20110718DOE-1-1 through DOE-1-23 to IPC.pdf

Department of Energy
Washington, DC 20585 RECE! D
20" JUL '8 AM 9: 00
Ms. Jean D. Jewell, Secretary
Idaho Public Utilties Commission
472 West Washington Street
P.o. Box 83720
Boise, Idaho 83720-0074
July 12,2011
Re: Case No. IPC-E-II-08
Dear Ms. Jewell:
Two copies of the United States Department of Energy's first and second requests for
information and production of documents in the above-captioned proceeding are enclosed
herewith for filing.
Than you for your kind attention.
Very truly yours,
J~~-..Q ~
Arthur pe~ ;ru~er
Attorney for
United States Deparment of Energy
1000 Independence Avenue SW
Washington, DC 20585
arhur.bruder~hq.doe.gov
phone: [phone]
cell: [phone]
fax: [phone]
* Printed with soy ink on recycled paper
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )
IDAHO POWER COMPANY FOR AUTHORITY )
TO INCREASE ITS RATES AND CHARGES )
FOR ELECTRIC SERVICE TO ITS )
CUSTOMERS IN THE STATE OF IDAHO. )
)
CASE NO. IPC-E-11-08
U.S. DOE's First Interrogatories
and Production Requests
to Idaho Power Company
The United States Deparment of Energy, by and through its attorney of record,
Arthur Perry Bruder, hereby requests that Idaho Power Company ("the Company" or
"Idaho Power") provide the following documents and information as soon as possible,
but no later than THURSDAY, AUGUST 2, 2011.
As per the Commission's Rules of Procedure, responses must include the name(s)
and phone number of the person(s) who prepared the document, and the name(s),job
title(s), location(s) and phone number(s) ofthe record holder(s) and, if different, the
witness(es) who can sponsor the answer at hearing if need be.
These Interrogatories and Production Requests are to be considered as continuing,
and the Company is requested to provide, by way of supplementar responses, additional
documents that it or any person acting on its behalf may later obtain that constitute
relevant augmentation of the documents produced.
Please provide answers to each question, supporting workpapers that provide
detail or are the source of information used in calculations, and the name, job title and
telephone number of the person preparing the çlocuments.
Please provide all Excel and electronic fies on CD with formulas activated.
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:::i\...o
IDAHO POWER COMPANY CASE No. IPC-E-11-08
DOE's FIRST REQUEST FOR INFORMATION AND PRODUCTION OF DOCUMENTS
DOE-I-I.
DOE-1-2.
DOE-1-3.
DOE-1-4.
DOE-1-5.
DOE-1-6.
Please provide copies of all responses to requests for information
submitted by other paries to Idaho Power in this docket. This is an
ongoing request.
Please provide Exhibit Nos. 28 and 29 in native format (e.g., Excel, Word)
with all links and formulas intact (if applicable). (M. Larkin, p. 8.)
Please provide the workpapers referred to by Mr. Larkin on page 8, 15-16,
in native format (e.g., Excel, Word) with all links and formulas intact (if
applicable).
Please explain what Mr. Larkin is referrng to when he says "maximum
demand imposed on the Company's system." (M. Larkin, pp. 10-11.)
Per Mr. Larkin, pages 10-11, "due to the hydro production capabilty of
the Company, a portion of the hydro and thermal generating plant
investment has historically been classified as energy-related."
(a) Is it Mr. Larkin's testimony that a portion ofIdaho Power's hydro and
thermal generating plant investment has historically been classified as
energy-related solely because of the fact that Idaho Power has hydro
production capabilty?
(b) How does control of hydro production capability support the
conclusion that a portion of Idaho Power's hydro and thermal
generating plant investment should be classified as energy-related?
Per Mr. Larkin, page 18, "(t)he energy portion of the steam and hydro
production investment has been determined by use of the Idaho
jursdictional load factor of 53.88 percent."
(a) Please provide Mr. Larkin's workpapers that show the computation of
the Idaho jurisdictional load factor.
(b) In which Idaho Power general rate case was the Idaho jurisdictional
load factor first used to classify a portion of Idaho Power's hydro and
thermal generating plant investment as energy -related?
(c) Please list each Idaho Power general rate case in the last twenty years
where the Idaho jurisdictional load factor was used to classify a
portion of Idaho Power's hydro and thermal generating plant
investment as energy -related? Please also provide the Idaho
jurisdictional load factor that was used in each of these cases.
