20120727IPC to Exergy 59-67.pdf

IDAHO
PNER®
An IDACORP Company
4:21
JASON B. WILLIAMS
Corporate Counsel
IwilIiamsidahopower.com
July 27, 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 Sixth Production Request
Dear Ms. Jewell:
Enclosed for filing please find an original and three (3) copies of Idaho Power
Company's Response to the Sixth Production Request of Exergy Development Group of
Idaho ("Exergy") to Idaho Power Company in the above matter.
Also enclosed are four (4) confidential disks containing information being produced
in response to Exergy's Sixth Production Request. Please handle the enclosed
confidential information in accordance with the Protective Agreement executed in this
matter.
Very truly yours,
Jason B. Williams
JBW:kkt
Enclosures
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]
dwalker(äidahoDower.com
iwiIliams(idahopower.com
Attorneys for Idaho Power Company
RECEIVED
"I" JUL 27 PM4: 28
JJ-iOP 1 r'
:
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 SIXTH
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 Sixth Production Request of Exergy Development Group of Idaho
("Exergy") to Idaho Power Company dated July 6, 2012, herewith submits the following
information:
IDAHO POWER COMPANY'S RESPONSE TO THE SIXTH PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -1
REQUEST FOR PRODUCTION NO. 59: At page 13 of her rebuttal testimony,
Ms. Parks [sic] states, "As a result of the large amount of PURPA requests on Idaho
Power's system, the Company has to complete interconnection and transmission
system upgrades that it otherwise would not need to serve load." Please identify all
network transmission system upgrades paid for, in full or in part, by PURPA QFs on
Idaho Power's transmission system. Please provide maps and studies and all work
papers and supporting documents used preparing your response.
RESPONSE TO REQUEST FOR PRODUCTION NO. 59: Idaho Power objects
to this Request on the grounds of relevance. The network transmission upgrades paid
for, in full or in part, by Public Utility Regulatory Policies Act of 1978 ("PURPA")
Qualifying Facilities ("QF") on Idaho Power's transmission system bears no relevance
on the issues presented in this case and therefore are irrelevant in this proceeding.
Idaho Power also objects to this Request on the grounds that the requested
material is overly broad and unduly burdensome.
Idaho Power further objects to this Request on the grounds that some of the
material sought is or may be privileged and protected by the attorney-client privilege
and/or the attorney work-product doctrine.
Notwithstanding and without waiving Idaho Power's objection to this Request,
please see the confidential attachments provided on the confidential CD which include
facilities studies going back to 1998 describing the required network transmission
system upgrades for PURPA QFs connecting to Idaho Power's electrical system. The
confidential CD will be provided to those parties that have signed the Protective
Agreement in this proceeding.
The response to this Request was prepared by Tessia Park, Director of Load
Serving Operations, Idaho Power Company, in consultation with Jason B. Williams,
Corporate Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SIXTH PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -2
REQUEST FOR PRODUCTION NO. 60: Ms. Parks [sic] then states on page 13
of her rebuttal testimony, in reference to the PURPA caused transmission system
upgrades, "Because these system upgrades do not serve any other purpose or need
required to provide serve [sic] to Idaho Power's customers, it would be [sic] not be
appropriate to require customers to pay for interconnection and transmission system
upgrades that are not needed to serve load."
(a)Please provide all work papers and supporting documents relied upon by
Ms. Parks [sic] supporting the assertion that "these system upgrades do not serve any
other purpose."
(b)Does Idaho Power grant Us paying for such upgrades the exclusive use
for such facilities?
RESPONSE TO REQUEST FOR PRODUCTION NO. 60:
(a)Idaho Power did not rely on any specific workpapers or supporting
documents besides the Company's Integrated Resource Plan ("IRP") which provides
the portfolio that Idaho Power utilizes to meet its future expected load. In the IRP, Idaho
Power identifies resources and the transmission upgrades required to deliver those
resources to load. QF resources are developed outside the IRP process, and as Idaho
Power has no control over the dispatch, deliverability, timing, or location at which a QF
project delivers energy, additional transmission required to deliver this energy to load is
duplicative and customers should not have to pay for the required additional
transmission.
(b)No.
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 SIXTH PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -3
REQUEST FOR PRODUCTION NO. 61: At page 6 of Mr. Stokes' rebuttal
testimony he states: "historically there has been a significant difference between the
prices paid to QF resources on Idaho Power's system and the Mid-C market index."
Please explain the relationship, as Mr. Stokes' understands it, between the Mid-C
market index and avoided cost rates. Please explain whether Idaho Power can secure
a twenty year strip of electricity at Idaho Power's forecasted Mid-C market price index.
