20220315IPC to ICIP 11-18.pdf

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:i:1i.','i:D An ]oACOPP Company
March 15,2022
VIA ELECTRONIC FILING
Jan Noriyuki, Secretary
ldaho Public Utilities Commission
11331 W. Chinden BIvd., Bldg 8,
Suite 201-A (83714)
PO Box 83720
Boise, ldaho 83720-0074
Re Case No. !PC-E-2141
ln The Matter Of ldaho Power Company's Application For Authority to
Proceed with Resource Procurements to Meet ldentified Capacity
Deficiencies in 2023, 2024, and 2025 to Ensure Adequate, Reliable, and
Fair-Priced Service to its Customers
Dear Ms. Noriyuki
Attached for electronic filing is ldaho Power Company's Response to the Second
Production Request and First Request forAdmission of the lndustrial Customers of ldaho
Power in the above entitled matter. lf you have any questions about the attached
document, please do not hesitate to contact me.
Very truly yours,
DONOVAN WALKER
Lead Counsel
dwalker@ida hooower.com
DEW:cd
Enclosures
- .- ,A
- -'-. r..,.-rn !l
Donovan E. Walker
Mzda!4-
DONOVAN E. WALKER (lSB No. 5921)
ldaho Power Company
1221 West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
dwa lker@ idahopower.com
Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR
AUTHORITY TO PROCEED WITH
RESOURCE PROCUREMENTS TO MEET
IDENTIF]ED CAPACITY DEFICIENCIES IN
2023,2024, AND 2025 TO ENSURE
ADEQUATE, RELIEABLE, AND FAIR.
PRICED SERVICE TO ITS CUSTOMERS.
cAsE NO. rPC-E-2141
IDAHO POWER COMPANY'S
RESPONSE TO THE SECOND
PRODUCTION REQUEST AND
FIRST REQUEST FOR
ADMISSION OF THE INDUSTRIAL
CUSTOMERS OF IDAHO POWER
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COMES NOW, ldaho Power Company ("ldaho Powe/' or "Company'), and in
response to the Second Production Request of the lndustrial Customers of ldaho Power
to ldaho Power Gompany and First Request for Admission dated February 22,2022,
herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST AND FIRST REQUEST FOR ADMISSION
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER.l
REQUEST NO. 11 AND REQUEST FOR ADMISSION NO. l: The lClP Request
for Production No. 2 provided:
Page 23 of the Company's Application references "[M]odern tools used in attempts to
force deregulation onto state jurisdictions that have chosen to retain the traditional
vertically integrated, state regulated service providers..." later in the same sentence
the Company's Application identifies some of those modern tools, "such as . . . [an]
anticompetitive tax credit policy for renewable energy procurement."
The lClP Request for Production No. 2 then asked ldaho Power to identify the
"anticompetitive tax credit policy" itwas referencing in its application. The lClP specifically
asked:
Please identify the "anticompetitive tax credit policy for renewable energy
procuremenf [that] ...forces ... deregulation onto state jurisdictions."
In response, ldaho Power stated that "Federal and state tax policies can have
different impacts on regulated and non-regulated utilities." And that, "Ihese policies have
been cited as a factor in driving non-utility ownership of renewables, which erodes the
regulatory compact for veftically integrated utilities;'
Please admit that the Company is unaware ol an"anticompetitive tax credit policy
for renewable energy procuremenf ... [that] ... forces deregulation onto state jurisdicfions."
ln the alternative, please respond to the question and identify the tax credit policy[ies]that
the company is referencing in its Application that "forces ... deregulation onto state
jurisdictions."
ln the second part of Request No. 2, the lClP asked ldaho Power to:
Please explain ldaho Powe/s understanding as to how said policies "forces
de reg u I ation o nto state j u ri sd icfions. "
ln response, ldaho Power stated:
These policies have been cited as a factor in driving non-utility ownership of
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST AND FIRST REQUEST FOR ADMISSION
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 2
renewables, which erodes the regulatory compact for veftically integrated utilities.
Please admit that the Company has no understanding as to how said polices
"forces . . . deregulation onto state jurisdictions." ln the alternative, please respond to the
question and explain Idaho Powe/s understanding as to how said policies "forces. . .
dereg u I ation onto state j u risd icfions."
RESPONSE TO ICIP REQUEST NO. 11 AND REQUEST FOR ADMISSION NO.