(d) Please provide Idaho Power's actul anual jursdictional load factor
for the last ten calendar years, 2001 through 2010, including the
annual peak in megawatts, the time of the anual peak, and the anual
energy in megawatt-hours.
2
IDAHO POWER COMPANY CASE No. IPC-E-11-08
DOE's FIRST REQUEST FOR INFORMATION AND PRODUCTION OF DOCUMENTS
DOE-1-7.
DOE-1-8.
(e) Please provide Idaho Power's weather normalized anual
jursdictional load factor for the last ten calendar years, 2001 through
2010, including the weather normalized peak in megawatts and the
weather normalized energy in megawatt-hours.
(f) Please provide Idaho Power's anual jurisdictional load factor for the
most recent 12 month period (e.g., July 2010 through June 2011),
including the peak in megawatts, the time of the peak, and the energy
in megawatt-hours.
(g) Please provide Idaho Power's anual jurisdictional load factor for the
12 months ended July 2011, August 2011, and September 2011 when
that information becomes available, including the peak in megawatts,
the time of the peak, and the energy in megawatt-hours.
Per Exhibit No. 30, page 6, "(t)he base period is equivalent to a low load
or off-peak time period where loads are at the lowest, normally during the
nighttime hours."
(a) For the sumer months of June through August 2010, please list the
hours Mr. Larkin typically considers to be base period hours.
(b) For the non-sumer months of December 2009 through February
2010, please list the hours Mr. Larkin typically considers to be base
period hours.
(c) For the non-summer months of September 2009 thòugh November
2009, please list the hours Mr. Larkin typically considers to be base
period hours.
(d) For the non-sumer months of March 2010 through May 2010,
please list the hours Mr. Larkin typically considers to be base period
hours.
Per Exhibit No. 30, page 6, "(t)he intermediate time period represents the
shoulder hours which are driven by the mid-peak loads that typically occur
throughout the winter daytime and in the early morning and late evening
during the summer months."
(a) For the sumer months of June through August 2010, please list the
hours Mr. Larkin typically considers to be intermediate period hours.
(b) For the non-sumer months of December 2009 through Februar
2010, please list the hours Mr. Larkin typically considers to be
intermediate period hours.
(c) For the non-summer months of September 2009 through November
2009, please list the hours Mr. Larkin typically considers to be
intermediate period hours.
3
IDAHO POWER COMPANY CASE No. IPC-E-11-08
DOE's FIRST REQUEST FOR INFORMATION AND PRODUCTION OF DOCUMENTS
(d) For the non-summer months of March 2010 through May 2010,
please list the hours Mr. Larkin typically considers to be intermediate
base period hours.
DOE-1-9. Per Exhibit No. 30, page 6, "(t)he peak category is driven by the peak
loads that occur during summer afternoons and evenings."
(a) For the summer months of June through August 2010, please list the
hours Mr. Larkin typically considers to be peaking period hours.
(b) Does Mr. Larkin typically consider peaking hours to exclude
weekends and holidays? Please explain.
DOE-1-10. Per Exhibit No. 30, page 6, "(t)he base and intermediate loads on the
Company's system are typically served by the same generation resources."
(a) What does the Company mean by base loads on the Company's
system? Are those loads in what the Company considers to be the
base period?
(b) What does the Company mean by intermediate loads on the
Company's system? Are those loads in what the Company considers
to be the intermediate period? Are those loads incremental to base
loads?
(c) To which generation resources is the Company referring?
(d) Please explain how base loads on the Company's system were
typically served by the same generation resources during the months
of June 2010 through August 2010?
(e) Please explain how intermediate loads on the Company's system were
typically served by the same generation resources during the months
of June 2010 through August 2010?
(f) Please explain how base loads on the Company's system were
actully served by the same generation resources, if they were served
by the same generation resources, on each of the monthly system peak
days for the months of June 2010 through August 2010, and for each
hour on each of those three days?
(g) Please explain how intermediate loads on the Company's system were
actually served by the same generation resources, if they were served
by the same generation resources, on each of the monthly system peak
days for the months of June 2010 through August 2010, and for each
hour on each of those three days?