RESPONSE TO REQUEST FOR PRODUCTION NO. 61: The following is taken
directly from page 7 of Mr. M. Mark Stokes' rebuttal testimony: "While the Mid-C index
does not represent an avoided cost rate, it does highlight the harm done to Idaho
Power's customers when Idaho Power has excess QF energy which must be sold into
the market at a substantial loss."
The differential between QF avoided cost rates and the Mid-C market index
indicates Idaho Power could purchase electricity from the market for substantially less
than what it is required to pay for QF generation.
Idaho Power's merchant trading group indicates that long-term, firm purchase
contracts at current forward prices are readily available out to 2020. Longer contract
terms, as long as 20 years, could likely be executed or at least hedged, but it would
require contacting and negotiating with specific counterparties.
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 SIXTH PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -4
REQUEST FOR PRODUCTION NO. 62: Please identify the estimated levelized
cost approved by the Commission when it issued the order for approval/construction of
each resource Idaho Power has built and placed into ratebase since PURPA was first
adopted.
RESPONSE TO REQUEST FOR PRODUCTION NO. 62: The Company is
unaware of any time when the Commission has approved an estimated levelized cost in
an order issued for approval/construction of any resource the Company has built and
placed into rate base since PURPA was first adopted.
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 SIXTH PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -5
REQUEST FOR PRODUCTION NO. 63: Please reference Mr. Stokes' rebuttal
testimony page 19 beginning on line 20 through page 20 end line 29 Mr. Stokes.
Please specifically identify what it is in Staff witness Sterling's direct testimony that is
being rebutted in this passage.
RESPONSE TO REQUEST FOR PRODUCTION NO. 63: The referenced
passage, extended through page 21 line 8, shows that although Staff is supportive of
Idaho Power's proposed Hourly Incremental Cost methodology, they continue to
support the use of the Surrogate Avoided Resource ("SAR") model for the calculation of
published rates. Idaho Power believes the Hourly Incremental Cost methodology
should be used to establish both published and negotiated avoided cost rates.
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 SIXTH PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -6
REQUEST FOR PRODUCTION NO. 64: At page 23 of his rebuttal testimony,
Mr. Stokes states that "if [sic] the capital and fixed costs of an SCCT were used to
determine the capacity portion of the avoided cost rate. The energy component would
still require using the heat rate and other variable operations and maintenance
assumptions appropratiate [sic] for a CCCT." What is the source of the 'requirement'
that a CCCT heat rate be used when the SAR is a SCCT.
RESPONSE TO REQUEST FOR PRODUCTION NO. 64: The quoted testimony
states, "The energy component would still require. . . ." (Emphasis added.) The intent
of proposing that an SCCT be used in the SAR model would be for the avoided cost of
capacity to be based on the capital cost of an SCCT, while the avoided cost of energy
would continue to be based on the operating costs of a CCCT.
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 SIXTH PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -7
REQUEST FOR PRODUCTION NO. 65: At page 39 of his rebuttal testimony,
Mr. Stokes makes reference to the IRP Advisory Council. Please provide all documents
relating to the selection of the current IRP Advisory Council. Are the council members
provided with independent, technical staff?
RESPONSE TO REQUEST FOR PRODUCTION NO. 65: No documents exist
related to the selection of the IRP Advisory Council ("Council") with the exception of the
list of current members listed below that participated in the preparation of the 2011 IRP:
Customer ReDresentatives
Agricultural Representative..............................
Boise State University.....................................
Heinz Frozen Foods.......................................
INL.............................................................
Micron.........................................................
Simplot........................................................
Public Interest ReDresentatives
Boise Metro Chamber of Commerce
Idaho Conservation League..................................
Idaho Department of Commerce...........................
Idaho Office of Energy Resources........................
Idaho State House of Representatives .................
Idaho State Senate...............................................
Northwest Power and Conservation Council.........
Oil/Gas Industry Advisor.......................................
Snake River Alliance.............................................
Water Issues Advisor............................................
Sid Erwin
John Gardner
Steve Munn
Tom Moriarty
Michael Bick
Don Sturtevant
Bill Connors
Ben Otto
Lane Packwood
John Chatburn
Representative Elaine Smith
Senator Russ Fulcher
Jim Yost/Shirley Lindstrom
David Hawk
Ken Miller
Vince Alberdi
Reuulatorv Commission Renresentatives
Idaho Public Utilities Commission.........................Rick Sterling
Public Utility Commission of Oregon.....................Erik Colville
There is routinely some turnover in Council membership between IRP cycles.
