HomeMy WebLinkAbout20171102Protective Agreement.pdfPROTECTIVE AGREEMENT RECEIVED
BETWEEN
rDAHo powER coMpANy AND l0lt t{0Y -2 [t'f l0: 35
TDAHO PUBLIC UTILITIES COMMISSION STANR,
(AND orHER pARrr ES AS Ad;iiilffi ;1?l fPCollf'h i8 *,0 *
CASE NO. IPC-E-17-13
This Protective Agreement is entered into this 21'r day of September, 2017,by Idaho Power
Company ("Idaho Power") and the Idaho Public Utilities Commission (Staff), and other parties as
applicable.
Recitals:
l. WHEREAS,Idaho Power and the ldaho Public Utilities Commission Staff (hereinafter
"Staff') anticipate that parties to this proceeding may make requests to provide, or make available
for review, certain information, considered by its custodian to be of a trade secret, privileged or
confidential nature (as defined in ldaho Code $ $ 7 4-107 through 7 4-109 and 48-80 I ).
2. WHEREAS, Idaho Power and the undersigned parties agree that entering into a
Protective Agreement will expedite the production of documents; will afford the necessary protection
to Idaho Power's and the undersigned parties' employees and/or representatives in Case No.
IPC-E- 1 7- 1 3 who might review the information and subsequently be requested to reveal its contents
by setting forth clear cut parameters for use of Confidential Information, and will protect
Confidential Information which might be provided during the course of the proceedings, now
therefore,
IT IS HEREBY STIPULATED AND AGREED AS FOLLOWS:
1. (a) Confidential Informstion
All documents, data, information, studies and other materials furnished pursuant to any
requests for information, subpoenas or other modes of discovery (formal or informal), and including
depositions, that are claimed to be of trade secret, proprietary or confidential nature (herein referred
to as "Confidential Information") shall be so marked by the party or entity providing the information
by stamping the same with a designation indicating its trade secret, proprietary orconfidential nature
and printed on "yellow" paper. TDAPA 31.01.01.067. Any claim of confidentiality must be
accompanied by an attorney's certificate that the material is protected by law from public disclosure
and cite the specific legal authority to support the claim. IDAPA 31.01.01.233.
PROTECTIVE AGREEMENT - I
(b) Protection of Confidential Information
Access to and review of Confidential [nformation shall be strictly controlled by the terms of
this Agreement. Unless otherwise ordered, Conhdential Information, including transcripts of
depositions containing information to which a claim of confidentiality is made, shall remain under
seal, shall continue to be subject to the protective requirements of this Agreement, and shall not be
disclosed to individuals who have not executed the nondisclosure agreement set forth in Exhibit "A."
(c) Uss of Confidential Information
All persons who may be entitled to review, or who are afforded access to any Confidential
Information by reason of this Agreement shall neither use nor disclose the Confidential Information
for purposes of business or competition, or any purpose other than the purpose ofpreparation for and
conduct of the proceedings, and then solely as contemplated herein, and shall keep the Confidential
Information secure as trade secret, confidential or proprietary information and in accordance with the
purposes and intent of this Agreement.
(d) Persons Bntitlcd to Rcview
Access to Confidential Information shall be limited to counsel of the undersigned parties,
employees, experts, agents or representatives of the undersigned parties who have executed an
Exhibit "A" to this Agreement. Such information will be clearly marked and protected from
unauthorized public disclosure.
(e) Non-tlisclosure Agreement
Confidential Information shall not be disclosed to any person who has not signed a non-
disclosure agreement on this form, which is attached hereto as Exhibit o'A" and incorporated herein.
The non-disclosure agreement or Exhibit "A" shall require the person to whom disclosure is to be
made to read a copy of this Protective Agreement and to certifr in writing that he or she has
reviewed the same and has consented to be bound by its terms. The Agreement shall contain the
signatory's full name, permanent address and employer. Such agreement shall be delivered to
counsel for the providing pa(ry, before disclosure is made.