(h) Please explain how base loads on the Company's system were
actually served by the same generation resources, if they were served
by the same generation resources, on each of the monthly system peak
days for the months of December 2009 through Februar 2010, and
for each hour on each of those three days?
4
IDAHO POWER COMPANY CASE No. IPC-E-11-08
DOE's FIRST REQUEST FOR INFORMATION AND PRODUCTION OF DOCUMENTS
(i) Please explain how intermediate loads on the Company's system were
actually served by the same generation resources, if they were served
by the same generation resources, on each of the monthly system peak
days for the months of December 2009 through Februar 2010, and
for each hour on each of those three days?
DOE-I-II. Please provide in Excel format the following information on an hourly
basis for the calendar years 2008 through 2010, for the months Januar
2011 through June 2011, and for the months of July 2011 though
September 2011 as information becomes available:
(a) Idaho Power's system loads.
(b) Idaho Power's share of production from the Jim Bridger coal-fired
plant.
(c) Idaho Power's share of production from the Valmy coal-fired plant.
(d) Idaho Power's share of production from the Boardman coal-fired
plant.
(e) Idaho Power's production from the Brownlee hydro plant.
(f) Idaho Power's production from the Oxbow hydro plant.
(g) Idaho Power's production from the Hells Canyon hydro plant.
(h) Idaho Power's total hydro production from the Upper-Snake area,
including the American Falls, Milner, and Shoshone Falls hydro
plants.
(i) Idaho Power's hydro production from the Mid-Snake area from the
Swan Falls, Twin Falls, Upper Salmon A, and Upper Salmon B hydro
plants.
G) Idaho Power's hydro production from the Mid-Snake area from the
Bliss, C. J. Strike, and Lower Salmon hydro plants.
(k) Idaho Power's total hydro production from the North Fork Payette
and and South Central Idaho areas, including the Cascade, Clear
Lake, Lower Malad, Thousand Springs, and Upper Malad hydro
plants.
(1) Idaho Power's production from the Danskin natual gas-fired
combustion turbine plant.
(m) Idaho Power's production from the Bennett Mountain natural gas-
fired combustion turbine.
(n) Idaho Power's production from the Salmon diesel-fired plant.
(0) Idaho Power's wholesale market purchases booked to Account 555.1.
(P) Idaho Power's purchases from qualifying facilties booked to Account
555.2.
5
IDAHO POWER COMPANY CASE No. IPC-E-11-08
DOE's FIRST REQUEST FOR INFORMATION AND PRODUCTION OF DOCUMENTS
(q) Any other generation or purchases not listed above that were available
to Idaho Power to meet its hourly system load for the requested time
period. Please explain the source of any energy if Idaho Power
responds to this request.
DOE-l-12. For each purchase whose cost is booked to Account 555.1, please provide
in Excel format with all formulas and links intact the following by month
for the calendar years 2008 through 2010, for the months Januar 2011
through June 2011, and for the months of July 2011 through September
2011 as information becomes available:
(a) Transaction number, transaction date, duration, type (for example,
firm energy), total capacity and/or energy purchased, total cost,
applicable pricing mechansm ($/MW, $/MWh, or some
combination), and specific prices.
DOE-I-B. For each purchase whose cost is booked to Account 555.2, please provide
in Excel format with all formulas and links intact the following by month
for the calendar years 2008 through 2010, for the months Januar 2011
through June 2011, and for the months of July 2011 through September
2011 as information becomes available:
(a) Transaction number, transaction date, duration, type (for example,
firm energy), total capacity and/or energy purchased, total cost,
applicable pricing mechanism ($/MW, $/MWh, or some
combination), and specific prices.
DOE-1-14. In Idaho Power's 2011 Integrated Resource Plan, page 28, Idaho Power
states, "(w)ater storage in Brownlee Reservoir also enables the Hells
Canyon projects to provide the major portion of Idaho Power's peaking
and load following capabilty."
(a) What was the output of each of the Hells Canyon projects (Brownlee,
Oxbow, and Hells Canyon hydro plants) at the hour of Idaho Power's
anual system peak for the years 2006 through 201 O? Please also
provide the date and time of the anual system peaks.
(b) What was the output of each of the Hells Canyon projects (Brownlee,
Oxbow, and Hells Canyon hydro plants) at the hour of Idaho Power's
minimum mornng load on the day Idaho Power established its anual
system peak for the years 2006 through 201 O? Please also provide the
time of the minimum morning load on those days.
