20171117IPC to Vote Solar 49-57.pdf

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An IDACORP Company
P.O. Box 70 (83707)
1221 W. ldaho St.
Boise, lD 83702
November 17,20'17
VIA HAND DELIVERY
Diane Hanian, Secretary
ldaho Public Utilities Commission
472 West Washington Street
Boise, ldaho 83702
Re: Case No. IPC-E-17-13
New Schedules for Residential and Small General Service Customers with
On-Site Generation - ldaho Power Company's Response to Vote Solar's
Third Set of Data Requests to Idaho Power Company
Dear Ms. Hanian
Enclosed for filing are an original and three (3) copies of ldaho Power Company's
Response to Vote Solar's Third Set of Data Requests to ldaho Power Company in the
above matter.
Also enclosed are four (4) copies each of non-confidential and confidential disks
containing information responsive to Vote Solar's data requests. Please handle the
confidential information in accordance with the Protective Agreement executed in this
matter.
lf you have any questions about the enclosed documents, please do not hesitate to
contact me.
Very truly yours,
0 %n,1.*,--Lrdstrom
LDN:kkt
Enclosures
Lisa D. No
LISA D. NORDSTROM (lSB No. 5733)
ldaho Power Company
1221West Idaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
I n ord strom@ id a hopowe r. com
RE C T IVED
?0l1tt0Y l7 PH h: l5
1it',11.i pLjilLi
i -rt rr-:,- ,-ta'1 [flll! : :,,.-,'._.,Vrrtryll SSION
Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILIT!ES COMMISSION
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
AUTHORITY TO ESTABLISH NEW
SCHEDULES FOR RES!DENTIAL AND
SMALL GENERAL SERVICE CUSTOMERS
WITH ON-SITE GENERATION
)
)
)
)
)
)
)
)
CASE NO. rPC-E-17-13
!DAHO POWER COMPANY'S
RESPONSE TO VOTE SOLAR'S
THIRD SET OF DATA REQUESTS
TO IDAHO POWER COMPANY
COMES NOW, ldaho Power Company ("ldaho Power" or "Comp?ny"), and in
response to Vote Solar's Third Set of Data Requests to ldaho Power Company dated
October 27,2017, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
THIRD SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 1
REQUEST NO. 49: Reference your response to Vote Solar Request No. 4
a. Please identify the nameplate capacity and generation resource (i.e., solar
PV, wind, hydro, etc.) for each generator interconnected on Jamieson circuit 012.
b. For the seven substations identified as having customer-sited distributed
generation that contributed to reverse power flow conditions, please provide the
nameplate capacity, interconnection date, and generation resource for each generator
served by that substation and, separately for each generator, the tariff(s) and/or
contracts pursuant to which it takes service from, and sells electricity to, ldaho Power
Company.
RESPONSE TO REQUEST NO.49:
a. The nameplate capacity and generation resource for each generator
interconnected on Jamieson circuit 012 are listed below.
Name Nameplate capacity (kW) Generation Source
Generator 1
Generator 2
Generator 3
Generator 4
Generator 5
Generator 6
Generator 7
Generator 8
100
100
99.84
65.52
99.96
74.97
65.60
65.45
Solar PV
Solar PV
Solar PV
Solar PV
Solar PV
Solar PV
Solar PV
Solar PV
b. The nameplate capacity, interconnection date, generation resource, and
rate are listed below for each generator on the seven substations identified as having
customer-sited distributed generation that contributed to reverse power flow conditions.