2, Copies
No copies or transcriptions of the Confidential lnformation shall be made by the recipient
except as necessary to make the information available to individuals who have executed an Exhibit
"A" to this Protcctive Agreement.
PRO'| I,]CI'I V E AGREEMENT . 2
3. Non-waiver of Obicction to Admissibilitv
The furnishing of any document, information, data, study or other materials pursuant to this
Protective Agreement shall in no way limit or waive the right of the providing party to object to its
relevance or admissibility in any proceedings before this Commission.
4, Challenee to Confidcntiality
(a) Initial Challenee
This Protective Agreement establishes a procedure for the expeditious handling of
information that a parly claims is confidential. Any party may challenge the characterization of any
information, document, data or study claimed by the providing party to be a trade secret, proprietary
or confidential information. A party seeking to challenge the confidentiality of any information shall
first contact counsel for the providing party and attempt to resolve any difference by stipulation.
Resolution may include removing the confidential classifications, creating a non-confidential
summary, reformatting the information, etc.
(b) Subsequent Challenee
In the event that the parties cannot agree as to the character of the information challenged,
any party challenging the confidentiality may petition the Commission to rule upon the disputed
information. The Petition shall be served upon the Commission and all parties to the case who have
signed an Exhibit "A" as provided in this Protective Agreement. The Petition shalldesignate with
specificity the document or material challenged and state the grounds upon which the subject
material are deemed to be non-confidential by the challenging party.
(c) Challenee Hearine
The challenging party shall request that the Commission conduct an in camera proceeding
where only those persons duly authorized to have access to such challenged materials under this
Protective Agreement shall be present. This hearing shall be commenced no earlier than hve (5)
business days after serving the Petition on the providing party and the Commission. The record of
the in camera hearing shall be maTked "CONFIDENTIAL - Subject to Protective Agreement."
To the extent necessary, the transcript of such hearing shall be separately bound, segregated, sealed,
and withheld from public inspection by ary person not bound by the terms of this Agreement.
PROTECTIVE AGREI]MENT - 3
(d) Determination
The parties will ask the Commission to issue an Order determining whether any challenged
information or material is not properly deemed to be exempt from public disclosure pursuant to the
ldaho Public Records Act(ldaho Code $$ 74-l0l through 74-126). tf information is found to be not
exernpt from disclosure, no party shall disclose such challenged material or use it in the public
record, or otherwise outside the proceedings for at least five (5) business days unless the providing
party consents to such conduct. This procedure enables the restrictions of this Agreement from
material claimed to be confidential. Such relief may be sought from the Commission or a court of
competent j urisdiction.
5. (a) Rcccirrt Into Evidence
Provision is hereby made for receipt into evidence in this proceeding of materials claimed to
be confidential in the following manner:
(l) If the requesting party intends to use Confidential Information or to make
substantive reference to Confidential Information supplied to it under this Agreement, it shall give
reasonable prior notice of such intention to the providing party and shall provide copies of the used
Confidential Information or substantive reference to Confidential Information onlyto the providing
pafty, and such other parties, if any, who have executed an Exhibit "A" to this Protective Agreement.
(2) One (l) copy of the used Confidential Information or substantive reference to
Confidential lnformation or substantive reference to Confidential Information described in paragraph
5(aXl) shall be placed in the sealed record.
(3) The copy of the documents to be placed in the sealed record shall be tendered by
counsel for the providing party to the Commission, and shall be maintained in accordance with the
terms of this Protective Agreement.
(b) Seal
While in the custody of the Commission, materials containing Confidential Information shall
be marked "CONFIDENTIAL - SUBJECT TO ATTORNEY'S CERTIFICATE OF
CONFIDENTIALITY" and shall not be examined by any person except under the conditions set
forth in this Agreement, if applicable.
PROTECTIVE AGREEMENT - 4
(c) .fir Carrera Hearing and Transcriots
Any Confidential Information that must be orally disclosed at a hearing in the proceedings
shall be offered at an in camera hearing, attended only by persons authorized to have access to the
information under this Protective Agreement. Similarly, any transcription of any examination or
other reference to Conhdential Information (or that portion of the record containing Confidential
Information) shall be marked and treated as provided herein for Confidential Information.