(c) What does Idaho Power consider to be its next most importt source
of peaking capabilty after the. Brownlee, Oxbow, and Hells Canyon
hydro plants, and why?
(d) Please explain what the Company means by load following capabilty.
6
IDAHO POWER COMPANY CASE No. IPC-E-11-08
DOE's FIRST REQUEST FOR INFORMATION AND PRODUCTION OF DOCUMENTS
(e) Please explain how Idaho Power typically utilizes its Hells Canyon
projects for load following purposes during the sumer months of
June through August.
(f) Please explain how Idaho Power typically utilizes its Hells Canyon
projects for load following purposes during the winter months of
December through Februar.
(g) Please explain how Idaho Power actually used the Hells Canyon
projects for load following puroses for each hour on each of the
monthly system peak days for the months of June 2010 through
August 2010.
(h) Please explain how Idaho Power actually used the Hells Canyon
projects for load following purposes for each hour on each of the
monthly system peak days for the months of December 2009 through
February 2010.
DOE-1-16. In Idaho Power's 2011 Integrated Resource Plan, page 31, Idaho Power
states, "(t)he Danskin plant operates as needed to support system load"
and "(t)he Bennett Mountain plant also operates as needed to support
system load."
(a) What does the Company mean by "operates as needed to support
system load"?
(b) What is the load following capability of those combustion turbines,
and to what extent does Idaho Power use those combustion turbines
for load following? Using the month of July 2010 as an. example,
provide specific examples of hours in which Idaho Power used these
combustion turbines for load following purposes.
(c) What are the input parameters that are used by Idaho Power in its
production simulation modeling for the 179 megawatt Siemens 501F
combustion turbine at the Danskin plant? In particular, what is Idaho
Power's assumed minimum loading on this unit for production
simulation purposes.
(d) What are the input parameters that are used by Idaho Power in its
production simulation modeling for the two 46 megawatt Siemens-
Westinghouse W251 B 12A combustion turbines at the Danskin plant?
In paricular, what is Idaho Power's assumed minimum loading on
each of these units for production simulation puroses.
(e) What are the input parameters that are used by Idaho Power in its
production simulation modeling for the 173 megawatt Siemens-
Westinghouse 501F combustion turbine at the Bennett Mountain
plant? In particular, what is Idaho Power's assumed minimum
loading on this unit for production simulation puroses.
7
IDAHO POWER COMPANY CASE No. IPC-E-11-08
DOE's FIRST REQUEST FOR INFORMATION AND PRODUCTION OF DOCUMENTS
DOE-l-17. Please answer the following regarding Idaho Power's share of the Jim
Bridger coal-fired plant.
(a) What is the maximum sumer capacity associated with Idaho
Power's share of each ofthe four unts at this plant?
(b) How does Idaho Power schedule its share of the output from the four
units at the Jim Bridger plant?
(c) How does Idaho Power typically use its share of the output from the
four units at the Jim Bridger plant to meet peak loads during the
summer months of June though August?
(d) How does Idaho Power typically use its share of the output from the
four units at the Jim Bridger plant to meet peak loads during the
winter months of December through Februar?
(e) How does Idaho Power typically use its share of the output from the
four units at the Jim Bridger plant for load following purposes during
sumer and winter months?
(f) What flexibilty does Idaho Power have to ramp up or down its share
of the output from the four units at the Jim Bridger plant?
(g) Please list when each of the Jim Bridger units was off-line for
scheduled maintenance for the period Januar 2008 through the
present.
(h) Please list when each of the Jim Bridger units is scheduled to be off-
line for maintenance for the period from the present through 2012.
DOE-1-18. Please answer the following regarding Idaho Power's share of the Valmy
coal-fired plant.
(a) What is the maximum sumer capacity associated with Idaho
Power's share of each of the two units at this plant?
(b) How does Idaho Power schedule its share of the output from the two
units at the Valmy plant?
(c) How does Idaho Power typically use its share of the output from the
two units at the Valmy plant to meet peak loads during the sumer
months of June through August?
(d) How does Idaho Power typically use its share of the output from the
two units at the Valmy plant to meet peak loads during the winter
months of December through Februar?
( e) How does Idaho Power tyically use its share of the output from the
two unts at the Valmy plant for load following puroses during
sumer and winter months?