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
THIRD SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 2
Cairo 011
Generator 1
Generator 2
Generator 3
Generator 4
Generator 6
Orchard 042
Nameplate
Capacity (kW)
lnterconnection
date
Generation
source
Rate
13
2.225
9.45
10.92
4,500
Nameplate
Capacity (kW)
06t25t2010
02t19t2013
10t26t2015
10t15t2015
02t10t2017
lnterconnection
date
Solar PV
Solar PV
Solar PV
Solar PV
Solar PV
Generation
source
084-lrrigation
084-Residential
084-Residential
084-Large Commercial
PURPA
Rate
Generator 1
Generator 2
Generator 3
Generator 4
Generator 5
Generator 6
Generator 7
Mora 042
2.5
2
40
21
4.56
3.12
20,000
Nameplate
Capacity (kW)
08t17t2005
09/05/2008
06t19t2013
06t19t2013
10t14t2015
12t2t2015
02t11t2017
lnterconnection
date
Wind
Wind
Solar PV
Solar PV
Solar PV
Solar PV
Solar PV
Generation
source
084-Residential
084-Residential
084-Large Commercial
084-Large Commercial
084-Residential
084-Residential
PURPA
Rate
Generator 1
Generator 2
Generator 3
Generator 4
Generator 5
Generator 6
Generator 7
8.4
5.4
56.43
7.5
9.72
14.70
13.64
10t13t2015
08t16t2016
05t26t2016
05t11t2016
05t10t2017
07t13t2017
10t10t2017
Solar PV
Solar PV
Solar PV
Solar PV
Solar PV
Solar PV
Solar PV
084-Residential
084-Residential
084-Large Commercial
084-Large Commercial
084-Residential
084-Residential
084-Residential
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
THIRD SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 3
Generator 8
Generator 9
Generator 10
Generator 11
Generator 12
Sinker Creek
Generator 1
Generator 2
Canyon Greek
6.96
11.78
3.10
17.4
20,000
Nameplate
Capacity (kW)
8.25
20,000
Nameplate
Capacity (kW)
Pending
Pending
Pending
Pending
02t08t2017
lnterconnection
date
lnterconnection
date
Solar PV
Solar PV
Solar PV
Solar PV
Solar PV
Generation
source
101-Residential
101-Residential
101-Residential
101-Residential
PURPA
Rate
Solar PV
Solar PV
Generation
source
084-Residential
PURPA
Rate
Generator 1
Generator 2
Nyssa
40
20,000
Nameplate
Capacity (kW)
11t14t2012
01t19t2017
lnterconnection
date
Wind
Solar PV
Generation
source
184-lrrigation
PURPA
Rate
Generator 1
Generator 2
Generator 3
Generator 4
Generator 5
Generator 6
Generator 7
Generator I
Generator 9
1.68
6.60
1.50
3.42
9.405
7.32
4.275
14.88
10,000
09t12t2002
09t10t2014
02t25t2016
08t18t2016
08t26t2016
01t20t2017
05t17t2017
10t09t2017
02t20t2017
Solar PV
Solar PV
Solar PV
Solar PV
Solar PV
Solar PV
Solar PV
Solar PV
Solar PV
O84-Residential
184-Residential
O84-Residential
184-Small General
184-Residential
O84-Residential
O84-Residential
184-Residential
PURPA
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
THIRD SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 4
11t21t2014
04t05t2017
Vale
Generator 1
Generator 2
Generator 3
Generator 4
Generator 5
Nameplate
Capacity (kW)
4.00
9.00
2.40
3.18
10,000
lnterconnection
date
Generation
source
Solar PV
Solar PV
Wind
Solar PV
Solar PV
Rate
O84-Large Commercial
O84-Large Commercial
O84-Residential
O84-Large Commercial
PURPA
The response to this Request is sponsored by Dave Angell, Transmission and
Distribution Planning Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
THIRD SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 5
05t14t2002
01t14t2004
04t17t2009
11t26t2013
11t01t2016
REQUEST NO. 50:Please identify each substation on your system and, for
each, please provide:
a. The total number of connected distribution circuits;
b. The total number of residential customers served on each circuit;
c. The total number of small general service customers served on each
circuit;
d. The total number of distribution transformers (line transformers) serving
residential customers on each circuit;
e. The total number of distribution transformers (line transformers) serving
small general service customers on each circuit; and
f. The total number, nameplate capacity, and generation type of residential
and small commercial class, customer-sited, net metered, distributed generation
connected to each circuit.
RESPONSE TO REQUEST NO. 50:
a. -f . Please see the Confidential Excel file provided on the confidential CD for
the requested data. The confidential CD will be provided to those parties that have
executed the Protective Agreement in this matter.
The response to this Request is sponsored by Dave Angell, Transmission and
Distribution Planning Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
THIRD SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 6
REQUEST NO. 51:Reference your response to Vote Solar Request No. 5(a)
a. Please identify, by date, time, and substation, each instance when excess
energy from customer-sited distributed generation flowed to the transmission system.
b. Please identify, for each instance identified in response to 3(a), above, the
amount of generation from net-metered, customer-sited distributed generation, and the
amount from other interconnected generation (e.9., PURPA QF generation).