(d) Access to Record
Access to sealed testimony, records, and information shall be limited to the Commission and
persons who have signed an Exhibit "A" as provided in this Protective Agreement, unless such
information is released from the restrictions of this Agreement either through agreement of the
parties or after notice to the parties and hearing, pursuant to the order of the Commission and/or the
final order of a court having final jurisdiction.
(e) Appeal
Should an appeal from the proceeding be taken, sealed portions of the record may be
forwarded to any court of competent jurisdiction for purposes of an appeal, but under seal as
designated herein for the information and use of the court. If a portion of the record is forwarded to a
court under seal for the purposes of an appeal, the providing party shall be notified which portion of
the sealed record has been designated by the appealing party as necessary to the record on appeal.
6. Use in Pleadines
Where references to Confidential Information in the sealed record or with the custodian is
required in pleadings, briefs, arguments, or motions (except as provided in Paragraph 5), it shall be
by citation to title or exhibit number or some other description that will not disclose the substantive
Confidential Information contained therein. Any use of or substantive references to Confidential
Information shall be placed in a separate section of the pleading or brief and submitted to the
Commission pursuant to Paragraph 5. This sealed section shall be served only on counsel of record
who have signed the nondisclosure agreements set forth in Exhibit "A" attached to this Protective
Agreement, and may, in turn, be disclosed by them only to individuals who likcwise signed Exhibit
,.Arr.
PROTECTIVE AGREEMEN . 5
7. $urrolqsry aflRecord
If deemed necessary by the Commission, the providing parties shall prepare a written
summary of the Confidential Information referred to in Orders to be issued to the public and the
parties.
8. Return or Destruction of Confidential Information
(a) Upon request of the providing party, all original documents and copies of the
Confidential lnformation shall be: (l) returned to the providing party; or (2) or at the option of the
recipient destroyed within thirty (30) days after the final settlement or conclusion of the proceedings,
including administrative or judicial review thereof. After return or destruction of documents
pursuant to this paragraph, and upon request, a written receipt veriffing return or destruction shall be
provided by counsel.
(b) On a case-by-case basis and upon notification to the utility, the Commission Staff
may retain one copy of the Confidential Information under seal. Notwithstanding any other
provision in this Agreement, any member of Staff may review and use that copy of the Confidential
Information outside this proceeding while performing his or her duties as a Staff member. Staff s
use and disclosure of the Confidential Information in a later Commission proceeding shall be subject
to any protective agreement signed in the proceeding.
(c) Any notes maintained by a recipient of Confidential Information which embody or
rcflect any of the Confidential Information provided under this Agreement shall, upon request ofthe
providing party, be either returned to the providing party or, at the option of the recipient, destroyed.
9, Effective Date
This Protective Agreement shall become effective on the date hereof.
PROTECTIVE AGREEMENT - 6
\DATED this 2l't day of September 2017
IDAHO POWER COMPANY
By
Q . /) <---tz?rAuu il . / / o,</zlr.-,--lffi
Idaho Power Company
1221 West Idaho Street
Boise,ldaho 83702
Attorney Representing Idaho Power Company
IDAHO PUBLIC UTILITIES COMMISSION STAFF
By:J* (
')
Sean Costello
Deputy Attorney General
Idaho Public Utilities Commission
472 W est Washington Street
Boise,ldaho 83702
Attorney Representing the
Idaho Public Utilities Commission Staff
'I
PROTECTIVE AGREEMENT - 7
11*
^t- |
DATED this C5 day of September 2017.
IDAHYDRO
IDAHO CLEAN ENBRGY ASSOCIATION
C. Tom Arkoosh
Attorney Representing Idahydro and Idaho Clean Energy
Association
By
PROTECTIVE AGREEMENT. 8
DATED this of September 2017
IDAHO CLEAN ENERGY ASSOCIATION
David H. Arkoosh
Attorney Representing Idaho Clean Energy Association
By:
PROI'ECTIVE AGREEM ENT . 9
o**t"-
\/DATED this j*aayof Septemb er2017.
