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HomeMy WebLinkAbout20110112Staff 1 to IPC.pdfKRISTINE A. SASSER DEPUTY ATTORNEY GENERAL IDAHO PUBLIC UTILITIES COMMISSION PO BOX 83720 BOISE, IDAHO 83720-0074 (208) 334-0357 BARNO. 6618 i~\\ jMi \2 tt\ 4: 21 Street Address for Express Mail: 472 W. WASHINGTON BOISE, IDAHO 83702-5918 Attorneys for the Commission Staff BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE APPLICATION OF IDAHO POWER COMPANY FOR APPROVAL OF A FIRM ENERGY SALES AGREEMENT WITH HIDDEN HOLLOW ENERGY 2, LLC FOR THE SALE AND PURCHASE OF ELECTRIC ENERGY. ) ) CASE NO. IPC-E-10-44 ) ) FIRST PRODUCTION ) REQUEST OF THE ) COMMISSION STAFF ) TO IDAHO POWER COMPANY ) The Staff of the Idaho Public Utilties Commission, by and through its attorney of record, Kristine A. Sasser, Deputy Attorney General, requests that Idaho Power Company (Company; Idaho Power) provide the following documents and information on or before FRIDAY, JANUARY 21, 2011. This Production Request is to be considered as continuing, and Idaho Power is requested to provide, by way of supplementary responses, additional documents that it or any person acting on its behalf may later obtain that wil augment the documents produced. Please provide answers to each question and any supporting workpapers that provide detail or are the source of information used in calculations. The Company is reminded that responses pursuant to Commission Rules of Procedure must include the name and phone number of the person preparing the document, and the name, location and phone number of the record holder and FIRST PRODUCTION REQUEST TO IDAHO POWER 1 JANUARY 12,2011 if different the witness who can sponsor the answer at hearing if need be. Reference IDAPA 31.01.01.228. In addition to the written copies provided as response to the questions, please provide all Excel and electronic fies on CD with formulas activated. REQUEST NO.1: The attched Form 556 (in pertinent par), Certification of Qualifying Facilty (QF) Status for a Small Power Production or Cogeneration Facility, was filed with FERC on January 5, 2011 in Docket No. QFll-97 to obtain self-certification as a QF of the Hidden Hollow Energy 2 LLC facility. Question 8a of the attached Form 556 requires the applicant to identify any facilities with electrical generating equipment located within 1 mile of the electrical generating equipment of the instant facility, and for which any of the entities identified in lines 5a or 5b, or their affiiates, holds at least a 5 percent equity interest. Hidden Hollow has identified the existing Ada County Hidden Hollow generating facilty as located within 1 mile and with common ownership by Fortistar LLC. ~ 3.2 of the Firm Energy Sales Agreement between Idaho Power and Hidden Hollow Energy 2 LLC requires the facility to maintain QF status throughout the term of the Agreement. a. Does Idaho Power believe that the self-certification application fied with FERC for the Hidden Hollow Energy 2 facilty complies with FERC's one-mile separation rule as contained in 18 C.F.R. 292.204(a)(2)? b If not, is Idaho Power aware as to whether Hidden Hollow Energy 2 has requested a waiver pursuant to 18 C.F.R. 292.204(a)(3)? c. If not, does Idaho Power intend to contest Hidden Hollow 2's QF status? Dated at Boise, Idaho, this I;iTt day of January 2011. ~Lu..(l~ Kri me A. Sasser Deputy Attorney General Technical Staff: Rick Sterling i:umisc:prodreq/ipcelO.44ksrps pr l.doc FIRST PRODUCTION REQUEST TO IDAHO POWER 2 JANUARY 12,2011 FERC Form 556 Page 3 -Instructions Filing Fee No filing fee is required if you are submitting a self-certification or self-recertification of your facility as a QF pursuant to 18 CF.R. § 292.207(a). A filing fee is required if you are filing either of the following: (1) an application for Commission certification or recertification of your facility as a QF pursuant to 18 CF.R. § 292.207(b), or (2) a petition for declaratory order granting waiver pursuant to 18 CF.R. §§ 292.204(a)(3) and/or 292.205(c). The current fees for applications for Commission certifications and petitions for declaratory order can be found by visiting the Commission's QF website at www.ferc.gov/QF and clicking the Fee Schedule link. You will be prompted to submit your filing fee, if applicable, during the electronic filing process described on page 2. Required Notice to Utilities and State Regulatory Authorities Pursuant to 18 CF.R. § 292.207(a)(ii), you must provide a copy of your self-certification or request for Commission certification to the utilities with which the facility will interconnect and/or transact, as well as to the State regulatory authorities