1:
The Company denies that it is unaware of an"anticompetitive tax credit policy for
renewable energy procuremenf ... [that] ... forces deregulation onto state jurisdicfions"
and denies that it has no understanding as to how said policies "forces . . . deregulation
onto state ju ri sdiction s ;'
As explained in the Company's response to lClP Request No. 2, tax policies can
result in differing tax outcomes for regulated utilities and unregulated renewable
developers, thus potentially making renewable Power Purchase Agreements ("PPA")
pricing appear more attractive relative to utility ownership. For example, electric utilities
are subject to tax normalization rules that require investment tax credits ("lTC") to be
amortized overthe life of the associated asset. Unregulated renewable resource investors
can utilize the full benefit of the ITC in the first year of the associated asset's useful life.
If all other price components were equal, this tax treatment would result in a lower overall
PPA cost as compared to utility ownership. \A/hile Idaho Power is not representing that
tax normalization rules are bad or somehow flawed, in the example of regulated utility
ownership versus unregulated renewable ownership there is a disparity in tax treatment
that favors the unregulated owner. Therefore, if an evaluation of potential resource
projects focuses only on price attributes, PPAs are likely to be selected over utility-owned
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST AND FIRST REQUEST FOR ADMISSION
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER- 3
resources even though other benefits of the regulatory compact may otherwise justifiably
support utility ownership of generation resources. lt is the Company's position in this case,
that adding PPAs from unregulated third-party owners to the exclusion of regulated utility
ownership is a form of deregulation.
The response to this Request is sponsored by Tim Tatum, Vice President of
Regulatory Affairs of ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST AND FIRST REQUEST FOR ADMISSION
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 4
REQUEST NO. 12 AND REQUEST FOR ADMISSION NO. 2: ICIP Request for
Production No. 4 provided:
Yet another 'modern tool' referenced by ldaho Power that is being used to "force
deregulation onto state jurisdictions" are the "competitive procurement rules and
regulations specifically designed to "remove the utility's competitive advantage"... "
Please . . . explain how rules that are designed to "remove the utility's competitive
advantage" are being used to "force deregulation onto state jurisdictions."
ln its response, the Company stated, "Please see fhe Company's response fo
IPUC Sfaffs Requesf No. 12 for a discussion and analysis of such rules and regulations;'
Counsel for the lClP has been unable to find a reference, or an explanation, of how
"competitive procurement rules and regulations are specifically designed to remove the
utility's competitive advantage" in the Company's response to IPUC Staffs Request No.
12.
Please admit that the Company has no understanding as to how said "competitive
procurement rules and regulations are specifically designed to remove the utility's
competitive advantage." ln the alternative, please respond to the question and explain
ldaho Powe/s understanding as to how said how competitive procurement rules and
regulations are specifically designed to remove the utility's competitive advantage.
RESPONSE TO ICIP REQUEST NO. 12 AND REQUEST FOR ADMISSION NO.
2:
The Company denies lClP's statement. The Company's response to Staffs
Request No. 12 describes specific features of the resource procurement rules that can
remove the utility's competitive advantage. That response is repeated, in part, below.
While the OPUC Resource Procurement Rules do contemplate non-price factors
as part of the evaluation, the OPUC Resource Procurement Rules appear to heavily
weight price over some of the operational constraints that occur with a contracted
resource. OAR 860-089-0300(1)(a) provides that "[e]lectric company and affiliate bids
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST AND FIRST REQUEST FOR ADMISSION
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 5
must be treated in the same manner as other bids." However, ownership of a resource
and a contractual right to the output of a resource, when constrained by the other terms
and conditions of the contract, are not equivalent. For instance, OAR 860-089-0300(5)
provides that the "electric company issuing the RFP must allow independent power
producers to submit bids with and without an option to renew, and may not require that
bids include an option for transferring ownership of the resource." OAR 860-089-0400(2),
pertaining to bid scoring, provides that the "electric company must base the scoring of
bids and selection of an initial shortlist on price and, as appropriate, non-price factors.
Non-price factors must be converted to price factors where practicable." The OAR then
prescribes the method by which the utility must develop the price and non-price scores.
This includes subsection (2)(d), which provides that scoring criteria "may not be based on
renewal or ownership options, except insofar as these options affect costs, revenues,
benefits or prices.' The combination of these rules, together with an independent
examiner and intervenors heavily focused on price, introduce a heavy bias toward PPA
transactions. This is further exacerbated by federal tax credit amortization rules for
regulated utilities that favor third-party ownership of resources, resulting in a power
purchase agreement (PPA) bias...
The response to this Request is sponsored by Tim Tatum, Vice President of
Regulatory Affairs of ldaho Power Company.
]DAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST AND FIRST REQUEST FOR ADMISSION
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER_6
REQUEST NO. 13: At page 15 of the Company's Application ldaho Power states
that, "ldaho Power objected to the adoption of the Competitive Bidding Guidelines, the
precursor to the OPUC Resource Procurement Rules." Please provide copies of ldaho
Power's objections that are referred to in its Application.
RESPONSE TO lClP REQUEST NO. 13: The Public Utility Commission of
Oregon (OPUC) adopted its Competitive Bidding Guidelines in OPUC Docket UM 1182.
ldaho Power's filed comments in OPUC Docket UM 1182 are publicly available on the
OPUC's website.
ldaho Power's objections referenced on page 15 of the Company's Application
refer to the OPUC's presumption that there is a utility self-build bias that needed to be
mitigated through the adoption of the Competitive Bidding Guidelines. The Commission
adopted its original Competitive Bidding Guidelines in OPUC Order No. 06-446 in August
2006. Concurrent with adopting the Competitive Bidding Guidelines, the OPUC also
initiated Docket UM 1276 "to address the bias inherent in the utility resource procurement
process that favors utility ownership of generation assets over Power Purchase
Agreements (PPAs) with third parties." OPUC Order No. 11-001 at 1. ln Docket UM
1276, the OPUC "accept[ed] the premise that a bias exists in the utility resource
procurement process that favors utility-owned resources over PPAs' and based on the
acceptance of the premise ordered the following:
we reopen Docket UM 1182 to further examine issues related
to our competitive bidding guidelines. ln Order No. 06*446,
this Commission adopted comprehensive guidelines to
improve competitive bidding for utility resource acquisitions.
Utilities are now expected to issue an RFP for major resources
with generating capacity greater than 100 MW. Utilities must
also engage an lE to oversee the RFP process if they expect
to receive Commission acknowledgement of the finalshort-list
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST AND FIRST REQUEST FOR ADMISSION
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 7
of RFP resources. Although these guidelines have greatly
increased confidence that the utility RFP process is being
conducted fairly and properly, we believe further
improvements are needed to fully address utility self-build
bias.
OPUC Order No. 11-001 at 5-6.
!n the re-opened OPUC Docket UM 1182 proceeding the Company repeatedly
objected to the OPUC's presumed utility self-build bias. For example, at page 5 of
comments filed by ldaho Power on April 22,2011, in the re-opened Docket UM 1182, the
Company, explained:
The Commission specifically reopened this docket to explore
further improvements to the competitive biddlng guidelines
designed to address utility self-build bias. As an initial matter
and one of extreme significance to ldaho Power, the
Commission has presumed that this bias exists but it has not
reached this conclusion based upon evidence in the record
before it. Rather, in Docket UM 1276 the Commission
instructed the parties to assume that the bias exists. ldaho
Power objects to the comments of any party in this proceeding
that assumes this Commission has made a finding that a build
versus buy bias exists. The Commission has not reached
such a finding, and ldaho Power reserves the right to submit
evidence to the contrary.
ldaho Power repeated this objection at page 2 of a Prehearing Brief, filed on
February 1,2013, in Docket UM 1 182:
ln Order No. 11-001 the Commission assumed that a "bias
exists in the utility resource procurement process that favors
utility-owned resources over[power purchase agreements]"
because utilities earn a return on utility-owned resources but
do not earn a return on power purchase agreements. \Mrile
the Commission assumed the bias existed, it neither
quantified the significance of the assumed bias nor concluded
that the assumed bias resulted in customer harm.
To avoid doubt, ldaho Poweremphasized in footnote 3 of the Prehearing Brief that
it has previously "noted its objection to [the self-build bias] assumption, which was not
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST AND FIRST REQUEST FOR ADMISSION
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 8
based upon evidence in the record. ldaho Power continues to object to this premise based
upon the evidene presented in Phase ll of this docket."
The response to this Request is sponsored by Tim Tatum, Vice President of
Regulatory Affairc of ldaho Power Company.
IDAHO POVVER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST AND FIRST REQUEST FOR ADMISSION
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POVVER - 9
REQUEST NO. 14: Did ldaho Power also object to the adoption of the OPUC
Resource Procurement Rules? lf so, please provide copies of ldaho Powe/s objections
to the adoption of the OPUC Resource Procurement Rules.
