20160726IPC to ICL 1-19.pdf

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An IDACORP Company
LISA D. NORDSTROM
Lead Gounsel
ffi CEIVED
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July 26, 2016
VIA HAND DELIVERY
Jean D. Jewell, Secretary
ldaho Public Utilities Commission
47 2 W est Washington Street
Boise, ldaho 83702
Re: Case No. IPC-E-16-14
New Tariff Schedule 63, A Community Solar Pilot Program
ldaho Power Company's Response to the First Production Request of the
Idaho Conservation League
Dear Ms. Jewell:
Enclosed forfiling in the above matter please find an original and three (3) copies of
ldaho Power Company's Response to the First Production Request of the ldaho
Conservation League.
Also enclosed are four (4) copies of a non-confidential disk containing information
responsive to the ldaho Conservation League's production requests.
Very truly yours,
&l*Q r(*t;-.^-'
Lisa D. Nordstrom
LDN:kkt
Enclosures
LISA D. NORDSTROM (lSB No.5733) I{ECEIVED
ldaho Power Company
1221 West ldaho Street (83702) i{)16 -l{.ll 25 PFl L: 22
P.O. Box 70 : -,1 i,\
Boise, ldaho 83707 ' iir'i ,-i,,i,"i.jd;,i';isstcFt
Telephone: [phone]
Facsimile: [phone]lnq@
Attomey for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
tN THE MATTER OF IDAHO POWER )coMpANy's AppLtcATIoN FoR ) CASE NO. !PC-E-16-14
APPROVAL OF NEW TARIFF SCHEDULE )
63, A COMMUNTTY SOLAR PILOT ) TDAHO POWER COMPANY'S
PROGRAM.) RESPONSE TO THE IDAHO
) CoNSERVAT|ON LEAGUE',S) FIRST PRODUCTTON REQUEST
)
COMES NOW, ldaho Power Company ("ldaho Powe/' or "Comp?ry"), and in
response to the ldaho Conservation League's ("lCL") First Production Request to Idaho
Power dated July 5, 2016, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO
CONSERVATION LEAGUE'S FIRST PRODUCTION REQUEST - 1
LARKIN TESTIMONY
REQUEST NO. 1: Please provide a complete copy of the "most recently
reviewed class cost-of-service methodology filed in Case No IPC-E-11-08, adjusted to
reflect revenue requirement changes that were subsequently authorized by the
Commission which impact the authorized level of energy related cost recovery" refened
to on Page 12 of Mr. Larkin's direct testimony.
RESPONSE TO REQUEST NO. 1: Please see Attachments 1 and 2 provided
on the enclosed CD, which contain the class cost-of-service study reflecting the
stipulated results of Case No. IPC-E-11-08.
To facilitate the review of these models, please see the following information
detailing the contents of Attachments 1 and 2, and how to properly link these files to
create a fully functional model:
ldaho Power Company
Case No. IPC-E-11-08
Class Cost-of-Service Study
!nstructions for Excel Spreadsheet Models
The class cost-of-service model consists of two separate Microsoft Excel workbooks.
The first workbook, called the Assign Model, or AS Mode! for short, performs the
functionalization and classification processes. This workbook categorizes the ldaho
jurisdictional costs identified by Federal Energy Regulatory Commission account into
operating functions, such as production, transmission, distribution, metering, customer
service, etc. !t also categorizes the functional costs into demand-, energy-, and
customer-related classifications.
The second workbook, called the Functionalized Cost Model, or FC Model for short,
performs the class allocation process. This workbook allocates the functionalized and
classified costs developed in the AS Mode! to the various customer classes.
To verify that the FC Model is Iinked to the appropriate AS Model, open the FC Model
file and go to "Data" and then "Edit Links." The "linked" file name should appear in the
dialog box under the heading "Source."
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO
CONSERVATION LEAGUE'S FIRST PRODUCTION REQUEST - 2
Following the conclusion of Case No. IPC-E-11-08, four rate changes have
impacted the authorized level of energy-related cost recovery embedded in base rates:
(1) an update to depreciation rates (!PC-E-12-08), (2) an update to the leve! of recovery
associated with the Boardman power plant (|PC-E-12-09), (3) the inclusion of the
Langley Gulch power plant in base rates (IPC-E-12-14), and an (4) an update to the
base level of net power supply expenses embedded in rates (|PC-E-13-20).