of the states in which your facility and those utilities reside. Links to information about the regulatory authorities in various states can be found by visiting the Commission's QF website at www..grW.Q.Y1QEand clicking the Notice Requirements link. What to Expect From the Commission After You File An applicant filng a Form 5S6 electronically will receive an email message acknowledging receipt of the filing and showing the docket number assigned to the filing. Such email is typically sent within one business day, but may be delayed pending confirmation by the Secretary of the Commission of the contents of the filing. An applicant submitting a self-certification of QF status should expect to receive no documents from the Commission, other than the electronic acknowledgement of receipt described above. Consistent with its name, a self-certification is a certification by the applicant itself that the facility meets the relevant requirements for QF status, and does not involve a determination by the Commission as to the status of the facility. An acknowledgement of receipt of a self-certification, in particular, does not represent a determination by the Commission with regard to the QF status of the facility. An applicant self-certifying may, however, receive a rejection, revocation or deficiency letter if its application is found, during periodic compliance reviews, not to comply with the relevant requirements. An applicant submitting a request for Commission certification wil receive an order either granting or denying certification of QF status, or a letter requesting additional information or rejecting the application. Pursuant to 18 CF.R. § 292.207(b)(3), the Commission must act on an application for Commission certification within 90 days of the later of the filing date of the application or the fiing date of a supplement, amendment or other change to the application. Waiver Requests 18 CF.R. § 292.204(a)(3) allows an applicant to request a waiver to modify the method of calculation pursuant to 18 CF.R. § 292.204(a)(2) to determine if two facilities are considered to be located at the same site, for good cause. 18 CF.R. § 292.205(c) allows an applicant to request waiver ofthe requirements of 18 CF.R. §§ 292.205(a) and (b) for operating and efficiency upon a showing that the facility will produce significant energy savings. A request for waiver of these requirements must be submitted as a petition for declaratory order, with the appropriate filing fee for a petition for declaratory order. Applicants requesting Commission recertification as part of a request for waiver of one of these requirements should electronically submit their completed Form 556 along with their petition for declaratory order, rather than fiing their Form 556 as a separate request for Commission recertification. Only the filing fee for the petition for declaratory order must be paid to cover both the waiver request and the request for recertification if such requests are made simultaneously. 18 CF.R. § 292.203(d)(2) allows an applicant to request a waiver of the Form 556 filing requirements, for good cause. Applicants filing a petition for declaratory order requesting a waiver under 18 CF.R. § 292.203(d)(2) do not need to complete or submit a Form 556 with their petition. ()Fi/- j7 FEDERAL ENERGY REGULATORY COMMISSION WASHINGTON, DC Certification of Qualifying Facility (QF) Status for a Small Power Production or Cogeneration Facility OMS Control #1902-0075 Expiration 5/3112013 Form 556 1 a Full name of applicant (legal entity on whose behalf qualifying facility status is sought for this facility) HIDDEN HOLLOW ENERGY 2 LLC 1 b Applicant street address 5087 JUNCTION ROAD 1c City 1 d State/province LOCKPORT NEW YORK 1 e Postal code 1 f Country (if not United States)1 9 Telephone number 14094 716-439-1004 1 h Has the instant facility ever previously been certified as a QF?Yes 0 No rg 1i If yes, provide the docket number of the last known QF filing pertaining to this facility:QF -- ._...._._M..._._......_...-_..~.................._... 1j Under which certification process is the applicant making this filing? rg Notice of self-certification o Application for Commission certification (requires filing C (see note below)fee; see "Filing Fee" section on page 3) 0 Note: a notice of self-certification is a notice by the applicant itself that its facility complies with the requirements for+-QF status. A notice of self-certification does not establish a proceeding, and the Commission does not review aCO E notice of self-certification to verify compliance. See the "What to Expect From the Commission After You File"~section on page 3 for more information.