RESPONSE TO REQUEST NO. 51:
a. Please see the Company's response to Vote Solar's Request No. 4 for
instances when excess energy flowed from the distribution system to the transmission
system.
b. Please see the attachment for the amount of excess net energy generated
by net-metered, customer-sited distributed generation and the amount of excess net
energy generated by other distributed energy resources at the time of each instance
identified in a. above.
The response to this Request is sponsored by Dave Angell, Transmission and
Distribution Planning Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
THIRD SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 7
REQUEST NO. 52: Reference your response to Vote Solar Request No. s(cXi).
Please identify the date, time, and volume of energy from customer-sited distributed
generation that was sold in the wholesale market since January 1,2015.
RESPONSE TO REQUEST NO. 52: All energy available for sale on the
wholesale market is aggregated into an equivalent resource. This includes all energy
from Company, PURPA, and customer-sited resources. Thus, the Company is not able
to identify the volume of energy from customer-sited distributed generation that was
sold in the wholesale market.
The response to this Request is sponsored by Dave Angell, Transmission and
Distribution Planning Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
THIRD SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 8
REQUEST NO. 53: Reference Angell Direct at 12 and your response to Vote
Solar Data Request No. 6. Please identify the distribution substation that the "Net Zero
Net Metering Customer" and the "Standard Service Residential Customer" are served
from and, for each substation, the hourly loads for each hour on June 29,2016.
RESPONSE TO REQUEST NO. 53: Both customers are served from the Eagle
substation. The hourly loads for the Eagle substation are shown in the table below.
Date Load (MW)
22.543L9
t9.55074
17.35533
15.84045
1s.19908
L5.44702
15.78609
L7.2935L
L9.2045L
21.20264
23.58742
26.32649
29.48202
32.37792
36.04343
38.92216
4L.66375
43.26327
43.74838
42.59342
39.32464
36.82599
33.24237
28.6833
The response to this Request is sponsored by Dave Angell, Transmission and
Distribution Planning Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
THIRD SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 9
29-Jun-16 00:00:00
29Jun-16 01:00:00
29Jun-16 02:00:00
29-Jun-16 03:00:00
29Jun-15 04:00:00
29-Jun-16 05:00:00
29-Jun-16 06:00:00
29-Jun-16 07:00:00
29-Jun-16 08:00:00
29-Jun-16 09:00:00
29-Jun-16 10:00:00
29-Jun-16 11:00:00
29-Jun-16 12:00:00
29-Jun-16 13:00:00
29-Jun-16 14:00:00
29Jun-16 15:00:00
29-iun-16 16:00:00
29-Jun-15 17:00:00
29-Jun-L6 18:00:00
29-Jun-16 19:00:00
29-Jun-16 20:00:00
29-Jun-16 21:00:00
29-Jun-16 22:00:00
29-Jun-16 23:00:00
REQUEST NO. 54: Reference your response to Vote Solar Data Request No.
l3,AschenbrennerDirectat2, line 15,7,line 16, 16, lines6-8, 17, line 6,27,line 15,:lf
the Company is not proposing a cost assignment methodology in this case, is the
Company basing its contentions in this case that customers with on-site distributed
generation are causing a "cost shift" and receiving a "subsidy" on the methodology used
in the 2017 Report to the Commission, Aschenbrenner Direct Exhibit 9 and as
described in response to Vote Solar Data Request No. 17? lf not, please explain the
methodology used to determine a "cost shift" and "subsidy."
RESPONSE TO REQUEST NO. 54:
Beginning on page 12, line 23, of Tatum Direct, Mr. Tatum describes what is
meant by the term "cost shift" in the context of this case
Currently, the Company's R&SGS customers are
billed two types of charges: (1) a flat monthly service charge
of $5.00 and (2) per kWh energy charges that vary by
season and total monthly consumption. Due to the limited
billing components associated with these rates classes, most
of the Company' s revenue requirement is collected through
the volumetric energy rates. This includes costs associated
with all components of the electrical system, from investment
in generation resources to the meters installed on customers'premises. Consequently, energy rates for R&SGS
customers reflect not only the energy- related components of
the revenue requirement, but fixed costs associated with
generation, transmission, and distribution as well.