Please see Attachment 3 provided on the enclosed CD for a determination of the
level of energy-related revenue requirement associated with the Langley Gulch power
plant.
For the remaining three cases, adjustments to energy-related revenue
requirement are demonstrated in Attachment 4 provided on the enclosed CD. This
attachment incorporates the results from the "Unit Cost by Schedule" tabs of the cost-of-
service studies provided in Attachments 1 through 3, and further adjusts the revenue
requirement for Case Nos. I PC-E-1 2-08, I PC-E-1 2-09, and I PC-E -13-20.
Please note Attachment 4 also demonstrates the seasonal weighting of the
proposed Solar Energy Credit rates in response to ICL's Request No. 5.
The response to this Request is sponsored by Matthew Larkin, Revenue
Requirement Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO
CONSERVATION LEAGUE'S FIRST PRODUCTION REQUEST . 3
REQUEST NO. 2: For the "revenue requirement changes [to the IPC-E-11-08
class cost-of-service studyl that were subsequently authorized by the Commission'
refened to on page 12 of Mr. Larkin's direct testimony, please identify each subsequent
adjustment and the associated Commission order approving such change.
RESPONSE TO REQUEST NO. 2:
. Application of ldaho Power Company for authority to increase its rates due to
revised depreciation rates for electric plant-in-service, Case No. IPC-E-12-08, Order
No.32559.
o Application of ldaho Power Company for authority to increase its rates for
electric service to recover the Boardman balancing account, Case No. IPC-E-12-09,
Order No.32549.
. Application of ldaho Power Company for authority to increase its rates and
charges for electric service due to the inclusion of the Langley Gulch power plant
investment in rate base, Case No. IPC-E-12-14, Order No. 32585.
. Application of ldaho Power Company for authority to establish a new base
level of net power supply expense, Case No. IPC-E-13-20, Order No. 33000.
Dollar adjustments associated with the cases listed above are detailed in the
Company's response to ICL's Request No. 1.
The response to this Request is sponsored by Matthew Larkin, Revenue
Requirement Manager, ldaho Power Company.
]DAHO POWER COMPANY'S RESPONSE TO THE IDAHO
CONSERVATION LEAGUE'S FIRST PRODUCTION REOUEST - 4
REQUEST NO. 3: Please refer to page 12 of Mr. Larkin's direct testimony
referencing the point of measurement as the "generator source". Please provide a
precise definition of where the power production will be measured relative to the power
project and any associated transformers or substation interconnection points.
RESPONSE TO REQUEST NO. 3: The power production will be measured on
the altemating current side of the community solar plant inverter before the distribution
circuit service transformer.
The response to this Request is sponsored by David Angel!, Customer
Operations Planning Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO
CONSERVATION LEAGUE'S FIRST PRODUCTION REQUEST - 5
REQUEST NO. 4: Please refer to Exhibit No. 2 of Mr. Larkin's direct testimony.
Please provide the associated workbooks, formulas, and sources for input assumptions
used in that analysis.
RESPONSE TO REQUEST NO. 4: Please see the Excel workbook provided on
the enclosed CD.
The response to this Request is sponsored by Matthew Larkin, Revenue
Requirement Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO
CONSERVATION LEAGUE'S FIRST PRODUCTION REQUEST - 6
REQUEST NO. 5: Please refer to page 15 of Mr. Larkin's direct testimony where
he explains the 'year-round [solar eneryy credit] rates were appropriately adjusted to
reflect the summer/nonsummer weighting of solar production." Please provide a!!
documentation of this appropriate adjustment, including both the methodology and the
data.
RESPONSE TO REQUEST NO. 5: Please see the "Seasonal Rates" tab
contained in Attachment 4 to the Company's response to IGL's Request No. 1.
The response to thls Request is sponsored by Matthew Larkin, Revenue
Requirement Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO
CONSERVATION LEAGUE'S FIRST PRODUCTION REQUEST - 7
REQUEST NO. 6: Please refer to page 14 of Mr. Larkin's direct testimony where
he explains ldaho Powe/s proposed Solar Energy Credit "will be reflective of the
seasonal differences in the cost of energy" but the actual rate will not adjust seasonally.
