20120802Amended Protective Agreement.pdf

PROTECTIVE AGREEMENT
BETWEEN AVISTA CORPORATION,
IDAHO POWER COMPANY, PACIFICORP,
IDAHO PUBLIC UTILITIES COMMISSION STAFF,
AND INTERVENORS
This Protective Agreement is entered into this day of October 2011 by Avista
Corporation, Idaho Power Company, PacifiCorp dba Rocky Mountain Power (collectively the
Utilities), the Idaho Public Utilities Commission Staff, and Intervenors.
Recitals:
1.WHEREAS, Avista, Idaho Power, PacifiCorp, Intervenors, and Commission
Staff desire to make available certain information, and desires to examine certain information,
respecting the Review of Surrogate Avoided Resource (SAR) and Integrated Resource Planning
(IRP) Methodologies (Case No. GNR-E-1 1-03).
2.WHEREAS, Avista, Idaho Power, and PacifiCorp, Intervenors and Staff
anticipate that the Utilities may provide, or make available for review, certain information
considered by Avista, Idaho Power, and PacifiCorp to be of a trade secret, privileged or
confidential nature (as defined in Idaho Code § 9-340 et seq. and § 48-801 et seq.).
4. WHEREAS, Avista, Idaho Power, and PacifiCorp, Intervenors and Staff agree
that entering into a Protective Agreement will expedite the production of documents; will afford
the necessary protection to Avista's, Idaho Power's, PacifiCorp's, Intervenors' and Staff's
employees and/or representatives in this proceeding who might review the information and
subsequently be requested to reveal its contents by setting forth clear cut parameters for use of
Confidential Information, and will protect Confidential Information which might be provided
hereafter,
IT IS HEREBY STIPULATED AND AGREED AS FOLLOWS:
1. (a) Confidential Information.
All documents, data, information, studies and other materials furnished that are
claimed to be of trade secret, proprietary or confidential nature (herein referred to as
"Confidential Information") shall be so marked by the Utilities by stamping the same with a
designation indicating its trade secret, proprietary or confidential nature. To the extent any such
Confidential Information is provided in hard copy, such hard copies shall be printed on "colored"
PROTECTIVE AGREEMENT BETWEEN
AVISTA, IDAHO POWER, AND PACIFICORP, INTERVENORS,
AND IDAHO PUBLIC UTILITIES COMMISSION STAFF
paper. Any claim of confidentiality must be accompanied by an attorney's certificate that the
material is protected by law from public disclosure and cite the specific legal authority to support
the claim. IDAPA 31.01.01.067 and 31.01.01.233. Access to and review of Confidential
Information shall be strictly controlled by the terms of this Protective Agreement.
(b)Use of Confidential Information
All persons who may be entitled to review, or who are afforded access to any
Confidential Information by reason of this Protective Agreement shall neither use nor disclose
the Confidential Information for purposes of business or competition, or any purpose other than
the purpose of preparation for and conduct of Case No. GNR-E- 11-03 and then solely as
contemplated herein, and shall keep the Confidential Information secure as trade secret,
confidential or proprietary information and in accordance with the purposes and intent of this
Protective Agreement.
(c)Persons Entitled to Review.
Access to Confidential Information shall be limited to counsel of the undersigned
parties, employees, experts, agents or representatives of the undersigned parties who have
executed an Exhibit "A" to this Protective Agreement. Such information will be clearly marked
and protected from unauthorized public disclosure.
(d)Nondisclosure Agreement.
Confidential Information shall not be disclosed to any person who has not signed a
nondisclosure agreement on this form, which is attached hereto as Exhibit "A" and incorporated
herein. The nondisclosure agreement or Exhibit "A" shall require the person to whom disclosure
is to be made to read a copy of this Protective Agreement and to certify in writing that he or she
has reviewed the same and has consented to be bound by its terms. The nondisclosure agreement
shall contain the signatory's full name, permanent address, and employer. Such agreement shall
be delivered to counsel for each Utility and acknowledged and approved by the Utility before
disclosure is made.
2. (a) Copies.
No copies or transcriptions of the Confidential Information shall be made by Staff
and/or the Utilities except as necessary to make the information available to individuals who
have executed an Exhibit "A" to this Protective Agreement.
PROTECTIVE AGREEMENT BETWEEN
AVISTA, IDAHO POWER, AND PACIFICORP, INTERVENORS,
AND IDAHO PUBLIC UTILITIES COMMISSION STAFF 2
(b)Return of Confidential Information.
Upon request of a Utility, all original documents and copies of the Confidential
Information shall be: (1) returned to the Utility, or (2) shredded by the holder of such documents.
Unless otherwise ordered, Confidential Information, including transcripts or
depositions containing information to which a claim of confidentiality is made, shall remain
under seal, shall continue to be subject to the protective requirements of this Agreement, and
shall likewise, be returned to counsel for the Utilities within thirty (30) days after final settlement
or conclusion of the proceedings before the Commission which Confidential Information is
relevant including administrative or judicial review thereof. After return of documents pursuant
to this Paragraph, and upon request, a written receipt verifying return shall be provided by
counsel. Notwithstanding any other term of this Protective Agreement, to the extent any
Confidential Information cannot be fully returned or destroyed due to automatic electronic
archiving systems or otherwise, such failure to return to destroy shall not be deemed a breach of
this Protective Agreement, so long as such Confidential Information is maintained in accordance
with the terms of this Protective Agreement.