~C 1k What type(s) of QF status is the applicant seeking for its facility? (check all that apply)- C k8 Qualifying small power production facility status o Qualifying cogeneration facility status0.-11 What is the purpose and expected effective date(s) ofthis filing?+- COU k8 Original certification; facility expected to be installed by 9/5/11 and to begin operation on 10/3/11.- 0.0.Change(s) to a previously certified facility to be effective on c:(identify type(s) of change(s) below, and describe change(s) in the Miscellaneous section starting on page 19) o Name change and/or other administrative change(s) Change in ownership Change(s) affecting plant equipment, fuel use, power production capacity and/or cogeneration thermal output Supplement or correction to a previous filing submitted on (describe the supplement or correction in the Miscellaneous section starting on page 19) 1 m If any of the following three statements is true, check the box(es) that describe your situation and complete the form to the extent possible, explaining any special circumstances in the Miscellaneous section starting on page 19. o The instant facility complies with the Commission's QF requirements by virtue of a waiver of certain regulationspreviously granted by the Commission in an order dated (specify any other relevant waiver orders in the Miscellaneous section starting on page 19) o The instant facility would comply with the Commission's QF requirements if a petition for waiver submittedconcurrently with this application is granted The instant facility complies with the Commission's regulations, but has special circumstances, such as the o employment of unique or innovative technologies not contemplated by the structure of this form, that make the demonstration of compliance via this form difficult or impossible (describe in Mise. section starting on p. 19) FERC Form 556 Page 6 - All Facilities 2a Name of contact person 2b Telephone number DAVID B JOHNSON 518-465-9319 2c Which of the following describes the contact person's relationship to the applicant? (check one) i:D Applicant (self)D Employee, owner or partner of applicant authorized to represent the applicant 0 D Employee of a company affliated with the applicant authorized to represent the applicant on this matter.-+- CO r8 Lawyer, consultant, or other representative authorized to represent the applicant on this matterE2d Company or organization name (if applicant is an individual, check here and skip to line 2e)lo~READ AND LANIADO LLPi:- +-2e Street address (if same as Applicant, check here and skip to line 3a)C.:U CO 25 EAGLE STREET+-i:0U 2f City 2g State/province ALBANY NEW YORK 2h Postal code 2i Country (if not United States) 10072 3a Facility namei:HIDDEN HOLLOW ENERGY 2 LLC0 +-3b Street address (if a street address does not exist for the facility, check here and skip to line 3c) LJCOu010300SEAMENS GULCH ROAD.. ""i: CO 3c Geographic coordinates: If you indicated that no street address exists for your facility by checking the box in line 3b,i:then you must specify the latitude and longitude coordinates of the facility in degrees (to three decimal places). Use0the following formula to convert to decimal degrees from degrees, minutes and seconds: decimal degrees =.-+- CO degrees + (minutes/60) + (seconds/3600).See the "Geographic Coordinates" section on page 4 for help. If you u provided a street address for your facility in line 3b, then specifying the geographic coordinates below is optionaL.~ +-D East (+)r8 North (+)i:Longitude 116.286 degrees Latitude 43. 698 degrees(J r8 West (-)D South (-)""~3d City (if unincorporated, check here and enter nearest city) D 3e State/province +-IDAHO-BOISE U CO 3f County (or check here for independent city)3g Country (if not United States)u. ADA Identify the electric utilities that are contemplated to transact with the facility. VI 4a Identify utilty interconnecting with the facility(J +-IDAHO POWER CORPORATION +-~4b Identify utilities providing wheeling service or check here if none 0 C'IDAHO POWER CORPORATIONi: +-4c Identify utilties purchasing the useful electric power output or check here if noneU CO IDAHO POWER CORPORATIONVIi: CO 4d Identify utilities providing supplementary power, backup power, maintenance power, and/or interruptible powerloi-service or check here if none IZ FERC Form 556 Page 7 - All Facilities Sa Direct ownership as of effective date or operation date: Identify all direct owners of the facility holding at least 10 percent equity interest. For each identified owner, also (1) indicate whether that owner is an electric utility, as defined in section 3(22) of the Federal