SNAKE RIVER ALLIANCE
NW ENERGY COALITION
By:
Hammond, Jr.
Representing Snake River Alliance and NW
Coalition
I
PROTECTIVE AGR-EEMENT - IO
I
DATED this X 7 day of September 2017
AURIC LLC
-F,rV i-By /
Preston N. Carter
Attorney Representing Auric Solar
PROTECTIVE AGREEMENT. I I
I
DATED thir2?\ay of Seprem ber2orT
AURIC LLC
De Nelson
Attomey Representing Auric Solar
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PROTECTIVE AGREEMENT . I2
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DArED tn" 2u4 day of September 2017.
IDAHO CONSERVATION LEAGUE
By:
Benjamin J.
Attorney Representing Idaho Conservation League
b
PROTECTIVE AGREEMENT. 13
n_$
DAI'ED this L5 day of September 2017.
SIERRA CLUB
By:
Kelsey Jae N
Attorney Sierra Club
PRO]-EC'I'IVF] ACREEMEN'T . I4
DATED this l(tb'auy or@zon.
Attorney
INTERMOUNTAIN WIND AND SOLAR, LLC
By:
Wind and Solar, LLC
PROTECTIVE AGREEMENT - I5
' ' +L Oc*$'t
DATED this lto day of S,qpffier 2017.
By:
INTERMOUNTAIN WIND AND SOLAR, LLC
Q
Brian W. Burnett
Attorney Representing Intermountain Wind and Solar, LLC
PROTECTIVE AGREEMENT . I6
P.
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0 DArED this 3 ou, offinrorr.
CTTY OF BOTSE CITY
By:
Boise
Germaine
Attomey Representing the City of Boise
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PROTECTIVE AGREE]VIENT . I7
3
DATED thiS -ZZ*hu,of September20lT.
IDAIIO
By:
PUMPERS ASSOCIATION, INC.
Olsen
Attorney Representing the Idaho Irrigation Pumpers
Association, Inc.
PROTECTIVE AGREEMENT. I 8
I
I
I
I
)^,.I{DATED this dl day of September 2017.
VOTE SOLAR
By:
David Bender
Attorney Representing Vote Solar
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1
PROTECTIVE AGREEMENT - 19
3
EXHIBIT ..A''
I have reviewed the foregoing Protective Agreement dated this Zl"t day of September 2017 in Case
No. IPC-E- 17- l3 and agree to be bound by the terms and conditions of such Agreement.
El"nnbAL\L)
Stacey
Public Utilities Commission
Employer or Firm
472 \4r. \uashiumou StreELBliseJL837Qz
)
Business Address
Commission Staff
Party
Date
lo /7
)
)EXHIBIT *A'
I have reviewed the foregoing Protective Agreement dated this 2lu_day of September 2017 in Case
No. IPC-E-17-13 and agree to be bound by the terms conditions of such Agreement.
Public Utilities Commission
Employer or Firm
472W. Washineton Street. Boise" ID 83702
Business Address
Party
Date
F
0
\
J
Commission Staff
II
EXHIBIT "A''
I have reviewed the foregoing Protective Agreement dated this 2l't day of September20lT in Case
No. IPC-E- 17- 13 and agree to be bound by the terms and conditions of such Agreement.
Public Utilities Commission
Employer or Firm
472 W. Washinston Street.se ID 81702
Business Address
Commission Staff
Party
Zr'
Date
)
i
)
EXHIBIT 6'A''
I have reviewed the foregoing Protective Agreement dated this 21't day of September 2017 in Case
No. IPC-E-17-13 and agree to be bound by the terms and conditions of such Agreement.