(c)Return of Notes.
Any notes maintained by a recipient of Confidential Information, which embody or
reflect any of the Confidential Information provided under this Agreement shall, upon request of
a Utility, be either returned to the Utility or, at the option of the recipient, destroyed.
3.Non-waiver of Objection to Admissibility.
The furnishing of any document, information, data, study or other materials pursuant
to this Protective Agreement shall in no way limit or waive the right of the providing party to
object to its relevance or admissibility in any proceedings before this Commission.
4.Challenge to Confidentiality.
(a) Initial Challenge.
This Protective Agreement establishes a procedure for the expeditious handling of
information a Utility claims is Confidential Information. In any proceeding before the
Commission, Staff may challenge the characterization of any information, document, data, or
study claimed by a Utility to be a trade secret, proprietary or confidential information. If seeking
to challenge the confidentiality of any information, Staff shall first contact counsel for the Utility
and attempt to resolve any difference by stipulation. Resolution may include removing the
PROTECTIVE AGREEMENT BETWEEN
AVISTA, IDAHO POWER, AND PACIFICORP, INTERVENORS,
AND IDAHO PUBLIC UTILITIES COMMISSION STAFF 3
confidential classifications, creating a non-confidential summary, reformatting the information,
etc.
(b)Subsequent Challenge.
In the event that the parties cannot agree as to the character of the information
challenged, Staff may challenge the confidentiality of the information by petitioning, in any
proceeding in which the information is relevant, the Commission to rule upon the disputed
information. The Petition shall be served upon the Commission and all parties to the proceeding
who have signed on Exhibit "A" as provided in this Protective Agreement. The Petition shall
designate with specificity the document or material challenged and state the grounds upon which
the subject material are deemed to be non-confidential by Staff.
(c)Challenge Hearing.
Staff shall request that the Commission conduct an in camera proceeding where only
those persons duly authorized to have access to such challenged materials under this Protective
Agreement shall be present. This hearing shall be commenced no earlier than five (5) business
days after serving the Petition on the Utility and the Commission. The record of the in camera
hearing shall be marked "CONFIDENTIAL -- Subject to Protective Agreement." To the
extent necessary, the transcript of such hearing shall be separately bound, segregated, sealed, and
withheld from public inspection by any person not bound by the terms of this Protective
Agreement.
(d)Determination.
The parties will ask the Commission to issue an Order determining whether any
challenged information or material is not properly deemed to be exempt from public disclosure
pursuant to the Idaho Public Records Act. (Idaho Code § 9-335 et seq.) If information is found
to be not exempt from disclosure, Staff shall not disclose such challenged material or use it in the
public record or otherwise outside the proceedings for at least five (5) business days unless the
Utility consents to such conduct. This procedure enables the providing party to seek a stay or
other relief from the Commission's Order removing the restrictions of this Agreement from
material claimed to be confidential. Such relief may be sought from the Commission or a court
of competent jurisdiction.
PROTECTIVE AGREEMENT BETWEEN
AVISTA, IDAHO POWER, AND PACIFICORP, INTERVENORS,
AND IDAHO PUBLIC UTILITIES COMMISSION STAFF 4
5. (a) Receipt Into Evidence.
Provision is hereby made for receipt into evidence in this proceeding of materials
claimed to be confidential in the following manner:
(1)If Staff intends to use Confidential Information or to make substantive
reference to Confidential Information supplied to it under this
Protective Agreement, it shall give reasonable prior notice of such
intention to the Utility and shall provide copies of the used Confidential
Information or substantive reference to Confidential Information only to
the providing party, and such other parties, if any, who have executed
an Exhibit "A" to this Protective Agreement.
(2)One (1) copy of the used Confidential Information or substantive
reference to Confidential Information or substantive reference to
Confidential Information described in Paragraph 5(a)(1) shall be placed
in the sealed record.
(3)Only one (I) copy of the documents designated to be placed in a sealed
record shall be made, which copy shall be supplied by the providing
party.
(4)The copy of the documents to be placed in the sealed record shall be
tendered by counsel for the Utility to the Commission, and shall be
maintained in accordance with the terms of this Protective Agreement.
(b)Seal.
While in the custody of the Commission, materials containing Confidential
Information shall be marked "CONFIDENTIAL - SUBJECT TO ATTORNEY'S
CERTIFICATE OF CONFIDENTIALITY" and shall not be examined by any person except
under the conditions set forth in this Agreement, if applicable.
(c)In Camera Hearing and Transcripts.
Any Confidential Information that must be orally disclosed at a hearing in the
proceedings shall be offered at an in camera hearing, attended only by persons authorized to
have access to the information under this Protective Agreement. Similarly, any transcription of
any examination or other reference to Confidential Information (or that portion of the record
containing Confidential Information) shall be marked and treated as provided herein for
Confidential Information. See IDAPA 31.01.01.287.
PROTECTIVE AGREEMENT BETWEEN
AVISTA, IDAHO POWER, AND PACIFICORP, INTERVENORS,
AND IDAHO PUBLIC UTILITIES COMMISSION STAFF 5
(d)Access to Record.
Access to sealed testimony, records, and information shall be limited to the
Commission and persons who have signed an Exhibit "A" as provided in this Protective
Agreement, unless such information is released from the restrictions of this Protective
Agreement either through agreement of the parties or after notice to the parties and hearing,
pursuant to the order of the Commission and/or the final order of a court having final
jurisdiction.