For this type of rate design, recovery of fixed costs
from an individual customer declines with any reduction in
net energy usage. This creates a potential inequity between
net metering customers and standard service customers as
net metering customers, who still rely heavily upon the grid
to both purchase power and transfer excess generation, are
provided the opportunity to unduly reduce collection of class
revenue requirement by reducing a portion or even all of
their net kWh usage while other residential customers are
left to compensate for the fixed costs that transfer to them
through this revenue shortfall.
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
THIRD SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 1O
Please see the Company's response to Vote Solar's Request No. 17.b for a
description of the methodology and assumptions utilized to estimate the cost shift
occurring from net metering customers to residential customers.
The response to this Request is sponsored by Connie Aschenbrenner, Rate
Design Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
THIRD SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 11
REQUEST NO. 55: Please provide the date, hour, and magnitude of each
monthly system peak during each of the last ten (10) years.
RESPONSE TO REQUEST NO. 55: The date, hour, and magnitude of each
monthly system peak during each of the last ten years are provided in the attachment to
this request.
The response to this Request is sponsored by Dave Angell, Transmission and
Distribution Planning Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
THIRD SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 12
REQUEST NO. 56: Reference your response to Vote Solar Data Request Nos.
15(a) and 16 and Mr. Tatum's Direct at pp.4-5.
a. Please explain how costs incurred and prices paid by individual customers
would be "perfectly align[ed]." For example, would aligning costs within the mean of Mr.
Tatum's testimony mean that the individual customer's contribution to class cost
allocation in the cost of service study would match revenues collected from that
customer? lf not, please explain how perfectly aligned costs and prices paid would be
determined.
b. Please state whether you contend that the existing retail rate results in
inappropriate cost shifting and intra class subsidy to customers with distributed
generation who do not export (i.e., do not net meter) but instead use all generation to
offset load served from the Company (i.e., through battery storage or by sizing
generation to never exceed load).
RESPONSE TO REQUEST NO. 56:
a. The Company is not proposing to achieve perfect alignment of rates with
costs in this case. However, from a theoretical perspective, perfect alignment would
mean collecting the exact revenue requirement attributable to each individual customer
from that customer.
b. Yes. Under the hypothetical scenario presented by Vote Solar in this
request, it is possible that the existing retail rate structure would result in cost shifting
and intra class subsidies. However, the Company does not have any residential or
small general service customers with on-site generation who have not, at some time,
produced a surplus of electricity.
The response to this Request is sponsored by Tim Tatum, Vice President of
Regulatory Affairs, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
THIRD SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 13
REQUEST NO. 57: Reference your response to Vote Solar Data Request 17(b)
a. Please identify each way in which the methodology used to quantify the
estimated cost shifts in 2015 and 2016 were different from the methodology used to
assign costs during the Company's last general rate case.
b. Please identify the date and hour of the system coincident demand and
residential class non-coincident demand that was used to determine "the residential
customer class's functionalized and classified revenue requirement authorized in the
Company's 2011 GRC' and the date and hour of the system coincident demand and the
residential net metering segment's non-coincident demand used to estimate the net
metering segment's revenue requirement.
c. Please define "the absolute value of the average usage in that hour" as
used on page 23 of your response to Vote Solar Data Request 17(b) and how it differs
from "the average of each customer's positive consumption."
RESPONSE TO REQUEST NO. 57:
a. As discussed in the Company's Response to Vote Solar's Request No.
17.b, the starting point for the cost shift analysis included in the 2016 and 2017 Annual
Net Metering Reports ("Annual Reports") was the class cost-of-service study from the
2011 general rate case ("2011 GRC"). Therefore, the underlying class cost-of-service
methodology used as the basis for the 2011 GRC and the Annual Reports was identical.
However, as described in the Company's Response to Vote Solar's Request No.
17.b, in orderto update the revenue requirement approved in the 2011 GRC to reflect
amounts currently recovered in rates, the Company added or subtracted incremental
revenue requirement authorized by the IPUC since the conclusion of the 2011 GRC.
