confidential document containing the operational policy for
Schedule 72. The confidential document will be provided to those parties that have
executed the Protective Agreement in this proceeding. The Schedule 72 policy was
developed to provide instructions, as required by mandated reliability standards, for
dealing with operational reliability issues. The policy was developed following internal
discussions among Idaho Power's operations and legal personnel to specifically deal
with North American Energy Reliability Council Balancing Standards and other
operational reliability issues.
(b)The Schedule 72 policy/procedure has not been reviewed by the Idaho
Public Utilities Commission ("Commission"). However, Schedule 72 is on file and has
been approved by the Commission.
(C) The narrative portion of this policy has been provided to any Qualifying
Facility ("QF") project that has requested a copy.
IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -2
(d) The narrative portion of this policy has been made available to any QF
that requests a copy of the procedure.
The response to this Request was prepared by Tessia Park, Director of Load
Serving Operations, Idaho Power Company, in consultation with Donovan E. Walker,
Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -3
REQUEST FOR PRODUCTION NO. 45: For each QF curtailment the Company
has implemented under Schedule 72 in the years 2009, 2010, 2011 and 2012, please
provide:
(a)date;
(b)hour of day;
(c)duration of curtailment;
(d)notice given to Us prior to curtailment;
(e)control area load and system load during the hours of the
curtailment event and in each of the 24 hours before and each of the 24 hours after
such curtailment.
(f)generation levels for all Company-owned resources during the
event.
RESPONSE TO REQUEST FOR PRODUCTION NO. 45: Please see the
attached Excel file which contains the requested information.
The response to this Request was prepared by Tessia Park, Director of Load
Serving Operations, Idaho Power Company, in consultation with Donovan E. Walker,
Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -4
REQUEST FOR PRODUCTION NO. 46: Please explain how the Company's
policy for curtailment proposed for Schedule 74 differs from that for its policy for
curtailment for Schedule 72. Please include explanation of how many incremental
additional hours of annual curtailment are expected to be required by the Company's
proposed Schedule 74 curtailment policy.
RESPONSE TO REQUEST FOR PRODUCTION NO. 46: Please see the Direct
Testimony of Tessia Park at page 15 beginning at line 6 through page 16, line 14 for an
explanation of how the Company's proposed Schedule 74 differs from Schedule 72.
Please see Idaho Power's response to Commission Staffs Production Request No. 5
for an explanation of how many incremental additional hours of annual curtailment are
expected to be required by the Company's proposed Schedule 74.
The response to this Request was prepared by Tessia Park, Director of Load
Serving Operations, Idaho Power Company, in consultation with Donovan E. Walker,
Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -5
REQUEST FOR PRODUCTION NO. 47: Reference the Company's Response
to Exergy Request No. 19(d).
(a)Please confirm that the Company's position is that the licenses and
state water quality certifications for these plants allow for the Company to spill or
otherwise bypass flows without generating electricity for system reliability or emergency
purposes. If the Company does not believe its permits and licenses allow it to stop
generating electricity at any of the plants for system reliability concerns, please state so
and identify the plant(s).
(b)For each of the identified run-of-river hydro projects, please explain
the duration of time the plant can be generating at full output (given available water
flow) after a spill or bypass event.
RESPONSE TO REQUEST FOR PRODUCTION NO. 47:
(a) The Federal Energy Regulatory Commission ("FERC") licenses and state
water quality certifications for Idaho Power's plants in question allow for the Company to
spill or otherwise bypass flows without generating electricity for emergency purposes,
including the maintenance of system reliability. Outside of the spring runoff period,
Idaho Power rarely spills water at any of the mid-Snake projects, with the exception of
meeting the aesthetic flow license requirements at the Shoshone Falls project. If the
amount of spill required at these projects to maintain system reliability were to increase
significantly above historical levels, an amendment to the FERC licenses and/or state
water quality certifications would likely be required, including Endangered Species Act
consultation in some cases.
IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -6
(b) For the subject projects, switching between spill and generation is done
simultaneously in order to maintain consistent river flows. The actual amount of time
necessary would be unique for each project depending on the total flow in the river and
how many spillgates were open. Some of the projects have larger radial gates that
typically operate at the rate of one foot per minute and switching from spill to generation
can be accomplished in a relatively short amount of time, depending on how much flow
is in the river. Other projects have older, sluice-style gates that must be manually
raised or lowered one at a time using an electric hoist, and therefore take much longer
to operate.
To minimize the potential for erosion, spillways are typically designed to have
several spillgates partially open for any given flow, as opposed to opening one gate fully
before the next is opened. This practice would tend to increase the time required to
switch from spill to generation.
The response to this Request was prepared by M. Mark Stokes, Power Supply
Planning Manager, Idaho Power Company, in consultation with Donovan E. Walker,
Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -7
REQUEST FOR PRODUCTION NO. 48: For the Hells Canyon Complex, please
explain the current limitations on the rate of increase in outflow (feet of water level per
hour, etc.) from each of the three dams. If the restriction differs by time of year, please
explain the differences.
RESPONSE TO REQUEST FOR PRODUCTION NO. 48: The limitation on the
rate of increase in outflow from the Hells Canyon project is one foot per hour as
measured at the Snake River at Johnson Bar gauge, which is located approximately 17
miles downstream from the Hells Canyon project. This limitation on the Hells Canyon
project ramping rate is stipulated in the original project license for the Hells Canyon
Complex (FERC No. 1971), and is proposed by Idaho Power in the new license
application submitted to the FERC in July 2003. There are no ramping rate restrictions
in the original license or the new license application for either the Brownlee or Oxbow
projects.
In 1991, Idaho Power voluntarily adopted an operations plan for the Hells
Canyon Complex known as the Fall Chinook Plan. Under this plan, Hells Canyon
project outflows are maintained at near constant levels for approximately two months
from mid-October to mid-December to provide consistent habitat for fall Chinook salmon
spawning. As part of its standard operations, Idaho Power continues to manage the
Hells Canyon Complex flows according to the Fall Chinook Plan, and proposes to
continue these operations as part of the new license application. During fall Chinook
spawning when the plan is in effect, the limitation on the rate of increase in outflow from
the Hells Canyon project is effectively zero.
The response to this Request was prepared by M. Mark Stokes, Power Supply
Planning Manager, Idaho Power Company, in consultation with Donovan E. Walker,
Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -8
REQUEST FOR PRODUCTION NO. 49: Reference the Response to Exergy
Request No. 21(b), describing an expected minimum generation condition at the Hells
Canyon Complex of 300 MW at 8,500 cfs outflow and 550 MW at outflows of 14,000 cfs.
For each of these minimum generation conditions, please explain the maximum
generation ramping rate (MW increased output per minute, or other available units) that
can be expected from the Hells Canyon Complex given the limitations on increased
outflow described in response to Request No. 48 above.
RESPONSE TO REQUEST FOR PRODUCTION NO. 49: Idaho Power
manages the water in the three reservoirs of the Hells Canyon Complex to optimally
schedule plant flows through the system while maintaining compliance with hydraulic,
environmental, and license constraints. An implication of optimizing the management of
the reservoirs is that outflows from the lowest dam (Hells Canyon) are often not equal to
outflows from the next upstream dam (Oxbow), which in turn is often not equal to
outflows from the furthest upstream dam (Brownlee). In other words, outflows from
Brownlee Dam are not, as a matter of standard operating practice, simply translated
(without modification) to the two lower dams. Thus, it is not possible to identify a unique
maximum generation ramping rate for a given outflow at Hells Canyon Dam; the
generation ramping rate for the three-dam complex in total is dependent on reservoir
and outflow conditions in the complex.
It is possible to estimate that Hells Canyon Dam outflows (and corresponding
generation) can be ramped in compliance with limitations described in the Company's
response to Exergy's Request for Production No. 48. In practice, Idaho Power
frequently assumes that Hells Canyon Dam outflows can be increased at a rate of 2,000
IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -9
cubic feet per second ("cfs") per hour while maintaining compliance with ramping
limitations as evaluated at the Snake River at Johnson Bar gauge. The change in
generation at Hells Canyon Dam associated with a 2,000 cfs change in outflow is about
30 megawatts ("MW"). However, it is important to note that reservoir conditions in the
three-dam complex may at times limit Idaho Power's ability to increase Hells Canyon
Dam outflows to less than 2,000 cfs.