Public Utilities Commission
Employer or Firm
472 W . Washineton Street.rD 83702
Business Address
Commission Staff
2S :>eP Zort
Date
arley
Party
\
J"EXHIBIT "A"
I have reviewed the foregoing Protective Agreement dated this 2l't day of September 2017 in Case
No. IPC-E-17-13 and agree to be bound by the terms and conditions of such Agreement.
Mike
Public Utilities Commission
Employer or Firm
472 W . Washineton Street. Boise. ID 83702
Business Address
Commission Staff
Party
/o t{
Date
\
"fl
J
EXHIBIT "A"
I have reviewed the foregoing Protective Agreement dated this 2_[" day of September 2017 in Case
No. IPC-E-17-13 and agree to be bound by the terms and conditions of such Agreement.
Public Utilities Commission
Employer or Firm
472W. Washington Street, Boise. lD 83702
Business Address
Commission Staff
Party
Date
B
\t
EXHIBIT ..A''
I have reviewed the foregoing Protective Agreement dated this 2l't day of September20lT in Case
No. IPC-E-17-13 and agree to be bound by the terms and conditions of such Agreement.
Randy Lobb
Public Utilities Commission
Employer or Firm
472W. Washington Street. Boise,ID 83702
Business Address
Commission Staff
Party
?/ u /ro77
Date
EXHIBIT "A'
I have reviewed the tbregoing Protective Agreement dated September 21, 2077 ,inCase No
IPC-E-17-13 and agree to be bound by the terms and conditions of such Agreement.
Name
City of Boise
Employer or Firm
PO Box 500
Business Address
Party
0912912017
Date
i
EXHIBIT "A''
EXHIBIT "A"
I have reviewed the foregoing Protective Agreement dated September 2l , 2017 ,inCase No.
IPC-E-17-13 and agree to be bound by the terms and conditions of such Agreement.
Name Mic-lretle
Employer or
Business Address
Party
--1
Date
EXHIBIT "A''
fu k,' 5c,C; hik- fD 33'acl
EXHIBIT "A"
I have reviewed the foregoing Protective Agreement dated September 21,2017, in Case No
IPC-E-17-13 and agree to be bound by the terms and conditions of such Agreement.
DAVID M. COOPER, Trustee
Name
ldaho Hydroelectric Producer's Trust
Employer or Firm
802 West Bannock, 9th Floor
Business Address
Party
1012612017
Date
EXHIBIT "A"
EXHIBIT "A"
I have reviewed the foregoing Protective Agreement dated September 21, 2017,inCase No.
IPC-E- l 7- I 3 and agree to be bound by the terms and conditions of such Agreement.
Loutts M. Zanu rZrX
Name
-l-w,inl F*ltx Cqilrl L CbI4PA^]L/
Employer or Firm
P,a, e Y 326 / rtl |-,q1/,<. tr\ A s<.,3
Business Address
]DAH YDI?D
Party
0
Date
EXHIBIT *A''
EXHIBIT *A"
I have reviewed the foregoing Protective Agreement dated September 27,2017 , in Case No
IPC-E-I7-13 and agree to be bound by the terms and conditions of such Agreernent.
J6r.u T Srneq t<uAt-
Name
5uo rlocr. 11yora., . Txs.
Employer or Firm
lll SHosH0^,6 S'-t,<ee T il,
Sqtzc zoo 7r,,.r r *t FaLts. TDAuo 33?o
Business Address
i D*ttYDRo
Party
O.trtlr*- 6, zot 7
Date
EXHIBIT*A"
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EXHIBIT "A"
I have reviewed the foregoing Protective Agreement dated September 2 I , 2017 , inCase No.
IPC-E-17-13 and agree to be bound by the terms and conditions of such Agreement,
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flB.raNt- L*,,u Drr,,rE<
Employer or Firm
Business Address
Par$
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Date
EXHIBIT "A''
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EXHIBIT'A"
I have reviewed the foregoing Protective Agreement dated Septernber 2 1 ,2017 , in Case No.
IPC-E-I7-13 and agree to be bound by the terms and conditions of such Agreement.