(e)Appeal.
Should an appeal from the proceeding be taken, sealed portions of the record may be
forwarded to any court of competent jurisdiction for purposes of an appeal, but under seal as
designated herein for the information and use of the court. If a portion of the recordis forwarded
to a court under seal for the purposes of an appeal, the providing party shall be notified which
portion of the sealed record has been designated by the appealing party as necessary to the record
on appeal.
6.Destruction [or Returni.
Unless otherwise ordered, Confidential Information provided pursuant to a discovery
request and this Protective Agreement, including transcripts of any discovery depositions to
which a claim of confidentiality is made, shall remain under seal, shall continue to be subject to
the protective requirements of this Protective Agreement, and shall be destroyed [shall be
returned to counsel for the providing party] within thirty (30) days after final settlement or
conclusion of this matter, including administrative or judicial review thereof.
7.Use in Pleadings.
Where references to Confidential Information in the sealed record or with the
custodian is required in pleadings, briefs, arguments, or motions (except as provided in
Paragraph 5), it shall be by citation to title or exhibit number or some other description that will
not disclose the substantive Confidential Information contained therein. Any use of or
substantive references to Confidential Information shall be placed in a separate section of the
pleading or brief and submitted to the Commission pursuant to Paragraph 5. This sealed section
shall be serviced only on counsel of record who have signed the non-disclosure agreements set
forth in Exhibit "A" attached to this Protective Agreement, and may, in turn, be disclosed by
them only to individuals who likewise signed Exhibit "A".
PROTECTIVE AGREEMENT BETWEEN
AVISTA, IDAHO POWER, AND PACIFICORP, INTERVENORS,
AND IDAHO PUBLIC UTILITIES COMMISSION STAFF 6
8.Summary of Record.
If deemed necessary by the Commission, a Utility shall prepare a written summary of
the Confidential Information referred to in Orders to be issued to the public and the parties.
9.This Protective Agreement shall become effective on the date hereof.
PROTECTIVE AGREEMENT BETWEEN
AVISTA, IDAHO POWER, AND PACIFICORP, INTERVENORS,
AND IDAHO PUBLIC UTILITIES COMMISSION STAFF
DATED this day of October 2011.
AVISTA CORPORATION
By
Daniel Solander
PacifiCorp dba Rocky Mountain Power
201 S. Main Street, Suite 2300
Salt Lake City, UT 84111
IDAHO. WER COMPANY
Donovan E. Walker
Jason B. Williams
Idaho Power Company
P0 Box 70
Boise, ID 83707-0070
IDAHO PUBLIC UTILITIES
COMMISSION STAFF
By p
Kristine A. Sasser
Deputy Attorney General
Idaho Public Utilities Commission
472 West Washington Street
Boise, ID 83702
By
Michael G. Andrea
Avista Corporation
P0 Box 3727
1411 E. Mission Ave.
Spokane, WA 99220-3727
PACIFICORD
DBA ROCKY MOUNTAIN POWER
By -
Ken Kaufinann
Lovinger Kaufmann LLP
825 NE Multnomah, Suite 925
Portland, OR 97232
PROTECTIVE AGREEMENT BETWEEN
AVISTA, IDAHO POWER, AND PACIFICORP, INTERVENORS,
AND IDAHO PUBLIC UTILITIES COMMISSION STAFF
Nkl4\10'r
DATED this L\day of 6%r2011.
AVISTA CORPORATION IDAHO POWER COMPANY
By
Michael G. Andrea
Avista Corporation
P0 Box 3727
1411 E. Mission Ave.
Spokane, WA 99220-3727
PACIFICORD
DBA ROCKY MOUNTAIN POWER
By
Daniel Solander
PacifiCorp dba Rocky Mountain Power
201 S. Main Street, Suite 2300
Salt Lake City, UT 84111
B
Ken Kaufinann
Lovinger Kaufmann LLP
825 NE Multnomah, Suite 925
Portland, OR 97232
By -- -
Donovan E. Walker
Lisa D. Nordstrom
Idaho Power Company
P0 Box 70
Boise, ID 83707-0070
IDAHO PUBLIC UTILITIES
COMMISSION STAFF
By
Kristine A. Sasser
Deputy Attorney General
Idaho Public Utilities Commission
472 West Washington Street
Boise, ID 83702
DATED this day of October 2011.
AVISTA CORPORATION IDAHO POWER COMPANY
7 / /
By ---
Mic1ae1 U. Andrea
Avista Corporation
P0 Box 3727
1411 F. Mission Ave.
Spokane, WA 99220-3 727
PACIFICORD
DBA ROCKY MOUNTAIN POWER
By
Daniel Solander
PacifiCorp dba Rocky Mountain Power
201 S. Main Street, Suite 2300
Salt Lake City, UT 84111
By
Donovan E. Walker
Lisa D. Nordstrom
Idaho Power Company
P0 Box 70
Boise, ID 83707-0070
IDAHO PUBLIC UTILITIES
COMMISSION STAFF
By
Kristine A. Sasser
Deputy Attorney General
Idaho Public Utilities Commission
472 West Washington Street
Boise, ID 83702
By
Ken Kaufmann
Lovinger Kaufmann LLP
825 NE Multnomah, Suite 925
Portland, OR 97232
PROTECTIVE AGREEMENT BETWEEN
AVISTA, IDAHO POWER. AND PACIFICORP, INTERVENORS,
AND IDAHO PUBLIC UTILITIES COMMISSION STAFF
x
DATED this ) day of January 2012.