This was achieved by applying the same classification and functionalization principles
utilized in the 2011 GRC to the approved incremental revenue requirement amounts on
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
THIRD SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 14
a case-by-case basis. This incremental adjustment differs from the process used in a
GRC only in that those costs would have been included in the initial jurisdictional
revenue requirement rather than being added to or subtracted from revenue
req u i rement after-the-fact.
Additionally, as further detailed in the Company's Response to Vote Solar's
Request No. 17.b, in order to determine revenue requirement attributable to net
metering customers, ldaho Power applied per-unit costs to net metering customers'
usage for the analyses performed in the Annual Reports. While the determination of
these per-unit costs and the corresponding allocation factors mirrored the classification,
functionalization, and allocation principles included in the 2011 GRC, the mechanics of
the calculations differed for the analyses contained in the Annual Reports. Within a
GRC, total jurisdictional revenue requirement is classified and functionalized, then
allocated to customer classes based on each class's proportional share of each
respective allocation factor. For the cost shifting analysis in the Annual Reports, a per-
unit cost was determined then applied to net metering customers' usage. While the
underlying classification, functionalization, and allocation principles were the same, a
per-unit calculation was utilized in the Annual Reports because the intent of these
analyses was to isolate a revenue requirement amount for net metering customers that
was reflective of amounts currently authorized for recovery in customer rates.
b. Please see the Company's response to Vote Solar's Request No. 10.c for
the date and hour (ending) of the system coincident demand and residential class non-
coincident demand that was used to determine "the residential customer class's
functionalized and classified revenue requirement authorized in the Company's 2011
GRC."
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
THIRD SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 15
The date and hour of the system coincident demand and the residential
segment's non-coincident demand used to estimate the net metering segment's 2015
and 2016 revenue requirement are listed below. The same hour was used for the
residential net metering segment's non-coincident demand as that of the residential
segment.
Month Residential Non-Coincident System Peak
Ja nuary
February
March
April
May
June
July
August
September
October
November
December
1111201519.00
212412015 8:00
3/5i2015 8:00
41312015 8:00
513112015 19:00
612812015 19:00
7t2t2015 20.00
8121201518:00
911312015 18:00
10t10t201518.00
1112912015 20:00
12t27t201519.00
1t2t2015 9"00
212312015 8:00
31412015 8:00
412812015 22:00
51412015 20:00
612912015 16:00
7111201519:00
8t12t201518'.00
9111201519:00
10/10/201518:00
11/30/2015 19:00
12t1t2015 8.00
January
February
March
April
May
June
July
August
September
October
November
December
1121161000
2t2t1620.00
3/18/16 8:00
416116 8:00
5/31/16 19:00
6t27t1619.00
712711619:00
81211619:00
9/1/16 19:00
10/30/16 21:00
1112811619:00
1211811619:00
1t2t1610'.00
2t2t16 8.OO
3/18/16 8:00
4t21t1618.00
5/31/16 19:00
6t29t1618.00
7/30/16 18:00
8t2t1619'.00
9/1/1618.00
10t17 t16 20.00
11130/1619:00
12t19116 9'.00
c. As stated on page 23 of the Company's response to Vote Solar Request
17.b, the absolute value of each hour was used to calculate the non-coincident kilowatts
("kW") for the residential net metering segment. This means that, if the net energy
consumption was negative, the positive value of that net energy consumption was used
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
THIRD SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 16
to calculate the average for that hour. The Company used the absolute value when
calculating the non-coincident kW because this factor is used to assign distribution
costs, and regardless of which direction the energy flows, the result is representative of
the customer's reliance on the distribution system in that hour.
This differs from the use of "the average of each customer's positive
consumption" in that, for the calculation of the system coincident kW and the average
monthly kilowatt-hour, if the net energy consumption was negative that hour was
zeroed. The system coincident kW is used to assign energy and transmission costs,
and therefore, if the customer was not consuming energy from the Company, a zeto
was used for the calculation.
The response to this Request is sponsored by Connie Aschenbrenner, Rate
Design Manager, ldaho Power Company.
DATED at Boise, ldaho, this 17th day of November 2017.