Power Act (16 U.S.C 796(22)), or a holding company, as defined in section 1262(8) of the Public Utility Holding Company Act of 2005 (42 U.s.C 16451 (8)), and (2) for owners which are electric utilities or holding companies, provide the percentage of equity interest in the facility held by that owner. If no direct owners hold at least 10 percent equity interest in the facility, then provide the required information for the two direct owners with the largest equity interest in the facility.Electric utility or If Yes, holding % equity Full legal names of direct owners company interest 1 )HIDDEN HOLLOW ENERGY 2 LLC Yes IZ No 0 100 % 2)Yes 0 No 0 % 3)Yes 0 No 0 % 4)Yes 0 No 0 % 5)Yes 0 No 0 % 6)Yes 0 No 0 % 7)Yes 0 No 0 % 8)Yes 0 No 0 % C0 9)Yes 0 No 0 % +-ro 10)Yes 0 No 0 %i- OJa.o Check here and continue in the Miscellaneous section starting on page 19 if additional space is needed0 '"Sb Upstream (Le., indirect) ownership as of effective date or operation date: Identify all upstream (Le., indirect) ownersCof the facility that both (1) hold at least 10 percent equity interest in the facility, and (2) are electric utilities, asroa.defined in section 3(22) of the Federal Power Act (16 U.s.C 796(22)), or holding companies, as defined in section ..1262(8) of the Public Utilty Holding Company Act of 2005 (42 U.S.C 16451 (8)). Also provide the percentage of Vl equity interest in the facility held by such owners. (Note that, because upstream owners may be subsidiaries of onei- OJ another, total percent equity interest reported may exceed 100 percent.) C Š Check here if no such upstream owners exist.0 0/ equity Full legal names of electric utility or holding company upstream owners interest 1 )HIDDEN HOLLOW ENERGY LLC 100 % 2)FORITSTAR METHANE GROUP LLC 100 % 3)FORTISTAR RENEWABLES LLC 100 % 4)FORTISTAR PROJECTS LLC 100 % 5)FORTISTAR LLC 100 % 6)% 7)% 8)% 9)% 10)% o Check here and continue in the Miscellaneous section starting on page 19 if additional space is needed Sc Identify the facility operator FORTISTAR SERVICES LLC FERC Form 556 Page 8 - All Facilities 6a Describe the primary energy input: (check one main category and, if applicable, one subcategory) IZ Biomass (specify) IZ Landfill gas o Manure digester gas o Municipal solid waste o Sewage digester gas o Wood D Renewable resources (specify) o Hydro power - river o Hydro power - tidal o Hydro power - wave o Solar - photovoltaic o Solar - thermal D Geothermal D Fossil fuel (specify) o Coal (not waste) o Fuel oil/diesel o Natural gas (not waste) Other fossil fuel o (describe on page 19) o Other biomass (describe on page 19) 0 Wind o Other renewable resource D Other (describe on page 19)(describe on page 19) 6b If you specified "waste" as the primary energy input in line 6a, indicate the type of waste fuel used: (check one) D Waste (specify type below in line 6b) ..:Ja.C ~O'~(JCW D Waste fuel listed in 18 CF.R. § 292.202(b) (specify one of the following) o Anthracite culm produced prior to July 23, 1985 o Anthracite refuse that has an average heat content of 6,000 Btu or less per pound and has an averageash content of 45 percent or more o Bituminous coal refuse that has an average heat content of 9,500 Btu per pound or less and has ànaverage ash content of 25 percent or more Top or bottom subbituminous coal produced on Federal lands or on Indian lands that has been determined to be waste by the United States Department of the Interior's Bureau of Land Management o (BLM) or that is located on non-Federal or non-Indian lands outside of BLM's jurisdiction, provided that the applicant shows that the latter coal is an extension of that determined by BLM to be waste Coal refuse produced on Federal lands or on Indian lands that has been determined to be waste by the o BLM or that is located on non- Federal or non-Indian lands outside of BLM's jurisdiction, provided that applicant shows that the latter is an extension of that determined by BLM to be waste o Lignite produced in association with the production of montan wax and lignite that becomes exposedas a result of such a mining operation o Gaseous fuels (except natural gas and synthetic gas from coal) (describe on page 19) Waste natural gas from gas or oil wells (describe on page 19 how the gas meets the requirements of 18 o CF.R § 2.400 for waste natural gas; include with your fiing any materials necessary to demonstrate compliance with 18 CF.R. § 2.400) o Materials that a government agency has certified for disposal by combustion (describe on page 19) o Heat from exothermic reactions (describe on page 19) 0 Residual heat (describe on page 19) o Used rubber tires 0 Plastic materials 0 Refinery