Name
L-o *oc-\<-\
Employer or Firm
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Business Address 6,.^-. te_ 2.O c>
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Part, ir,r^,
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Date
EXMBIT'A"
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EXHIBTT "A',
I have reviewed the tbregoing Protective Agreement dated Septemlxr 21,2077 ,in Case No.
IPC-E- l7- 13 and agree to be bound by the terms and conditions of such Agreement.
A^/Til oMY fAtl)<fL
Name
/buJ<6L +fiSSac. rMc
Ernployer or Firm
t /.Vocs L k<e
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Business Address
-T"TFfr
Party
97 2 Dt
Date
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EXHBTT *A"
EXHIBIT "A"
I have reviewed the foregoing Protective Agreement dated September 21,2017 , in Case No.
IPC-E-I7-13 and agree to be bound by the terms and conditions of such Agreement.
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tbAt+" Gxll*(Aflor cgA1uz
Employer or Firm
(-J rb8
Business Address
ti;fttlo Cirxsi.P-VffircyJ LVAlt tL
Party
Z}t1
Date
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EXHIBIT*A"
EXI{IBIT ftA''
I have reviewed the foregoing Protective Agreement dated September2l,2077,in Case No.
IPC-E-I7-13 and agree to be bound by the terms and conditions of such Agreement.
lut& 1,.O),'ltrr1*
Name
S a",1, l]-irtn d//''ooou '
Employer or Firm
P- O . B x 17 7 /, 77ais"*I-D eszct 1
Business Address
Party
0crt 7 '/7
Date
\l
EXHIBIT'A"
EXHIBIT "A"
I have reviewed the foregoing Protective Agreement dated September 21, 2017 ,in Case No.
IPC-E-17-13 and agree to be bound by the terms and conditions of such Agreement.
,Uc"s
Name
r1 ,'fu^av.,--
Employer or Firm
d{ /e,*./'0- f/Oo I
Business Address
/uoe c / tg,4--
Party
?> -(
Date
EXHIBIT "A''
UT
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EXHIBIT'A''
I have reviewed the foregoing Protective Agreement dated September 21, 2017 , in Case No.
IPC-E-I7-13 and agree to be bound by the terms and conditions of such Agreement.
Name
Employer or Firm
Business Address
*lol, Lb^ f^ ^u Atsni,l^
Party "___at7__
loAtlt2
Date
EXHIBIT *A"
EXI{IBIT 3A''
I have reviewed the foregoing Protectivc Agreernent datcd September 21,2017,in Case No.
IPC-E-17-13 and agree to be bound by the terms and conditions of such Agreement.
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Name c.otth€L LaarnnD.
A, rtuR,+ Do-.,< 4,v> \otorl I^-
Employer or Finn
\'/tz /. 3(r* Sr. Booo -Do fs7o3
Business Address
TceA
Parly
o1/uz / tt
Date
EXHIBIT "A"
EXIIIBIT *A''
I have reviewed the foregoing Protective Agreement dated Septerrber 21,2017 ,in Case No.
IPC-E-17-13 and agree to be bound by the terms and conditions of such Agreement.
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Nanre beeiFJ,r.a,szv
Aoi\orz* Po-ea Ar(D N"""0, Ttu
Employer or Firrr
\4tL M \re 5 ttc TL {3zo\t
Business Address
t ceA
Party
s1/>z /t7
Date
EXHIBIT "A"
EXHIBIT "A'
I have reviewed the foregoing Protective Agreement dated September2l,20lT,inCase No.
IPC-E-I7-13 and agree to be bound by the terms and conditions of such Agreement.
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Name
&ta,6ht S,[* { L;Al-'
Employer or Firm V
{,,{
Business Address
t{7,
t@4
Parly
7/"/z,n
Date
EXHIBIT'4"
EXHIBIT *A''
I have reviewed the foregoing Protective Agreement dated September 2l ,2017 , in Case No.
IPC-E-I7-13 and agree to be bound by the terms and conditions of such Agreement.