Idaho Power strives to maintain a balance on the Council between the interests of all
the different stakeholders. In the next few weeks the Company expects to finalize the
Council membership for its 2013 IRP which begins with the first Council meeting on
August 16, 2012.
IDAHO POWER COMPANY'S RESPONSE TO THE SIXTH PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -8
No, the Council members are not provided with independent technical staff.
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 SIXTH PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -9
REQUEST FOR PRODUCTION NO. 66: On page 46 of his rebuttal testimony
Mr. Stokes states that "The Commission has specifically found this [liquidated damages]
requirement to be in the public interest and a just and reasonable requirement of the
contracting process." Please provide copies of, or citations to, where the Commission
"specifically" made those findings.
RESPONSE TO REQUEST FOR PRODUCTION NO. 66: Please See Idaho
Power's Legal Brief filed in this proceeding on July 20, 2012, pp. 27-32.
Delay liquidated damages provisions have been
included in PURPA FESA contracts approved by the
Commission since at least 2007. See, Case No. IPC-E-06-
36. In addition, one of the first Commission approved
FESAs to contain terms requiring the project to post liquid
security was the FESA for Cassia Gulch Wind Park and
Tuana Springs Energy, Case No. IPC-E-09-24. In that case
the Commission approved provisions requiring the posting of
liquid security in the amount of $20 per kW of project
capacity.
The Commission considered and approved provisions
providing for the posting of liquid security in the amount of
$20 per kW of project capacity in at least four other PURPA
FESAs. See, Case No. IPC-E-09-18, IPC-E-09-19, IPC-E-
09-20, IPC-E-09-25. The Commission has since analyzed
and approved provisions requiring the posting of liquid
security in the amount of $45 per kW of nameplate capacity
in at least twenty-seven different PURPA FESAs. See, Case
No. IPC-E-10-02, IPC-E-10-05, IPC-E-10-15, IPC-E-10-16,
IPC-E-1 0-17, IPC-E-10-1 8, IPC-E-1 0-19, IPC-E-1 0-22, IPC-
E-1 0-26, IPC-E-1 0-37, IPC-E-1 0-38, IPC-E-1 0-39, IPC-E-1 0-
40, I PC-E-1 0-41, I PC-E-1 0-42, I PC-E-1 0-43, I PC-E-1 0-44,
IPC-E-1 0-45, IPC-E-1 0-47, IPC-E-1 0-48, IPC-E-1 0-49, IPC-
E-1 0-50, IPC-E-1 1-09, IPC-E-1 1-10, IPC-E-1 1-25, IPC-E-1 1-
26, and IPC-E-11-27. In approving the change in the
amount of delay damage security that is acceptable for such
contracts from $20 to $45 per kW of nameplate capacity, the
Commission specifically found such delay security to be
reasonable, necessary, and not to be punitive. Order No.
31034, p. 3-4, Case No. IPC-E-10-02 (2010).
Idaho Power's Legal Brief, Case No. GNR-E-1 1-03, pp. 27-28.
The response to this Request was prepared by Donovan E. Walker, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SIXTH PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -10
REQUEST FOR PRODUCTION NO. 67: At page 47 of his rebuttal testimony Mr.
Stokes, speaking of liquidated damages states that, "In addition to the system operation
and planning problems that failure to bring generation units online in a timely manner
and when they are scheduled to come on line, there is the substantial value that the QF
gets by locking in a price, and a pricing stream with a [sic] contract." Please quantify
and specify each system operation and planning problem Mr. Stokes is referring to and
please specify and quantify the damage incurred by Idaho Power when a QF locks in a
price.
RESPONSE TO REQUEST FOR PRODUCTION NO. 67: As dictated by Idaho
Power's Risk Management Policy, the Company routinely buys and sells electricity as
much as 18 months in advance of the month that it is needed (bought) or not needed
(sold). The amounts that are bought and sold are based on the overall portfolio position
(surplus/deficit) that includes Company-owned resources and QF contracts.
When a QF resource fails to come on-line by the Scheduled Operation Date,
Idaho Power would replace this energy by making a market purchase, assuming
transmission capacity is available to get the energy to Idaho Power's system. Because
the transaction is done closer to real time, market prices can be higher than they would
have been had Idaho Power been able to execute the transaction earlier in time. There
is also the possibility that market prices will be lower than the QF contract price, which
is typically the current situation if Idaho Power is able to buy energy from the Mid-C
market. If transmission capacity is not available from the Pacific Northwest, the energy
must be bought from the east side of the Company's system where market liquidity is an
issue and prices are usually higher.