(f) What flexibilty does Idaho Power have to ramp up or down its share
of the output from the two unts at the Valmy plant?
8
IDAHO POWER COMPANY CASE No. IPC-E-11-08
DOE's FIRST REQUEST FOR INFORMATION AND PRODUCTION OF DOCUMENTS
(g) Please list when each of the Valmy units was off-line for scheduled
maintenance for the period Januar 2008 through the present.
(h) Please list when each of the Valmy units is scheduled to be off-line
for maintenance for the period from the present through 2012.
DOE-1-19. Please answer the following regarding Idaho Power's share of the
Boardman coal-fired plant.
(a) What is the maximum sumer capacity associafed with Idaho
Power's share of this plant?
(b) How does Idaho Power schedule its share of the output from the
Boardman plant?
(c) How does Idaho Power typically use its share of the output from the
Boardman plant to meet peak loads during the summer months of
June through August?
(d) How does Idaho Power typically use its share of the output from the
Boardman plant to meet peak loads during the winter months of
December through Februar?
( e) How does Idaho Power typically use its share of the output from the
Boardman plant for load following puroses during sumer and
winter months?
(f) What flexibilty does Idaho Power have to ramp up or down its share
of the output from the Boardman plant?
(g) Please list when the Boardman plants was off-line for scheduled
maintenance for the period Januar 2008 through the present.
(h) Please list when the Boardman plant is scheduled to be off-line for
maintenance for the period from the present through 2012.
DOE-1-20. In Idaho Power's 2011 Integrated Resource Plan, page 67, Idaho Power
states, "( m )onthly average generation for Idaho Power's hydroelectric
resources is calculated with a generation model developed internally by
Idaho Power. The generation model treats the projects upstream of the
Hells Canyon Complex as ru-of-river plants. The generation model
mathematically manages reservoir storage in the Hells Canyon Complex
to meet the remaining system load, while adhering to the operating
constraints on the Brownlee Reservoir and outflows from the Hells
Canyon project. For peak-hour analysis, a review of historical operations
was performed to yield relationships between monthly energy production
and achieved one-hour peak generation. The projected peak-hour
capabilties for the IRP were derived to be consistent with the observed
relationships."
(a) Please provide a copy of the referenced model in native format
(e.g.,Excel) with all links and formulas intact (if applicable)?
9
IDAHO POWER COMPANY CASE No. IPC-E-11-08
DOE's FIRST REQUEST FOR INFORMATION AND PRODUCTION OF DOCUMENTS
(b) Please explain how the model mathematically manages reservoir
storage in the Hells Canyon Complex to meet remaining system load?
(c) Please explain specifically what is meant by remaining system load?
(d) Please provide the historical data that was reviewed and the
calculations that were preformed to yield the relationships between
monthly energy production and achieved one-hour peak generation,
and please provide this information electronically in native format
(e.g., Excel) with all links and formulas intact?
DOE-1-21. Per Mr. Larkin, page 3, "(t)he 2011 test year customer and kWh sales
forecast is based upon the Sales and Load Forecast prepared for the 2011
Integrated Resource Plan." Please answer the following regarding the
load forecast used in Idaho Power's 2011 Integrated Resource Plan.
(a) Was that forecast prepared on or about August 2010?
(b) What were the last available actual monthly sales used in preparng
that forecast?
DOE-1-22. Per Mr. Larkin, pages 6-7, "(h)istorical data from the most currently
available four calendar years is used to derive an average load factor by
month for each rate class. These average load factors are then applied to
monthly kWh sales figures to determine total forecasted biling demand
and BLC by class for each month ofthe test period."
(a) Please provide the historical data and the calculations that were
preformed to derive average load factors by month for each rate class,
and please provide this information electronically in native format
(e.g., Excel) with all links and formulas intact?
(b) Why did Idaho Power elect to use a four-year average?
DOE-l-23. Please provide Exhibit Nos. 31 through 37 in native format (e.g., Excel)
with all links and formulas intact (if applicable). (M. Larkin, pp. 26-27.)
At Washington, D.C., this 12th day of July, 2011.