THE NORTHWEST AND INTERMOUNTAIN
POWER PRODUCERS COALITION
J.R. SIMPLOT COMPANY
GRAND VIEW SOLAR II
EXERGY DEVELOPMENT GROUP OF
lIMBO, LLC
THE BOARD OF COUNTY COMMISSIONERS
OF ADAMS COUNTY, IDAHO
CLEARWATER PAPER CORPORATION
By,
Gregory M. Adams
Richardson & O'Leary, PLLC
P0 Box 7218
Boise, ID 83702
PROTECTIVE AGREEMENT BETWEEN
AVISTA, IDAHO POWER, AND PACIFICORP, INTERVENORS,
AND IDAHO PUBLIC UTILITIES COMMISSION STAFF
DATED this day of 8et&eer ar 2011.
RENEWABLE ENERGY COALITION
By
Thomas H. Nelson, Attorney
P0 Box 1211
Weiches, OR 97067-1211
PROTECTIVE AGREEMENT BETWEEN
AVISTA, IDAHO POWER, AND PACJFICORP, INTERVENORS,
AND IDAHO PUBLIC UTILITIES COMMISSION STAFF 10
DATED this 25 day of October 2011.
INTERCONNECT SOLAR DEVELOPMENT
LLC
By
R. Greg
Mimura Law Offices, PLLC
2176 E. Franklin Road, Suite 120
Meridian, 11) 83642
PRO113CTIVE AGREEMENT 8E1WEEN
AVTSTA. IDAHO POWER, AND PACIFICORP, INTERVENORS,
AND IDAHO PUBLIC UTILITIES COMMISSION STAFF
DATED this day of201 I
DYNAMIS ENERGY, LLC
BYM
Ronald L Williams
Williams Bradbury, P.C.
1015 W. Hayes Street
Boise, ID 83702
PROTECTIVE AGREEMENT BETWEEN
AVISTA, IDAHO POWER, AND PACIFICORPI INTERVENORS,
AND IDAHO PUBLIC UTILITIES COMMISSION STAFF 12
DATED this Zetf'of March 2012.
NORTH SIDE CANAL COMPANY
TWIN FALLS CANAL COMPANY
Z~By 6
C. Thomas Arkoosh
Capitol Law Group LLC
205 N. 10" Street, 4" Floot
P0 Box 2598
Boise, ID 83701-2598
PROTECTIVE AGREEMENT BETWEEN
AVISTA, IDAHO POWER, AND PACIFICORP, INTERVENORS,
AND IDAHO PUBLIC UTILITIES COMMISSION STAFF 13
DATED this 3 0 day of January 2012.
BIRCH POWER COMPANY
By -
Ted S. Sorenson, P.E.
Birch Power Company
5203 South 1 11h East
Idaho Falls, ID 83404
PROTECTIVE AGREEMENT BETWEEN
AVISTA, IDAHO POWER, AND PACIFICORP, INTERVENORS,
AND IDAHO PUBLIC UTILITIES COMMISSION STAFF 14
DATED this day ofc2011.
BLUE RIBBON ENERGY, LLC
By
Blue Ribbon Energy LLC9 '
4515 S. Ammon Road
Ammon, ID 83406
PROTECTIVE AGREEMENT BETWEEN
AVISTA, IDAHO POWER, AND PACIFICORP, INTERVENORS,
AND IDAHO PUBLIC UTILITIES COMMISSION STAFF 16
DATED this day ofOotober 2011.
RENEWABLE NORTHWEST PROJECT
\01 LL
Dean J. Miller
McDevitt & Miller, LLP
420 W. Bannock Street (83702)
P0 Box 2564
Boise, Id 83701
PROTECTIVE AGREEMENT BETWEEN
AVISTA, IDAHO POWER, AND PAcIFICORP, INTERVENORS,
AND IDAHO PUBLIC UTILITIES COMMISSION STAFF 17
DATED this day ofO 11.
IDAHO CONSERVATION LEAGUE
By 44 Benjamin J. Otto
Idaho Conservation League
710 N. Sixth Street (83 702)
P0 Box 844
Boise, ID 83701
PROTECTIVE AGREEMENT BETWEEN
AVISTA, IDAHO POWER, AND PACIFfCORP, INTERVENORS,
AND IDAHO PUBLIC UTILITIES COMMISSION STAFF 18
DATED this day of October 2011.
SNAKE RIVER ALLIANCE
By
Ken Miller
Snake River Alliance
P0 Box 1731
Boise, ID 83701
PROTECTIVE AGREEMENT BETWEEN
AVISTA, IDAHO POWER, AND PACIFICORP, INTERVENORS,
AND IDAHO PUBLIC UTILITIES COMMISSION STAFF 19
/4fi%
DATED this I i day of May 2012.
IDAHO WIND PARTNERS I LLC
B OAAIJI--j i~
Deborah E. Nelson
Givens Pursley LLP
601 W. Bannock Street
P0 Box 2720
Boise, ID 83701-2720
By
Kelsey J. Nunez
Givens Pursley LLP
601 W. Bannock Street
P0 Box 2720
Boise, ID 83701-2720
DATED this day of May 2012.
RIIDGELLNE ENERGY, LLC
BUL
Dean J. Miller
McDevitt & Miller, LLP
420 W. Bannock Street
P0 Box 2564 (83701)
Boise, ID 83702
DATED this 1st day of August, 2012.