Please explain how, under this proposal, subscribers will see the seasonal differences
in the cost of energy on their monthly electric bill.
RESPONSE TO REQUEST NO. 6: The proposed Solar Energy Credit rate is a
seasonally weighted rate, which means the seasonal difference in the cost of energy is
accounted for within the Solar Energy Credit rate calculation. Rather than proposing a
Solar Energy Credit that was different in the summer and non-summer months, the
Company chose to include the seasonal difference by weighting the single rate. The
seasonally weighted rates and associated computations are detailed in the "Seasonal
Rates" tab of the Excel workbook provided as Attachment 4 to the Company's response
to ICL's Request No. 1.
The response to this Request is sponsored by Matthew Larkin, Revenue
Requirement Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO
CONSERVATION LEAGUE'S FIRST PRODUCTION REOUEST - 8
REQUEST NO. 7: Please refer to Mr. Larkin's Direct Testimony at pages 10-11.
a. Please describe in detail the monthly payment option considered by ldaho
Power.
b. Please provide all analysis quantifying the "financial risk for non-
participants and the Company would be too great under the monthly payment option if
panels went unsubscribed throughout the Iife of the program."
RESPONSE TO REQUEST NO. 7:
a. The Company considered a monthly payment option that would have
allowed customers to pay for a subscription on a monthly basis for 20 years based on
the expected annual levelized cost of the program.
b. Allowing participants to pay monthly over the life of the program while at
the same time allowing them the ability to exit the program at any time introduces
financial risk that would ultimately be bome by the Company or non-participants.
Because IDACORP, lnc. shareholders have already committed to provide a contribution
equal to 15 percent of the construction cost, the Company was not willing to increase
shareholder exposure, nor was it willing to offer a payment option that would potentially
result in non-participating customers being assigned program-related costs. The
Company did not feel that this risk was appropriate for a pilot program and the proposed
program structure eliminates this financial risk; consequently, no additional analysis was
performed to quantify this risk.
The response to this Request is sponsored by Matthew Larkin, Revenue
Requirement Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO
CONSERVATION LEAGUE'S FIRST PRODUCTION REQUEST - 9
REQUEST NO. 8: Please refer to Mr. Larkin's Direct Testimony at page 11,
where he states "if there is interest by a third-party lender, the Company will make this
offering known to prospective subscribers during the recruitment period."
a. Please define what the Company means by "interest by a third-party
lendef. Does this mean the financial institution has a specific product, or is merely
willing to talk with a subscribeP
b. Please define what the Company means by "make known to prospective
subscriberc". Does the Company intend to include financing options in the marketing
materials, or separately?
RESPONSE TO REQUEST NO. 8:
a. The Company defines "interest by a third-party lende/' as one or more
third-party lenders willing to offer specific loan products to potential subscribers under
mutually agreeable terms. Idaho Power does not currently have an agreement with any
interested third-party lender.
b. !f ldaho Power is able to establish an agreement with one or more third-
party lenders, the Company anticipates it would include applicable information in the
marketing materials and website for the Community Solar Pilot Program.
The response to this Request is sponsored by Pete Pengilly, Customer Research
& Analysis Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO
CONSERVATION LEAGUE'S FIRST PRODUCTION REOUEST - 1O
REQUEST NO. 9: PIease refer to Mr. Larkin's Direct Testimony at 12 regarding
using embedded energy related costs as the basis of the solar energy credit. Please
provide any analytical or policy basis relied on to assign embedded energy related costs
as the appropriate means valuing power produced from the project.
RESPONSE TO REQUEST NO. 9: Please see the Company's response to
ICL's Request No. 1, which details the embedded energy-related costs reflected in the
proposed Solar Energy Credit rates. The Company's proposed methodology related to
the appropriate credit for the power produced from the pQect is stated on pages 13-14
of Mr. Larkin's direct testimony:
Providing participants with a bill credit based on embedded
energy costs reflects the general concept that participants
are choosing to subscribe to the community solar facility for
a portion of their electricity supply rather than receiving
electricity generated from the Company's overall systemresources. This methodology will ensure that
participating customers are able to offset the energy-related
portion of base rates, while still contributing to the recovery
of fixed costs related to infrastructure needed to serve all
customers, as well as other non-variable costs, such as
customer service and billing. The Company believes this
methodology is consistent with the objective of limiting
adverse rate impacts to non-participating customers.