ISA . NORDS M
Attorney for ldaho Company
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
THIRD SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 17
CERTIFICATE OF SERVICE
! HEREBY CERTIFY that on the 17th day of November 2017 I served a true and
correct copy of IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S THIRD
SET OF DATA REQUESTS TO IDAHO POWER COMPANY upon the following named
parties by the method indicated below, and addressed to the following:
Commission Staff
Sean Costello
Deputy Attorney General
ldaho Public Utilities Commission
47 2 W esl Washington (83702)
P.O. Box 83720
Boise, ldaho 83720-007 4
ldahydro
C. Tom Arkoosh
ARKOOSH LAW OFFICES
802 West Bannock Street, Suite 900
P.O. Box 2900
Boise, ldaho 83701
ldaho Conseruation League
Matthew A. Nykiel
ldaho Conservation League
102 South Euclid #207
P.O. Box 2308
Sandpoint, ldaho 83864
Benjamin J. Otto
ldaho Conservation League
710 North 6th Street
Boise, ldaho 83702
ldaho lrrigation Pumpers 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. Mail
_Overnight Mail
_FAXX Email sean.costel ouc.idaho.oov
_Hand DeliveredX U.S. Mail
_Overnight Mail
FAXX Email tom.arkoos h.com
erin. cecil@arkoosh. com
_Hand DeliveredX U.S. Mail
_Overnight Mail
_FAXX Email ahoconservation
_Hand DeliveredX U.S. Mail
_Overnight Mail
_FAXX Email botto@idahoco nservation.oro
_Hand DeliveredX U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
THIRD SET OF DATA REQUESTS TO IDAHO POWER COMPANY. 18
Anthony Yankel
12700 Lake Avenue, Unit 2505
Lakewood, Ohio 44107
Auric Solar, LLC
Preston N. Carter
Deborah E. Nelson
GIVENS PURSLEY LLP
601 West Bannock Street
Boise, ldaho 83702
Elias Bishop
Auric Solar, LLC
2310 South 1300 West
West Valley City, Utah 84119
Vote Solar
David Bender
Earthjustice
3916 Nakoma Road
Madison, Wisconsin 537 1 1
Briana Kobor
Vote Solar
360 22nd Street, Suite 730
Oakland, California 94612
City of Boise
Abigail R. Germaine
Deputy City Attorney
Boise City Attorney's Office
150 North Capitol Boulevard
P.O. Box 500
Boise, ldaho 83701-0500
ldaho Glean Energy Association
C. Tom Arkoosh
ARKOOSH LAW OFFICES
802 West Bannock Street, Suite 900
P.O. Box 2900
Boise, ldaho 83701
_Hand DeliveredX U.S. Mail
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den@q ivensp u rsley. com
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erin. ceci l@arkoosh. com
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
THIRD SET OF DATA REQUESTS TO IDAHO POWER COMPANY. 19
David H. Arkoosh
Law Office of David Arkoosh
P.O. Box 2817
Boise, ldaho 83701
Sierra Club
Kelsey Jae Nunez
KELSEY JAE NUNEZLLC
920 North Clover Drive
Boise, ldaho 83703
Zack Waterman
Director, ldaho Sierra Club
503 West Franklin Street
Boise, ldaho 83702
Michael Heckler
3606 North Prospect Way
Garden City, ldaho 83714
Snake River Alliance
NW Energy Coalition
John R. Hammond, Jr.
FISHER PUSCH LLP
101 South Capitol Boulevard, Suite 701
P.O. Box 1731
Boise, ldaho 83701
lntermountain Wind and Solar, LLC
Ryan B. Frazier
Brian W. Burnett
KIRTON McCONKIE
50 East South Temple, Suite 400
P.O. Box 45120
Salt Lake City, Utah 84111
X U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
_Hand DeliveredX U.S. Mail
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_FAXX Email [e-mail]
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_Hand Delivered
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_FAXX Email [e-mail]
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wwi I so n @ s n ake rive ra I I ia nce. o rg
[e-mail]
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_FAXX Email [e-mail]
[e-mail]
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
THIRD SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 20
Doug Shipley
lntermountain Wind and Solar, LLC
1953 West2425 South
Woods Cross, Utah 84087
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_FAXX Email [e-mail]
Ki Towell
IDAHO POWER COMPANY'S RESPONSE TO VOTE SOLAR'S
THIRD SET OF DATA REQUESTS TO IDAHO POWER COMPANY - 21
Assistant