The response to this Request was prepared by M. Mark Stokes, Power Supply
Planning Manager, Idaho Power Company, in consultation with Donovan E. Walker,
Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -10
REQUEST FOR PRODUCTION NO. 50: For each of the three dams in the
Hells Canyon Complex, please provide the increase in outflow in cfs for an hour when
the outflow increase causes the water level reading on the USGS gauge below the [sic]
each dam to increase by one foot.
RESPONSE TO REQUEST FOR PRODUCTION NO. 50: U.S. Geological
Survey ("USGS") gauges are not installed below Brownlee Dam and Oxbow Dam. The
gauge below Hells Canyon Dam was previously operated by the USGS, but since April
2001, it has been operated by Idaho Power. For a river gauge, the increase in outflow
in cfs corresponding to a one foot increase in water level vanes as a function of flow.
Thus, there is no single value that can be provided in response to this Request. The
relationship between outflow and water level can be described with a rating curve. The
tailwater rating curve for Hells Canyon Dam outflow is given as Figure B-13 on page B-
43 of the new license application for the Hells Canyon Complex submitted by Idaho
Power to the FERC in July 2003. This application can be found through the Hells
Canyon Application and Related Documents page on Idaho Power's website via the
following link:
hftp://www. idahopower.com/AbouttJs/RatesRepulatory/ReI icensing/hellscanyon/ HCaDplication .cfm.
The tailwater rating curve for Hells Canyon Dam outflow from the new license
application is provided below.
IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -11
HELLS CANYON DEVELOPMENT: TAILWATER RATING CURVE
P!
FMI Ø!I
hI
!( .ø.
•04 WA •
• ----------------------
Hells Canyon Discharge (dc)
It is important to recognize that relationships between outflow and water level
below Oxbow and Brownlee Dams are not readily established because of backwater
issues associated with downstream reservoirs (Oxbow Reservoir downstream from
Brownlee Dam and Hells Canyon Reservoir downstream from Oxbow Dam). As an
example, Oxbow Reservoir backwater effects may cause the water level below
Brownlee Dam to increase even with a decrease in Brownlee Dam outflow. While water
levels below Brownlee and Oxbow Dams are affected by their respective outflows, they
are also substantially influenced by downstream reservoir levels. In contrast, Hells
Canyon Dam outflow is discharged to a natural river channel, allowing establishment of
a tailwater rating curve as described earlier in this response and as shown above.
The response to this Request was prepared by M. Mark Stokes, Power Supply
Planning Manager, Idaho Power Company, in consultation with Donovan E. Walker,
Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -12
REQUEST FOR PRODUCTION NO. 51: For each of the three dams in the Hells
Canyon Complex, please list the flow (in cfs) through the dam and the electrical output
(MW) at the following generation levels:
(a)at full capacity;
(b)the least amount of generation operationally possible above 0 MW
for the plant;
(c)each increment of 100 MW (e.g. 100 MW, 200 MW, 300 MW, etc.)
between the MW values identified in (a) and (b).
RESPONSE TO REQUEST FOR PRODUCTION NO. 51: The electrical output
of a hydroelectric generator is a function of several variables. Key among these is the
hydraulic head, which is equal to the elevation difference between a project's headwater
and tailwater. Because these elevations vary as a part of routine management of a
hydroelectric project, an accepted measure to describe a hydroelectric generator is the
rated capacity. The response to this Request references the rated capacity and other
relevant ratings for the Hells Canyon Complex generators in the new license application
submitted by Idaho Power to the FERC in July 2003. This application can be found
through the Hells Canyon Application and Related Documents page on Idaho Power's
website via the following link:
http://www. idahopower.com/AboutUs/RatesRequIatorv/Relicensing/heIIscanyon/HCaipIication .cfm.