MOUNTAIN AIR
BY
J
Uda LajPinn, P.C.
7 W. Avenue, S
Heja, MT 59601 IL
By
J. Kahle Becker, Idaho
The Alaska Center
1020 W. Main St. Suite 400
Boise, ID 83702
E-mail: [e-mail]
EXHIBIT "A"
I have reviewed the foregoing Protective Agreement dated this <2) day of October
2011 in Case No. GNR-E-1 1-03 and agree to be bound by the terms and conditions of such
Agreement.
/
Jason. B. Williams
Idaho Power Company
Employer or Firm
1221 West Idaho Street, Boise, Idaho 83702
Business Address
Idaho Power Company
Party
November 1. 2011
Date
PROTECTIVE AGREEMENT BETWEEN
AVISTA, IDAHO POWER, AND PACIFICORP, INTERVENORS,
AND IDAHO PUBLIC UTILITIES COMMISSION STAFF 20
EXHIBIT "A"
I have reviewed the foregoing Protective Agreement dated this day of October
2011 in Case No. GNR-E-1I-03 and agree to be bound by the terms and conditions of such
Agreement.
~ic# Wri/rI-
Name /
j:-:hI,, 1'M
Employer or Firm 7/
... W I () i2 19?,7()vL
Business Address
Party
Date
lik 5z//
PROTECTIVE AGREEMENT BETWEEN
AVISTA, IDAHO POWER, AND PACIFICORP, INTERVENORS,
AND IDAHO PUBLIC UTILITIES COMMISSION STAFF 20
EXHIBIT "A"
I have reviewed the foregoing Protective Agreement dated this JD day ofetober-
2011 in Case No. GNR-E-1 1-03 and agree to be bound by the terms and conditions of such
Agreement.
M. g&m>
Name
Itc bwg e0P'3\'?
Employer or Firm
,a&, t' Iófr/c 57, &c,E, /t 7ba
Business Address
Party
/1
Date
PROTECTIVE AGREEMENT BETWEEN
AVISTA, IDAHO POWER, AND PACIFICORP, INTERVENORS,
AND IDAHO PUBLIC UTILITIES COMMISSION STAFF 20
EXHIBIT "A"
I have reviewed the foregoing Protective Agreement dated this 2 1 day of October
2011 in Case No. GNR-E- 11-03 and agree to be bound by the terms and conditions of such
Agreement.
xI &er
Employer or Firm
/221 IV 2T/ &)/ft th
Business Address
Party
Date

PROTECTIVE AGREEMENT BETWEEN
AVISTA, IDAHO POWER, AND PACIFICORP, INTERVENORS,
AND IDAHO PUBLIC UTILITIES COMMISSION STAFF 20
EXHIBIT "A"
I have reviewed the foregoing Protective Agreement dated this day of October
2011 in Case No. GNR-E-1 1-03 and agree to be bound by the terms and conditions of such
Agreement.
E.
Nme
:T bAHO POLA~EJZ (OM L--)L011'/
Employer or Firm
1 ?-?-1 NA 14b - I
Business Address
Party
b LC LE I5 ZOH
Date
PROTECTIVE AGREEMENT BETWEEN
AVISTA, IDAI-10 POWER, AND PACIFICORP, INTERVENORS,
AND IDAHO PUBLIC UTILITIES COMMISSION STAFF 20
EXHIBIT "A"

I have reviewed the foregoing Protective Agreement dated this ZI day of October
2011 in Case No. UNR-E-1 1-03 and agree to be bound by the terms and conditions of such
Agreement.
Nam
(0 ,4'i 6t 7 Employer or Firm
/i21 1,' J/J0 E01, 1d 7OZ
Business Address
Party
Date
PROTECTIVE AGREEMENT BETWEEN
AVISTA, IDAHO POWER, AND PACIFICORF, INTERVENORS,
AND IDAHO PUBLIC UTILITIES COMMISSION STAFF 20
EXHIBIT "A"
I have reviewed the foregoing Protective Agreement dated this iF day of
2011 in Case No. GNR-E-11-03 and agree to be bound by the terms and conditions of such
Agreement.
e (
Name

ftYFz C;
Employer or Firm

Business Address -
Party
Date
PROTECTIVE AGREEMENT BETWEEN
AVJSTA, IDAHO POWER, AND PACIFICORP, INTERVENORS,
AND IDAHO PUBLIC UTILITIES COMMISSION STAFF 20
EXHIBIT "A"
I have reviewed the foregoing Protective Agreement dated this day of October
2011 in Case No. GNR-E-I 1-03 and agree to be bound by the terms and conditions of such
Agreement.
r
Name
-; -
Employer or Firm
Business Address
Party
Date
r'RoTEC'l'lvE AGREEMENT BETwI:EN
AVISTA, IDAHO POWER, AND PACIFICORP, INTERVENORS,
AND IDAHO PUBLIC UTILITIES COMMISSION STAFF 20
EXHIBIT "A"
I have reviewed the foregoing Protective Agreement dated this _day of October
2011 in Case No. GNR-E-11-03 and agree to be bound by the terms and conditions of such
Agreement.
--Th-.