IDAHO POWER COMPANY'S RESPONSE TO THE SIXTH PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -11
Regardless of whether market prices are higher or lower than prices contained in
a QF contract, Idaho Powers customers end up assuming the risk associated with the
uncertainty. There is value associated with reducing or eliminating risk even if the
potential positive and negative outcomes are evenly split. A fixed rate QF contract
eliminates this risk for the QF developer and pushes it entirely onto Idaho Power's
customers.
The following is taken from the rebuttal testimony of Mr. Stokes and explains the
value or cost associated with this risk: "There are financial instruments that can be
purchased that would allow a utility to lock in a 20-year, or long-term, stream of prices,
and have the option to not execute on that option at a date certain in the future. Such
products are very costly, and could be as much as $5 per MWh of power." Stokes
Rebuttal Testimony, p. 47, II. 13-18 (emphasis added).
The financial instrument referenced above would be a "put" option. It is important
to note the emphasized section of the passage above in that a put option allows a party
to not execute on the option if conditions are not favorable for the option holder.
PURPA developers have argued that QF contracts provide the benefit of cost certainty
for a utility. However, a QF contract clearly does not provide the benefit of an option to
the utility as described above as the utility does not have the option to not take and pay
for the energy. A QF contract does provide the QF developer the benefit of a
guaranteed minimum price for their energy (put option) in a falling price market while
providing the utility no price protection in a rising price environment.
The value QF developers receive and the cost to customers of providing this
option could be as much as $5 per megawatt-hour, as stated in rebuttal testimony.
IDAHO POWER COMPANY'S RESPONSE TO THE SIXTH PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -12
Liquidated damages calculated at $45 per kilowatt of nameplate capacity is very small
in comparison, but at least provides an agreed upon valuation of an assessment of risk
that the customers are bearing associated with whether a QF generator brings its
project on-line when it commits that it will.
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 27th day of July 2012.
JAON B. WILLIAMS
Aforney for Idaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO THE SIXTH PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -13
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 27th day of July 2012 I served a true and correct
copy of IDAHO POWER COMPANY'S RESPONSE TO THE SIXTH 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
Kristine A. Sasser
Deputy Attorney 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
Spokane, Washington 99202
PacifiCorp dlbla 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 SIXTH PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -14
Exergy Development Group of Idaho, LLC
James Carkulis, Managing Member
Exergy Development Group of Idaho, LLC
802 West Bannock Street, Suite 1200
Boise, Idaho 83702
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Dr. Don Reading
6070 Hill Road
Boise, Idaho 83703
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 SIXTH PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -15
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 mary. IewalIen(cIearwaterpaper.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, Idaho
Windfarms, LLC, and Ridgeline Energy LLC
Dean J. Miller
Chas. F. McDevitt
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 SIXTH PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -16
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
CAPITOL LAW GROUP, PLLC
205 North 10th Street, 4th Floor
P.O. Box 2598
Boise, Idaho 83701-2598
ELECTRONIC SERVICE ONLY
Lori Thomas
CAPITOL LAW GROUP, PLLC
205 North 10th Street, 4th Floor
P.O. Box 2598
Boise, Idaho 83701-2598
ELECTRONIC SERVICE ONLY
Donald W. Schoenbeck
RCS, Inc.
900 Washington Street, Suite 780
Vancouver, Washington 98660
ELECTRONIC SERVICE ONLY
Twin Falls Canal Company
Brian Olmstead, General Manager
Twin Falls Canal Company
P.O. Box 326
Twin Falls, Idaho 83303
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IDAHO POWER COMPANY'S RESPONSE TO THE SIXTH PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -17
ELECTRONIC SERVICE ONLY
North Side Canal Company
Ted Diehl, General Manager
North Side Canal Company
921 North Lincoln Street
Jerome, Idaho 83338
Birch Power Company
Ted S. Sorenson, P.E.
Birch Power Company
5203 South 11th East
Idaho Falls, Idaho 83404
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
P.O. Box 1731
Boise, Idaho 83701
Energy Integrity Project
Tauna Christensen
Energy Integrity Project
769 North 1100 East
Shelley, Idaho 83274
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IDAHO POWER COMPANY'S RESPONSE TO THE SIXTH PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -18
Idaho Wind Partners I, LLC
Deborah E. Nelson
Kelsey J. Nunez
GIVENS PURSLEY LLP
601 West Bannock Street (83702)
P.O. Box 2720
Boise, Idaho 83701-2720
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Ki berly To e , Executive Assistant
IDAHO POWER COMPANY'S RESPONSE TO THE SIXTH PRODUCTION REQUEST
OF EXERGY DEVELOPMENT GROUP OF IDAHO TO IDAHO POWER COMPANY -19