(a) Exhibit A of the new license application provides a description of the Hells
Canyon Complex, including detailed characteristics of the project generators. A
summary of these characteristics for responding to this Request is given in the following
table:
IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -13
Hydraulic Capacity at Nameplate Rated Capacity Unit Nameplate Head and Capacity Head (per unit) (per unit)
Brownlee 1-4 250 feet 5,675cfs 90.1 MW
Brownlee5 240 feet 11,800 cfs 225.0 MW
Oxbow 1-4 115 feet 6,100 cfs 47.5 MW
Hells Canyon 1-3 210 feet 9,000 cfs 130.5 MW
(b)Generation at Brownlee and Oxbow can be managed such that the
hydroelectric output of each plant can be reduced to less than 200 cfs for very short
periods of time (typically for one hour during the night) as part of optimizing the use of
available water. Because of minimum flow constraints, flow through Hells Canyon Dam
cannot be reduced to these low levels. In the new license application for the Hells
Canyon Complex, Idaho Power proposes a typical Hells Canyon minimum outflow of
6,500 cfs during the period from June 1 until the start of operations for the Fall Chinook
Plan (please see the Company's response to Exergy's Request for Production No. 48).
Using this minimum flow level as an example, and simple mathematics using the ratings
given in part (a), an estimate of the electrical output at the 6,500 cfs minimum outflow
level can be calculated to be 94.3 MW (94.3 MW = (6,5000/9,000) X 130.5 MW).
Please note that this is an estimated output because the turbine efficiency at the 6,500
cfs turbine flow level is likely different from that at the rated flow level and rated
nameplate head.
(c)As described earlier in this response, the plant flow at the incremental
generation levels is a function of hydraulic head. Thus, for the purposes of this
response, the ratings given in part (a) will serve as the basis for estimating the plant
flows at the incremental generation levels. The estimated plant flows are calculated by
IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -14
simple mathematics as utilized in part (b). As described in part (b), the plant flows at
the incremental generation levels are considered estimates because of variable
efficiency and hydraulic head conditions.
Plant Output (MW) Estimated Plant Flow
(cfs)
Hells Canyon 94.3 6,500
Hells Canyon 100 6,900
Hells Canyon 200 13,800
Hells Canyon 300 20,700
Hells Canyon 390 27,000
Oxbow -0 200
Oxbow 100 12,800
Oxbow 190 24,400
Brownlee -0 200
Brownlee 100 5,900
Brownlee 200 11,800
Brownlee 300 17,700
Brownlee 400 23,600
Brownlee 500 29,500
Brownlee 585.4 34,500
The response to this Request was prepared by M. Mark Stokes, Power Supply
Planning Manager, Idaho Power Company, in consultation with Donovan E. Walker,
Lead Counsel, Idaho Power Company.
DATED at Boise, Idaho, this 10th day of May012.
DONOVAN E. WALKER
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -15
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on thislOth day of May 2012 I served a true and correct
copy of IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION
REQUEST OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER
COMPANY 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 Utilities Commission
472 West Washington (83702)
P.O. Box 83720
Boise, Idaho 83720-0074
Avista Corporation
Michael G. Andrea
Avista Corporation
1411 East Mission Avenue, MSC-23
P.O. Box 3727
Spokane, Washington 99220-3727
PacifiCorp dibla Rocky Mountain Power
Daniel E. Solander
PacifiCorp d/b/a Rocky Mountain Power
201 South Main Street, Suite 2300
Salt Lake City, Utah 84111
Exergy Development, Grand View Solar II,
J.R. Simplot, Northwest and Intermountain
Power Producers Coalition, Board of
Commissioners of Adams County, Idaho,
and Clearwater Paper Corporation
Peter J. Richardson
Gregory M. Adams
RICHARDSON & O'LEARY, PLLC
515 North 27th Street (83702)
P.O. Box 7218
Boise, Idaho 83707
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IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -16
Exergy Development Group
James Carkulis, Managing Member
Exergy Development Group of Idaho, LLC
802 West Bannock Street, Suite 1200
Boise, Idaho 83702
Dr. Don Reading
Ben Johnson Associates, Inc.