The response to this Request is sponsored by Matthew Larkin, Revenue
Requirement Manager, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO
CONSERVATION LEAGUE'S FIRST PRODUCTION REQUEST. 11
REQUEST NO. 10: Please refer to Mr. Larkin's Direct Testimony at 18 where he
states "participation through a Company-sponsored renewable energy program
provides for better @nsumer protection through ldaho Poweds regulated business
practices as compared to third-party installations or leasing of rooftop solar
installations." Please provide all objective evidence or analysis relied on by Mr. Larkin to
make this claim.
RESPONSE TO REQUEST NO. 10: The statement in Mr. Larkin's testimony
reflects the fact that, in addition to the laws and regulations goveming all businesses
operating within ldaho, the Company is also subject to the oversight of the ldaho Public
Utilities Commission ("Commission"). As an investor-owned utility regulated by the
Commission, Idaho Power is subject to additional regulation and oversight as compared
to a non-regulated business. The Commission has jurisdiction over ldaho Power with
regard to setting rates, rulemaking governing utility operations, hearing and deciding
complaints, and enforcing state Iaws affecting utilities. ldaho Power is not aware of any
third-party solar installer/lessor that is subject to this same !eve! of regulation.
The response to this Request is sponsored by Matthew Larkin, Revenue
Requirement Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO
CONSERVATION LEAGUE'S FIRST PRODUCTION REQUEST - 12
ANGELL TESTIMONY
REQUEST NO. 11: Please refer to Mr. Angell's Direct Testimony at 2 regarding
the selection process and categories for candidate sites. Please provide the specific
criteria used as the basis for site selection, including "cunent infrastructure'
considerations used.
RESPONSE TO REQUEST NO. 11: The site evaluation process relied on the
following criteria: land ownership, permitting requirements, topography (access and
obstructions for construction and maintenance), residential impact, environmental
i m pact, d istri butio n i nfrastructu re, and comm unicatio ns facilities.
The response to this Request is sponsored by David Angell, Customer
Operations Planning Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO
CONSERVATION LEAGUE'S FIRST PRODUCTION REQUEST - 13
REQUEST NO. 12: Please refer to Mr. Ange!!'s Direct Testimony at 9 - 10 where
he explains how the Company calculated the expected production of the pilot solar
project.
a. Please explain why the Company used the "Typical Meteorclogica! Year
3" instead of the ldaho Powe/s solar generation profile developed for the 2016 Solar
lntegration Study.
b. Please provide a comparison of expected project output using the Typical
Meteorological Year 3 and the solar generation profile developed for the 2016 Solar
lntegration Study.
RESPONSE TO REQUEST NO. 12:
a. The Company chose to use the Typical Meteorological Year 3 ('TMY3")
for the solar generation profile because it is publicly available through the use of the
National Renewable Energy Laboratory's PVWatts online application. The use of TMY3
allows any potential subscriber to evaluate the production of a subscription and
compare it with other options.
b. The annual production from the TMY3 would result in about 1,007,400
kilowatts ("kwh') compared with the 2016 Solar lntegration Study production of 961,296
kwh.
The response to this Request is sponsored by David Angell, Customer
Operations Planning Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO
CONSERVATION LEAGUE'S FIRST PRODUCTION REQUEST - 14
REQUEST NO. 13: Please refer to Mr. Angell's Direct Testimony at 11,
regarding line loss accounting. Please provide all analysis of effects on transmission
and distribution system line loadings for candidate locations.
RESPONSE TO REQUEST NO. 13: No analyses of the effects on transmission
and distribution system line loadings were conducted.
The response to this Request is sponsored by David Angell, Customer
Operations Planning Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO
CONSERVATION LEAGUE'S FIRST PRODUCTION REQUEST . 15
REQUEST NO. 14: Please referto Mr. Angell's Direct Testimony at 11 regarding
line loss accounting. Please provide all analytical support for line losses deriving from
delivery to community solar subscribers.