off-gas 0 Petroleum coke Other waste energy input that has little or no commercial value and exists in the absence of the qualifying D facility industry (describe in the Miscellaneous section starting on page 19; include a discussion ofthe fuel's lack of commercial value and existence in the absence of the qualifying facility industry) 6c Provide the average energy input, calculated on a calendar year basis, in terms of Btu/h for the following fossil fuel energy inputs, and provide the related percentage of the total average annual energy inputto the facility (18 CF.R. § 292.202(j). For any oil or natural gas fuel, use lower heating value (18 CF.R. § 292.202(m)). Fuel Natural gas Oil-based fuels Coal Annual average energy input for specified fuel Percentage of total annual energy input 0% 0% 0% c o Btu/h o Btu/h o Btu/h FERC Form 556 Page 9 - All Facilities co+-ro E~~C .ç uroLL rouc..u(Ji- Indicate the maximum gross and maximum net electric power production capacity of the facility at the point(s) of delivery by completing the worksheet below. Respond to all items. If any of the parasitic loads and/or losses identified in lines 7b through 7e are negligible, enter zero for those lines. 7a The maximum gross power production capacity at the terminals of the individual generator(s) under the most favorable anticipated design conditions 7b Parasitic station power used at the facility to run equipment which is necessary and integral to the power production process (boiler feed pumps, fans/blowers, offce or maintenance buildings directly related to the operation of the power generating facility, etc.). If this facility includes non- power production processes (for instance, power consumed by a cogeneration facility's thermal host) , do not include any power consumed by the non-power production activities in your reported parasitic station power. 3,200 kW 200 kW 7c Electrical losses in interconnection transformers o kW 7d Electrical losses in Ac/DC conversion equipment, if any o kW 7e Other interconnection losses in power lines or facilities (other than transformers and AC/DC conversion equipment) between the terminals of the generator(s) and the point of interconnection with the utilty 7f Total deductions from gross power production capacity = 7b + 7c + 7d + 7e o kW 200.0 kW 7g Maximum net power production capacity = 7a - 7f 3, OOG. 0 kW 7h Description of facility and primary components: Describe the facility and its operation. Identify all boilers, heat recovery steam generators, prime movers (any mechanical equipment driving an electric generator), electrical generators, photovoltaic solar equipment, fuel cell equipment and/or other primary power generation equipment used in the facility. Descriptions of components should include (as applicable) specifications of the nominal capacities for mechanical output, electrical output, or steam generation of the identified equipment. For each piece of equipment identified, clearly indicate how many pieces of that type of equipment are included in the plant, and which components are normally operating or normally in standby mode. Provide a description of how the components operate as a system. Applicants for cogeneration facilities do not need to describe operations of systems that are clearly depicted on and easily understandable from a cogeneration facility's attached mass and heat balance diagram; however, such applicants should provide any necessary description needed to understand the sequential operation of the facilty depicted in their mass and heat balance diagram. If additional space is needed, continue in the Miscellaneous section starting on page 19. THE FACILITY UTILIZES LANDFILL GAS FOR ITS HEAT INPUT. THE LANDFILL GAS IS COLLECTED BY A PIPELINE GATHERING SYSTEM AT A COUNTY LANDFILL. THE LANDFILL GAS IS THE HEAT INPUT FOR TWO INTERNAL COMBUSTION RECIPROCATING ENGINE-GENERATORS. THE GENERATORS ARE CONNECTED TO THE LOCAL UTILITIES DISTRIBUTION SYSTEM. FERC Form 556 Page 10- Small Power Production Information Required for Small Power Production Facility If you indicated in line 1 k that you are seeking qualifying small power production facility status for your facility, then you must respond to the items on this page. Otherwise, skip page 10. Pursuant to 18 CF.R. § 292.204(a), the power production capacity of any small power production facility, together with the power production capacity of any other small power production facilities that use the same energy resource, are owned by the same person(s) or its affliates, and are located at the same site, may not exceed 80 megawatts. To demonstrate compliance with this size limitation, or to demonstrate that your facility is exempt from this size limitation under the Solar, Wind, Waste, and Geothermal Power Production Incentives Act of 1990 (Pub. L. 101-575, 104 Stat. 2834 (1990) as amended by Pub. L. 102-46, 105 Stat. 249 (1991)), respond to lines 8a through 8e below (as applicable). 