6070 Hill Road
Boise, Idaho 83703
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Grand View Solar II
Robert A. Paul
Grand View Solar II
15690 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
Board of Commissioners of Adams
County, Idaho
Bill Brown, Chair
Board of Commissioners of
Adams County, Idaho
P.O. Box 48
Council, Idaho 83612
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IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -17
Clearwater Paper Corporation Hand Delivered
Mary Lewallen U.S. Mail
Clearwater Paper Corporation Overnight Mail
601 West Riverside Avenue, Suite 1100 FAX
Spokane, Washington 99201 X Email marv.IewaIIenclearwaterpaper.com
Renewable Energy Coalition and Dynamis
Energy, LLC
Ronald L. Williams
WILLIAMS BRADBURY, P.C.
1015 West Hays Street
Boise, Idaho 83702
Renewable Energy Coalition
John R. Lowe, Consultant
Renewable Energy Coalition
12050 SW Tremont Street
Portland, Oregon 97225
Dynamis Energy, LLC
Wade Thomas, General Counsel
Dynamis Energy, LLC
776 East Riverside Drive, Suite 150
Eagle, Idaho 83616
Interconnect Solar Development, LLC
R. Greg Ferney
MIMURA LAW OFFICES, PLLC
2176 East Franklin Road, Suite 120
Meridian, Idaho 83642
Bill Piske, Manager
Interconnect Solar Development, LLC
1303 East Carter
Boise, Idaho 83706
Renewable Northwest Project and Idaho
Windfarms, LLC
Dean J. Miller
McDEVITT & MILLER LLP
420 West Bannock Street (83702)
P.O. Box 2564
Boise, Idaho 83701
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IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -18
Megan Walseth Decker
Senior Staff Counsel
Renewable Northwest Project
421 SW 6th Avenue, Suite 1125
Portland, Oregon 97204
Idaho Windfarms, LLC
Glenn Ikemoto
Margaret Rueger
Idaho Windfarms, LLC
672 Blair Avenue
Piedmont, California 94611
Twin Falls Canal Company and North Side
Canal Company
C. Thomas Arkoosh
Lori Thomas
CAPITOL LAW GROUP, PLLC
205 North I th Street, 4th Floor
P.O. Box 2598
Boise, Idaho 83701-2598
Donald W. Schoenbeck
RCS, Inc.
900 Washington Street, Suite 780
Vancouver, Washington 98660
Twin Falls Canal Company
Brian Olmstead, General Manager
Twin Falls Canal Company
P.O. Box 326
Twin Falls, Idaho 83303
North Side Canal Company
Ted Diehl, General Manager
North Side Canal Company
921 North Lincoln Street
Jerome, Idaho 83338
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Birch Power Company Hand Delivered
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5203 South 11th East FAX
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IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -19
Blue Ribbon Energy LLC
M. J. Humphries
Blue Ribbon Energy LLC
3470 Rich Lane
Ammon, Idaho 83406-7728
Arron F. Jepson
Blue Ribbon Energy LLC
10660 South 540 East
Sandy, Utah 84070
Idaho Conservation League
Benjamin J. Otto
Idaho Conservation League
710 North Sixth Street (83702)
P.O. Box 844
Boise, Idaho 83701
Snake River Alliance
Liz Woodruff, Executive Director
Ken Miller, Clean Energy Program Director
Snake River Alliance
350 North 9th Street #13610
P.O. Box 1731
Boise, Idaho 83701
Energy Integrity Project
Tauna Christensen
Energy Integrity Project
769 North 1100 East
Shelley, Idaho 83274
Idaho Wind Partners I, LLC
Deborah E. Nelson
Kelsey J. Nunez
GIVENS PURSLEY LLP
601 West Bannock Street
P.O. Box 2720
Boise, Idaho 83701-2720
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a& ta-B C)0'f'11AJ4_
Christa Bearry, Legal Assistant U
IDAHO POWER COMPANY'S RESPONSE TO THE FOURTH PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -20
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. GNR-E-11-03
IDAHO POWER COMPANY
RESPONSE TO EXERGY'S
REQUEST FOR PRODUCTION NO. 44
THIS ATTACHMENT IS
CONFIDENTIAL
AND WILL BE PROVIDED
TO THOSE PARTIES THAT
HAVE SIGNED THE
PROTECTIVE
AGREEMENT