RESPONSE TO REQUEST NO. 14: The Company determined that, regardless
of the location of the subscribers, the community solar plant generation output would be
consumed locally on the interconnected distribution feeder. Thus, only the secondary
distribution system losses would be deducted from the measured solar production.
The response to this Request is sponsored by David Angell, Customer
Operations Planning Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO
CONSERVATION LEAGUE'S FIRST PRODUCTION REQUEST - 16
REQUEST NO. 15: Please refer to Mr. Angell's Direct Testimony at 11 regarding
line loss accounting. Please provide any analysis relied on to quantify and value losses
accruing from transmission, substation, and primary distribution line system
components.
RESPONSE TO REQUEST NO. 15: The Company relied on the 2012 system
loss study to quantify the system losses and their allocation to transmission, substation,
primary distribution, and secondary distribution components of the system. The loss
coefficients for each are shown in the aftachment to this response provided on the
enclosed CD.
The response to this Request is sponsored by David Angell, Customer
Operations Planning Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO
CONSERVATION LEAGUE'S FIRST PRODUCTION REQUEST - 17
REQUEST NO. 16: Please refer to Mr. Angell's Direct Testimony at 11 regarding
line loss accounting. Please provide any accounting of how offset transmission,
substation, and primary distribution line losses are credited to community solar
subscribers.
RESPONSE TO REQUEST NO. 16: A community solar subscribers' portion of
energy is calculated from the plant production less secondary distribution line losses.
As explained in the Company's response to ICL's Request No. 14, the energy share is
not reduced by transmission, substation, and primary distribution line losses. However,
the solar energy credit rate does reflect (offset) transmission, substation, and primary
distribution line losses because it is determined by dividing embedded energy-related
costs by sales at the meter.
The response to this Request is sponsored by David Angell, Customer
Operations Planning Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO
CONSERVATION LEAGUE'S FIRST PRODUCTION REQUEST - 18
PENGILLY TESTIMONY
REQUEST NO. 17: Please refer to Mr. Pengilly's Direct Testimony at 11
regarding ldaho Power ownership of RECs and carbon emission reduction credits.
Please provide any analysis, policy objectives, or computation of ldaho Power benefits
supporting ownership of RECs and carbon emission credits.
RESPONSE TO REQUEST NO. 17: Under the proposal, ldaho Power will not
receive any benefits from supporting ownership of Renewable Energy Certificates
("RECs") or carbon emission credits. Idaho Power does not have any analysis or
computations of benefits supported by ownership of the RECs and carbon emission
credits. The Company proposes to retire the RECs on behalf of participants. The
Company believes in this case, like the Green Power Program, participants are
supporting this project in part to be able to claim they use renewable energy. To make
that claim, the RECs must be retired.
RECs are tracked through the Westem Renewable Energy Generation System
("WREGIS') an independent renewable energy tracking system for the Western
Electricity Coordinating Council. WREGIS tracks renewable energy generation from
units that register in the system by using verifiable data and creating RECs for this
generation. lt would be burdensome and impractical for each participant to set up a
WREGIS account. Therefore, the Company plans to retire RECs from the Community
Solar Anay on behalf of participants. RECs will be transferred into an ldaho Power
retirement subaccount in WREGIS.
The response to this Request is sponsored by Pete Pengilly, Customer Research
& Analysis Leader, ldaho Power Company.
]DAHO POWER COMPANY'S RESPONSE TO THE IDAHO
CONSERVATION LEAGUE'S FIRST PRODUCTION REQUEST - 19
REQUEST NO. 18: Please refer to Mr. Pengilly's Direct Testimony at 10-11
regarding the $25 transfer fee. Please provide any analysis relied on to establish a cost
basis for the proposed fee.
RESPONSE TO REQUEST NO. 18: Transfer of a subscription to a different
account will require severa! steps including:
(1) Verification that the recipient meets the eligibility requirements (ldaho
customer total subscription does not exceed the estimated annua! use) and notify
customer of results: Estimated time is 20 minutes.
(2) Contact with recipient to fill out and sign a participation agreement:
Estimated time is 15 minutes.
(3) Transfer in billing system. Estimated time is 15 minutes.