-
Name
4
1
/y7 (j
Employer or Firm
Business Address
Party "J
Date [
PROTECTIVE AGREEMENT BETWEEN
AVISTA, IDAHO POWER, AND PACIFICORI', INTERVENORS,
AND IDAHO PUBliC UTILITIES COMMISSION STAFF 20
EXHIBIT "A"
I have reviewed the foregoing Protective Agreement dated this 24 day of October
2011 in Case No, GNR-E-11-03 and agree to be bound by the terms and conditions of such
Agreement.
J€2 u±
Name
Employer or Fiz1
-2--0 1
Business Address
Party
pcs- o,_t- 24t(
Date
PROTECTIVE AGREEMENT BETWEEN
AVISTA, IDAHO POWER, AND PACIFICORP, INTERVENORS,
AND IDAHO PUBLIC UTILITIES COMMISSION STAFF 20
EXHIBIT "A"
I have reviewed the foregoing Protective Agreement dated this 21S day of October 2011
in Case No. GNR-E-1 1-03 and agree to be bound by the terms and conditions of such
Agreement.
Name
_c9 L,6)
Employer or Firm
ôQ
Business Address
.-D / &- T / k -.-),
Date
EXI11131T "A"
I have reviewed the foregoing Protective Agreement dated this :J day of October
2011 in Case No. GNR-134 1-03 and agree to be bound by the terms and conditions of such
Agreement.
I!
M
Blue -Ribbon Energy LLC
Employer. or Firm
3470 Rich Lane. Armon. 11) 33406
Business Address
Member Manager
Party
Date
4i:i i
I have reviewed theforego Protective Agreementdatedthjs_2lfdayof October .
2011 m Case No Cft'IR-E-11-03 and agree to be bound by the term and conditions of such
Agreement
Name S
• S.. -'&l)s. (cJ C o
Employer or Finn • .

57 ctt W. , A :;j/ •.1/
Business Address
&Lp
Party .5
Date( (
in
PROTECUVE AGREEMENT BETWEEN
AVISTh, IDAHO POWEE, AND PACIFICORP, IN1BRVBNORS
AND IDAHO PUBLIC UTILI1ES COMMISSION STAFF 20
EXHIBrJ' "A"
Lt1
I hot reviewed the foregoing PMective Agreement dated this day of October
2011 in Case No GNR-E.1 1-03 and agree to be bound by the terms and conditions of such
Agreement
:4Jg Plsf
Name':
S;e .:•:4i ..4,1 AJ..
EmpIoyeroFinn "
Irn
puty 417 -
• .tIZ7//i
Date
PROThCflVE AORBEMENTBETWBEN
AVISTA, IDAHO POWER, AND PACIflCORP, INTERVENORS,
ANDiDAHoPuBuCrnLITIES COMMISSION STAFF 20
EAII1HTT "A"
I have reviewed the foregoing Protective Agreement dated this —9—day of October
2011 in Can No. ONR..B-11-03 and agree to be bouàd by the terms and conditions of such
2)
Ne
00f-mownff, 11
A.
Xmez&9j &I3 1 BusincssAddres
PRIYIBCI1VE AQREENT BETWEEN
AWSTA, IDAHO POWER, AND PACIPJCORP, INTERVE}IORS,
AND IDAHO PUBLIC UITUTJES COMMISSION STAPP 20
EXHIBIT "A"
I have reviewed the foregoing Protective Agreement dated the 21 ' day of October 2011
in Case No. GNR-E-1 1-03 and agree to be bound by the terms and conditions of such
Agreement.
bfLr. \N. icK
Name
RC :INC,
Employer or Firm
-ç. SO r 7
Business Address
Party
Date
PROTECTIVE AGREEMENT BETWEEN
AVJSTA, IDAHO POWER. AND PACIFJCORP, INTERVENORS,
AND IDAHO PUBLIC UTILITIES COMMISSION STAFF 20
EXHIBIT "A"
1 have reviewed the foregoing Protective Agreement dated the 21" day of October 2011
in Case No. GNR-E- 11-03 and agree to be bound by the terms and conditions of such
Agreement.
TP&s
Name
-
C, 0p4 LOlw rtp
Employer or Firm
,V5 N.Jo'
'?013& 1b 8370 I
Business Address
r
jsJ ;d ci
Party
6-3- I_
Date -
PROTECTIVE AGREEMENT BETWEEN
AVISTA. IDAHO POWER. AND PACIFICORP, INTERVENORS,
AND IDAHO PUBUC UTILITIES COMMISSION STAFF 20
EXHIBIT "A"

I have reviewed the foregoing Protective Agreement dated this 1 / day of Oteber
2011 in Case No. GNR-E-1 1-03 and agree to be bound by the terms and conditions of such
Agreement.
/dV\a~L&no.4 (-
Name
11 A)f
Employer or Firm J
'iZ / S Lk) * k Z/ z 5-
Business Address c' g 9 7 z-.'f
III Ira) c
Party
Date
PROTECTIVE AGREEMENT BETWEEN
AVISTA, IDAHO POWER, AND PACIFICORP, INTERVENORS,
AND IDAHO PUBLIC UTILITIES COMMISSION STAFF 20
j
P.1
EXHIBIT "A"
I have reviewed the foregoing Protective Agreement dated this ________day of
2011 in Case No. ONR-E-1 1-03 and agree to be bound by the terms and conditions of such
cz9 t:I-•
Agreement
c4;
Employer or Firm
5-r Business Address
Party
t2 k t \ Date
5Q -
-.