8a Identify any facilities with electrical generating equipment located within 1 mile of the electrical generating equipment of the instant facility, and for which any of the entities identified in lines Sa or 5b, or their affiliates, holds at least a 5 percent equity interest. OJ Check here if no such facilities exist.L jucVlFacility location Root docket #Maximum net powerCOC(city or county, state)(if any)Common owner(s)production capacity 0. .0 E +-l)ADA COUNTY QF06 128 FORTISTAR LLC 3,000 kW CO - 0 +---u E 2)QF -kW4-:.--0 3)kWcOJQF---0 N +-V'D Check here and continue in the Miscellaneous section starting on page 19 if additional space is needed CO ..u.:+-8b The Solar, Wind, Waste, and Geothermal Power Production Incentives Act of 1990 (Incentives Act) provides +-Š exemption from the size limitations in 18 CF.R. § 292.204(a) for certain facilities that were certified prior to 1995.~ OJ Are you seeking exemption from the size limitations in 18 CF.R. § 292.204(a) by virtue ofthe Incentives Act?U D Yes (continue at line 8c below)I2 No (skip lines 8c through 8e) 8e Was the original notice of self-certification or application for Commission certification of the facility filed on or before December 31, 1994?Yes No 8d Did construction of the facility commence on or before December 31, 1999?Yes 0 No 0 8e If you answered No in line 8d, indicate whether reasonable dilgence was exercised toward the completion of the facility, taking into account all factors relevant to construction? Yes 0 No 0 If you answered Yes, provide a brief narrative explanation in the Miscellaneous section starting on page 19 of the construction timeline (in particular, describe why construction started so long after the facility was certified) and the diligence exercised toward completion of the facility. OJ Vl Pursuant to 18 CF.R. § 292.204(b), qualifying small power production facilities may use fossil fuels, in minimal+-U C amounts, for only the following purposes: ignition; start-up; testing; flame stabilization; control use; alleviation orCOJprevention of unanticipated equipment outages; and alleviation or prevention of emergencies, directly affectingCOE-the public health, safety, or welfare, which would result from electric power outages. The amount offossil fuels0.OJ E i.used for these purposes may not exceed 25 percent of the total energy input of the facility during the 12-month.-::period beginning with the date the facility first produces electric energy or any calendar year thereafter.0 0-U OJ4-c:9a Certification of compliance with 18 CF.R. § 292.204(b) with respect to uses of fossil fuel:0 OJCVl I2 Applicant certifies that the facility will use fossil fuels exclusively for the purposes listed above.0 ::''¡ CO OJ 9b Certification of compliance with 18 CF.R. § 292.204(b) with respect to amount of fossil fuel used annually:U ::~Ll Applicant certifies that the amount of fossil fuel used at the facility wil not, in aggregate, exceed 25+-..I2 percent of the total energy input of the facility during the 12-month period beginning with the date the~ OJ +- U Š facility first produces electric energy or any calendar year thereafter. FERC Form 556 Page 19 - All Facilties Miscellaneous Use this space to provide any information for which there was not sufficient space in the previous sections of the form to provide. For each such item of information clearly identify the line number that the information belongs to. You may also use this space to provide any additional information you believe is relevant to the certification of your facility. Your response below is not limited to one page. Additional page(s) wil automatically be inserted into this form if the length of your response exceeds the space on this page. Use as many pages as you require. CERTIFICATE OF SERVICE I HEREBY CERTIFY THAT I HAVE THIS 12TH DAY OF JANUARY 2011, SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER, IN CASE NO. IPC-E-I0-44, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING: DONOV AN E WALKER LISA D NORDSTROM IDAHO POWER COMPANY POBOX 70 BOISE ID 83707-0070 E-MAIL: dwalker(fidahopower.com Inordstrom(fidahopower .com RANDY C ALLPHIN ENERGY CONTRACT ADMIN IDAHO POWER COMPANY PO BOX 70 BOISE ID 83707-0070 E-MAIL: rallphin(fidahopower.com THOMAS J GESICKI PRESIDENT FORTISTAR METHANE GROUP 5087 JUNCTION ROAD LOCKPORTNY 14094 SECRETARY CERTIFICATE OF SERVICE