Position
Hourly
Waqe Minutes Hours Total Task
Research Assistant $29.48 20 0.33 $9.73 Verify eligibility/notify' cuslomer
ResearchAssistant $2g.4g 0.25
Secure new participation
$7.37 agreement15
Customer Service
Rep ll $29.48 0.25 $7.37 Transfer
Total $24.47
The response to this Request is sponsored by Pete Pengilly, Customer Research
& Analysis Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO
CONSERVATION LEAGUE'S FIRST PRODUCTION REQUEST - 20
15
REQUEST NO. 19: Please refer to Mr. Pengilly's Direct Testimony at 12-13
regading "leaming objective' benefits. Please provide any analysis of the value of such
benefits and any estimates of the expected reductions in production from the facility
from providing voltage control services to ldaho Power.
RESPONSE TO REQUEST NO. 19: Through e-mai! corespondence with Ben
Otto of the lCL, the Company verified that this data request was intended to reference
Dave Angell's testimony rather than Mr. Pengilly's, and has prepared its response
accordingly:
The Company has not analyzed the value of the leaming objectives. Based on
the interconnection specification for the inverter to be capable of operating with a power
factor of 0.9 lead to 0.9 lag through full real power output, the Company does not
anticipate any reduction in facility production when the inverter is supplying reactive
power in support of voltage control.
The response to this Request is sponsored by David Angel!, Customer
Operations Planning Manager, ldaho Power Company.
DATED at Boise, tdaho, this 26h day of July 2016.
]DAHO POWER COMPANY'S RESPONSE TO THE IDAHO
CONSERVATION LEAGUE'S FIRST PRODUCTION REQUEST . 21
Attomey for Idaho Power Company
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 26h day of July 2016 I served a true and correct
copy of IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO CONSERVATION
LEAGUE'S FIRST PRODUCTION REQUEST upon the following named parties by the
method indicated below, and addressed to the following:
Commission Staff
Daphne Huang
Deputy Attomey General
ldaho Public Utilities Commission
47 2 W est Washington (83702)
P.O. Box 83720
Boise, ldaho 83720-007 4
ldaho Conservation League
Benjamin J. Otto
ldaho Conservation League
710 North Sixth Street
Boise, ldaho 83702
Industrial Customers of ldaho Power
Peter J. Richardson
Gregory M. Adams
RICHARDSON ADAMS, PLLC
515 North 27n Street (83702)
P.O. Box 7218
Boise, Idaho 83707
Dr. Don Reading
6070 Hill Road
Boise, ldaho 83703
lrrigation Pumperc Association, lnc.
Eric L. Olsen
ECHO HAWK & OLSEN, PLLC
505 Pershing Avenue, Suite 100
P.O. Box 6119
Pocatello, ldaho 83205
X Hand Delivered
_U.S. Mai!
Ovemight Mail
_FAXX Email [e-mail]
Hand DeliveredX U.S. Mail
_Overnight Mai!
_FAXX Email [e-mail]
_Hand DeliveredX U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
oreo@richardsonadams. com
_Hand DellveredX U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
_Hand DeliveredX U.S. Mail
_Overnight Mail
FAX
x Email [e-mail]
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO
CONSERVATION LEAGUE'S FIRST PRODUCTION REQUEST -22
Anthony Yankel
12700 Blake Avenue, Unit 2505
Lakewood, Ohio 4y'-107
Hand DeliveredX U.S. Mail
_Ovemight Mail_FAXX Email [e-mail]
_Hand DeliveredX U.S. Mail
_Ovemight Mail_FAXX Email [e-mail]
_Hand DeliveredX U.S. Mail
_Ovemight Mail_FAXX Email [e-mail]
_Hand DeliveredX U.S. Mail
_Ovemight Mail
_FAXX Email [e-mail]
Snake River Alliance
Ken Miller, Energy Program Director
Snake RiverAlliance
223 North Sixth Street, Suite 317
P.O. Box 1731
Boise, ldaho 83701
Sierra Glub
ZackWaterman
Director, ldaho Siena Club
Sierra Club
503 West Franklin Street
Boise, ldaho 83702
Michael Heckler
3606 North Prospect Way
Garden City, ldaho 83714
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO
CONSERVATION LEAGUE'S FIRST PRODUCTION REQUEST. 23