( 2-334----
4L
PROTECTIVE AGREEMENT BETWEEN
AVISTA, IDAHO POWER, AND PACKFICORP, INTERVENORS.
AND IDAHO PUBLIC UTILITIES COMMISSION STAFF ZC
EXHIBIT "A"
I have reviewed the foregoing Protective Agreement dated this day of October
2011 in Case No. GNR-E-l1-03 and agree to be bound by the terms and conditions of such
Agreement.
Z, i , 52 ~4- L
RICK STERLING
IDAHO PUBLIC UTILITIES COMMISSION
Employer or Firm
472 W Washington Street, Boise, ID 83702
Business Address
Commission Staff
Party
I?- /
Date /
EXHIBIT "A"
I have reviewed the foregoing Protective Agreement dated this day of October
2011 in Case No. GNR-E-1 1-03 and agree to be bound by the terms and conditions of such
Agreement.
RANDY LOBB
IDAHO PUBLIC UTILITIES COMMISSION
Employer or Firm
472 W Washington Street, Boise, ID 83702
Business Address
Commission Staff
Party
/
Date
EXHIBIT "A"
i-I
I have reviewed the foregoing Protective Agreement dated this day of October
2011 in Case No. GNR-E-1 1-03 and agree to be bound by the terms and conditions of such
Agreement.
IDAHO PUBLIC UTILITIES COMMISSION
Employer or Firm
472 W Washington Street, Boise, ID 83702
Business Address
Commission Staff
Party
1/
Date
EXHIBIT "A"
-
I have reviewed the foregoing Protective Agreement dated this 1) 7/1 day of October
2011 in Case No. GNR-E-11-03 and agree to be bound by the terms and conditions of such
Agreement.
4/Q/1/fTE (41J
NAME
IDAHO PUBLIC UTILITIES COMMISSION
Employer or Firm
472 W Washington Street, Boise, ID 83702
Business Address
Commission Staff
Party
/ ?- /-JL5-///
Date
EXHIBIT "A"
dzczliazLell
I have reviewed the foregoing Protective Agreement dated this day of-Octcr
2011 in Case No. GNR-E-1l-03 and agree to be bound by the terms and conditions of such
Agreement.
IAME%t&() 47L
/
IDAHO PUBLIC UTILITIES COMMISSION
Employer or Firm
472 W Washington Street, Boise, ID 83702
Business Address
Commission Staff
Party
/s///
Date
EXHIBIT "A"
I have reviewed the foregoing Protective Agreement dated this 1 5 day of Qetober
2011 in Case No. GNR-E-11-03 and agree to be bound by the terms and conditions of such
Agreement.
D01
NAME -
IDAHO PUBLIC UTILITIES COMMISSION
Employer or Firm
472 W Washington Street, Boise, ID 83702
Business Address
Commission Staff
Party
Date
/2/) -/Q 1/
EXHIBIT "A"
I have reviewed the foregoing Protective Agreement dated this I S day ofe,i-'
2011 in Case No. GNR-E-1 1-03 and agree to be bound by the terms and conditions of such
Agreement.
COA O-Q- 4J AIL bW
NAME
IDAHO PUBLIC UTILITIES COMMISSION
Employer or Firm
472 W Washington Street, Boise, ID 83702
Business Address
Commission Staff
Party
2Ot I - -
Date
EXHIBIT "A"
TH I214BE
I have reviewed the foregoing Protective Agreement dated this /SZ1ay ofOctebcr
2011 in Case No. GNR-E- 11-03 and agree to be bound by the terms and conditions of such
Agreement.
ff// iL
NAME
IDAHO PUBLIC UTILITIES COMMISSION
Employer or Firm
472 W Washington Street, Boise, ID 83702
Business Address
Commission Staff
Party
Date
EXHIBIT "A"
I have reviewed the foregoing Protective Agreement dated this 7) day of October
2011 in Case No. GNR-E-1 1-03 and agree to be bound by the terms and conditions of such
Agreement.
Name Don C. Reading
Ben Johnson Associates, Inc.0
Employer or Firm
6070 Hill Road, Boise, Idaho 83703
Business Address
Exergy
Party
12/14/2011
Date
EXHIBIT "A"
I have reviewed the foregoing Protective Agreement dated the 2l day of October 2011
in Case No. GNR-E-1 1-03 and agree to be bound by the terms and conditions of such
Agreement.
Qvzrt'-~c C--,
áme 3 /
C?./ DQ(o / Employer or F'irm
fa,i4&ck 1 c'h /,2ao
Business Address
()((f9)

Otp Lof2J?t€-/
Party
Date
PROTECTIVE AGREEMENT BETWEEN
AVISTA, IDAHO POWER, AND PACIFICORP, INTERVENORS,
AND IDAHO PUBLIC UTILITIES COMMISSION STAFF 20
EXHIBIT "A"
I have reviewed the foregoing Protective Agreement dated the 21St day of October 2011
in Case No. GNR-E-11-03 and agree to be bound by the terms and conditions of such
Agreement.
)
7
ool

iIe
7(1"-q W -
Business Address
/-O -gp
Date
PROTECTIVE AGREEMENT BETWEEN
AVISTA, IDAHO POWER, AND PACIFICORP, INTERVENORS,
AND IDAHO PUBLIC UTILITIES COMMISSION STAFF 20
EXHIBIT "A"
I have reviewed the foregoing Protective Agreement dated the 21 S day of October 2011
in Case No. GNR-E-1 1-03 and agree to be bound by the terms and conditions of such
Agreement.