Beau Husfloen
Name
Bluebird Solar and Light, LLC
Employer or Firm
POBox4714
Ketctum, lD 83340
Business Address
ldaho Clean Energy Association
Party
September 9,2017
Date
B* /L)^g,gna:ttr';--7
EXHIBIT *A''
EXHIBIT ..A"
I have reviewed the foregoing Protective Agreement dated September 21, 2017 , in Case No
IPC-E-17-13 and agree to be bound by the terms and conditions of such Agreement.
l*l*
Name t^t R . u,,,r^:leCo u,'/
s. l+
Employer or Firm
I t I 8 K*q[{5 }r. 8., rr. e37 tL
Business Address \l
I L.A
Party
Z(/.ot7
Date
EXHIBIT'A"
EXHIBIT "A"
I have reviewed the foregoing Protective Agreement dated September 21 , 2017 ,inCase No.
IPC-E-17-13 and agree to be bound by the terms and conditions of such Agreement.
(c,;n /(; n o
Name
ecr folor
Employer or Firm
{o t /U /?ldn el, flr.i/;on XD r56lL
Business Address
7c EA
Party
1-zz- t7
Date
EXHIBIT "A"
EXHIBIT ftA"
I have reviewed the foregoing Protective Agreement dated September 21, 2017,inCase No.
IPC-E-17-13 and agree to be bound by the terms and conditions of such Agreement.
Name
Employer or Firm
Business Address (Uikr, d+"L
IJ*f..-.\,.^
Party
Date
2
v
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EXHIBTT "A"
EXHIBIT *A'
I have reviewed the foregoing Protective Agreement dated September 21, 2017 ,in Case No.
IPC-E-I7-13 and agree to be bound by the terms and conditions of such Agreement.
Name
Vote Solar
Employer or Firm
360 22nd Street,Suite 730 CA94612
Business Address
Vote Solar
Party
September 28,20L7
Date
1
EXHIBIT "A''
\J
EXHIBIT (nA',
I have reviewed the forcgoing Protective Agreement dated September 2 | ,2017 , in Case No.
IPC-E- 1 7- I 3 and agree to be bound by the terms and conditions of such Agreement.
'(,-k G, / /,j-,,,4/ .t ;.L--
Name
V'ole S'rl^-
Employer or Firm
S'i o Er/"Lr, {),,,'*
It,at.*,{,rtr/co toa>O
Business Address
V rl, S,i^n
Party
?A - Snp' 7ot1
Date
EXHIBIT*4"
li't
;,/EXHIBIT'A''
I have reviewed the foregoing Protective Agreement dated September 21, 2017 , in Case No.
IPC-E-17-13 and agree to be bound by the terms and conditions of such Agreernent.
Name
Employer or Firm
{ol h t^"tt; ,8,;, Z)
Business Address
Srrr^ (lrl
Party
2t+?tttt
Date
EXHIBIT*A"
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EXHIBIT'A''
I have reviewed the foregoing Protective Agreement dated September2l,Z}l7,in Case No.
IPC-E-I7-13 and agree to be bound by the terms and conditions of zuch Agreement.
Slecro Clrh
Employer or Firm
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Business Address
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Party
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Date
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EXHIBIT "A''
/lr*l LJ"f*^"*, -Name /
1 EXHIBIT'A'
I have reviewed the foregoing Protective Agreement dated September2l,20l7,in Case No.
IPC-E-17-13 and agree to be bormd by the terms and conditions of such Agreement.
Aw-tu S"\ar, LLC-
Employer or Firm
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Business Address
Au.i. S.,l^t, LLU
Par$
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Date
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EXHIBIT"A"
1tA7-> Elias $islr-oP
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I have reviewedthe foregoingProtectiveAgrccme,ntdated Septernbo2I,20\7,inCaseNo
IPC-E-17-13 and agree to be bound by the tErms and conditions of such Agree,meut.
f,)c'tr-ta[a..s SYri=\e-rNamt J
Employer or Firm
Business Address
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Pafty
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)EXHIBIT'A"
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