Arhur Perr Bruder
Attorney for the United States
Department of Energy
Phone: [phone]
Fax: [phone]
Cell: [phone]
Arur.Bruder~hq.doe.gov
10
IDAHO POWER COMPANY CASE No. IPC-E-11-08
. DOE's FIRST REQUEST FOR INFORMATION AND PRODUCTION OF DOCUMENTS
CERTIFICATE OF SERVICE
I hereby certify that, this 1ith day of July, 2011, I served the foregoing first production
request ofthe United States Deparent of Energy to Idaho Power Company, in Case No.
iPC- 11- 08, by attching it to an email which I caused to be transmitted to the following
persons at the following email addresses:
Commission Staff
Donald L. Howell, DAG
Karl T. Klein, DAG
Weldon Stutzman, DAG
Randy Lobb
Neil Price
Idaho Public Utilities Commission
472 W. Washington St.
Boise, ID 83702
Don.Howell(ßpuc.ldaho.gov
Karl.Klein(ßpuc.idaho. gov; W eldon. Stutzman~puc.idaho. gov
Randylobb(ßpuc.Idaho.gov; Neil.Price ~puc.Idaho.gov
Idaho Power Company
Lisa D. Nordstrom
Jason B. Wiliams
Donovan E. Walker
Greg Said
John R. Gale
Idaho Power Company
P.O. Box 70
Boise, Idaho 83707-0070
Inordstrom(ßidahopower .com; jwiliams~idahopower .com
dwalker(ßidahopower.com; gsaid(ßidahopower .com; rgale~idahopower .com
Community Action Partnership Association
Brad M. Purdy
Attorney at Law
2019 N. 17th St.
Boise, ID. 83702
bmpurdy~hotmail.com
Idaho Conservation League
Benjamin J. Otto
Idaho Conservation league
710 N. 6th St. PO Box 844
Boise, ID 83701
botto~idahoconservation.org
11
IDAHO POWER COMPANY CASE No. IPC-E-11-08
DOE's FIRST REQUEST FOR INFORMATION AND PRODUCTION OF DOCUMENTS
Idaho Irrigation Pumpers Association
Eric L. Olsen
Racine, Olson, Nye, Bud & Bailey, Chartered
201 East Center Street
P.O. Box 1391
Pocatello, Idaho 83204-1391
elOCfracinelaw.net
Anthony Yanel
29814 Lake Road
Bay Vilage, Ohio 44140
tony~yanel.net
Industrial Consumers of Idaho Power
Peter J. Richardson
Gregory M. Adams
Richardson & O'Leary PLLC
515 N. 27th St
P.O. Box 7218
Boise, Idaho 83702
peter(ßrichardsonandoleary.com; greg~richardsonandolear .com
Dr. Don Reading
6070 Hil Road
Boise, Idaho 83703
dreading~mindspring.com
Kroger
John R Hamond, Jr.
Batt Fisher Pusch & Alderman, LLP
U.S. Ban Plaza, 5th Floor
101 S. Capitol Boulevard, Suite 500
P.O. Box 1308
Boise, ID 83701
jrh~battfisher .com
Kur J. Boehm
Boehm, Kurz & Lower
36 E. Seventh St., Suite 1510
Cincinnati, OH 45202
KBohm~PBKLlawfirm.com
12
IDAHO POWER COMPANY CASE No. IPC-E-11-08
DOE's FIRST REQUEST FOR INFORMATION AND PRODUCTION OF DOCUMENTS
Kevin Higgins
Energy Strategies; LLC
215 S. State Street
Suite 200
Salt Lake City, Utah 84111
khiggins~energystrat.com
Micron
MaryV. York
Holland & Har LLP
Suite 1400, U.S. Ban Plaza
101 South Capitol Boulevard
P.O. Box 2527
Boise, Idaho 83701-2527
myork~hollandhart.com
Thorvald A. Nelson
Mark A. Davidson
Holland & Har LL
6800 South Fiddlers Green Circle, Ste. 500
Greenwood Vilage, CO 80111
tnelson(ßhollandhart.com; madavidson~hollandhar.com
Richard E. Malmgren
Sr. Asst. General Counsel
Micron Technology, Inc.
800 South Federal Way
Boise, ID 83716
remalmgren~micron.com
Snake River Allance
Ken Miler, Clean Energy Program Director
350 N 9th St # B610
Boise, ID 83702-5473
kmiler~snakeriverallance.org
Arhur Perr Bruder
Attorney for
United States Deparment of Energy
13