Name
Employer or Firm
61.rJ 93'70
Business Address
GQ'C~",p V)CJ qj ç 014\N-TrA 0 LLC-
Party
1
Date
PROTECTIVE AGREEMENT BETWEEN
AVISTA, IDAHO POWER, AND PACIFICORP, INTERVENORS,
AND IDAHO PUBLIC UTILITIES COMMISSION STAFF 20
/
EXHIBIT "A"
I have reviewed the foregoing Protective Agreement dated the 21 1t day of October
2011 in Case No. GNR-E-11-03 and agree to be bound by the terms and conditions of such
Agreement.
Name
Employer or Finn z, 7j-eT oi& O2J-t ph e,47-
Business Address
Party
Date 1 ,/13I)20 /2_
PROTECTIVE AGREEMENT BETWEEN
AVISTA, IDAHO POWER, AND PACIF!CORP, INTERVENORS,
AND IDAHO PUBLIC UTILITIES COMMISSION STAFF 20
EXHIBIT "A"
I have reviewed the foregoing Protective Agreement dated this 21 day of October 2011
in Case No. GNR-E-11-03 and agree to be bound by the terms and conditions of such
Agreement.
nj
Name I)
Employer or Firm
1 7 0L1
Business Address
Party
/)/ 1
Date
EXHIBIT "A"
I have reviewed the foregoing Protective Agreement dated this 21 day of October 2011
in Case No. GNR-E-1 1-03 and agree to be bound by the terms and conditions of such
Agreement.
/.
(oc
Name
k-e ~2, er A)1ic
Employer or Firm
I?C-) 56 X 73 3 TD<9 370 1
Business Address
LI ,
i Kv~/- /1 (60 ce
Party
Date
EXHIBIT "A"
I have reviewed the foregoing Protective Agreement dated this 21 St day of October 2011
in Case No. GNR-E-11-03 and agree to be bound by the terms and conditions of such
Agreement.
Idaho Windfarms, LLC
Employer or Firm
3145 Geary Blvd #723
San Francisco, CA 94118
Business Address
Idaho Windfarms, LLC
Party
February 29, 2012
Date
EXHIBIT "A"
I have reviewed the foregoing Protective Agreement dated this 21 " day of October 2011
in Case No. GNR-E-1 1-03 and agree to be bound by the terms and conditions of such
Agreement.
Name
<-L A- " V)
Employer or Firm
oc
Business Address
Party
Date
EXHIBIT "A"
I have reviewed the foregoing Protective Agreement dated this 21 " day of October 2011
in Case No. GNR-E-1 1-03 and agree to be bound by the terms and conditions of such
Agreement.
Nam
2
Employer or Firm
JOe(
Business Address
Date
EXHIBIT "A"
I have reviewed the foregoing Protective Agreement dated this 21St day of October 2011
in Case No. GNR-E-1 1-03 and agree to be bound by the terms and conditions of such
Agreement.
A~mc_ e
Name
Employer or Firm
(cO( (A\2J fh 56 hIt... //dO 4A I)o(
Business Address
Party
Date
EXHIBIT "A"
I have reviewed the foregoing Protective Agreement dated this 21 day of October 2011
in Case No. GNR-E-1 1-03 and agree to be bound by the terms and conditions of such
Agreement.
Name ,
4-1~'
Business Address
— I/ )IV,-VeMlj &5x7c;rz~
Patty
Date
EXHIBIT "A"
I have reviewed the foregoing Protective Agreement between Avista Corporation, Idaho
Power Company, Pacificorp, Idaho Public Utilities Commission Staff, and Intervenors, dated
October 21, 2011 in Case No. NR-E- 11-03, and agree to be bound by the terms and conditions of
such Agreement.
Name V 17
ry() Pow PT L
Employer or Firm
PD Rry,/ O5S
Business Address
LLC
Party
Ao-'j ig,
Date
EXHIBIT "A"
I have reviewed the foregoing Protective Agreement between Avista Corporation, Idaho
Power Company, Paciticorp, Idaho Public Utilities Commission Staff, and Intervenors, dated
October 21, 2011 in Case No. NR-E-1 1-03, and agree to be bound by the terms and conditions of
such Agreement. -
-.---C)
Name
Employer or Firm
)K c)Q7 V
Business Address cK ç
Party
Date
i *:i : rrai
I have reviewed the foregoing Protective Agreement dated this 215t day of October 2011
in Case No. GNR-E-1 1-03 and agree to be bound by the terms and conditions of such
Agreement.
Robert-E1hs
General Counsel
Ridgeline Energy LLC
Business Address:
1300 North Northiake Way, 2' Floor, Seattle, WA 98103
206.508.4735
1ega1(r1-en.com
Party:
Ridgeline Energy LLC
Dated:
21 " May, 2012
EXHIBIT "A"
I have reviewed the foregoing Protective Agreement dated this 30 day of July, 2012 in
Case No. GNR-E- 11-03 and agree to be bound by the terms and conditions of such Agreement.
Erin Cecil
Name
Capitol Law Group, PLLC
Employer or Firm
205 N. 10th Street, 4 th Floor, Boise, ID 83702
Business Address
Twin Falls Canal Company, Inc.
North Side Canal Company, Inc.
Big Wood Canal Company
American Falls Reservoir District No. 2
Party
July 31, 2012
Date