RESPONSE TO lGlP REQUEST NO. 14: Yes. ldaho Power actively engaged in
the investigations and rulemakings that developed Oregon's resource procurement rules.
ldaho Power filed comments both individually and in coordination with Oregon's other
investor-owned utilities. The Company's and joint utility comments made suggestions to
improve certain aspects of the rules and objected to other provisions. Ultimately, the
OPUC weighed those suggestions and adopted the rules.
Please see ldaho Powe/s response to lClP Request No. 13 describing the
OPUC's presumption of a utility self-build bias, which informed its Competitive Bidding
Guidelines. !n addition, please see the Joint Utility Comments in filed on February 14,
2018, in the OPUC's rulemaking proceeding that lead to the adoption of the Resource
Procurement Rules, OPUC Docket AR 600. Among other things, these comments state
that 'certain proposals depart from the Commission's long history of promoting fairness
and transparency in competitive bidding, and instead reflect an anti-utility bias."
The response to this Request is sponsored by Tim Tatum, Vice President of
Regulatory Affairs of ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST AND FIRST REQUEST FOR ADMISSION
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER- 1O
REQUEST NO. 15: ldaho Power, in its response to the IPUC Stafts Request for
Production No. 7 states that the premise of the OPUC competitive procurement rules is
flawed, stating
The OPUC Resource Procurement Rules were established under the inconect
premise that without such rules, there is an inherent bias toward utili$ ownership or
that the utility holds an unfair advantage over third-pafi owners that must be
corrected. ln fact the utility does not hold an unfair advantage over third-party
owners...
Please provide copies of all pleadings filed by ldaho Power in which it sought to
redress the OPUC's alleged erroneous rulemaking when it based said rules on an
"incorrect premise." PIease identify the year said rules were first adopted and explain why
ldaho Power has waited until now to raise objections before the ldaho PUC as to the
incorrect premise upon which the Oregon Commission's established its Resource
Procurement Rules. Please identiff, and provide documentation, as to when ldaho Power
first came to the realization that the OPUC Rules referenced above, "were established
under [an] inconect premise."
RESPONSE TO lClP REQUEST NO. 15: Please see ldaho Power's response to
lClP Request No. 13 describing the OPUC's presumption of a utility self-build bias, which
informed its Competitive Bidding Guidelines. ln addition, please see the Joint Utility
Comments in filed on February 14,2018, in the OPUC's rulemaking proceeding that lead
to the adoption of the Resource Procurement Rules, OPUC DocketAR 600. Among other
things, these comments state that "certain proposals depart from the Commission's long
history of promoting fairness and transparency in competitive bidding, and instead reflect
an anti-utility bias."
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST AND FIRST REQUEST FOR ADMISSION
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER- 11
The resBonse to this Request is sponsored by Tim Tatum, Mce-President of
Regulatory Affairs of ldaho Power Gompany.
IDAI{O POVI/ER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST AT{D FIRST REQUEST FOR ADMISSION
OF THE INDUSTR]AL CUSTOMERS OF IDAHO POWER- 12
REQUEST NO. 16: ln its response to IPUC Staff Request for Production No. 12,
ldaho Power asserts that,
For a utility-scale baftery storage facility in pafticular...
lf the company were to execute a PPA for a battery storage facili$, the dispatchability,
curtailment, maintenance, secuity, mandatory payment, and operational terms,
conditions, and limitations would be pre-defined for the term of the PPA.
And that
These terms would be detrimental [to the company]...
Please explain (with specific legal citations) what would require ldaho Power
execute a PPA for a utility-scale battery storage project that is detrimental to the
Company.
RESPONSE TO lClP REQUEST NO. 16: ldaho Power was not attempting to
describe this issue from a legal perspective, but from a practical perspective. A third-party
PPA with pre-defined terms related to curtailment, discharge of stored energy, and other
operationa! mafters would limit the Company's flexibility when making decisions on how
to optimize its system resources. lf those same resources are owned by the Company,
those contractual limitations would not exist and the Company wil! have greater flexibility
to make decisions that are optimalfrom both an operationaland a cost standpoint, which
is beneficialto the Company and its customers.
The response to this Request is sponsored by Tim Tatum, Vice-President of
Regulatory Affairs of ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCT]ON REQUEST AND FIRST REQUEST FOR ADMISSION
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 13
REQUEST NO. 17: Does ldaho Power understand that ldaho PUC Order No.
32745 requires it to comply with the Oregon competitive bidding requirements governing
the issuance of an RFP by ldaho Power for new supply-side resources?
RESPONSE TO ICIP REQUEST NO. 17: Yes. That is why the Company is
requesting a change to that requirement in this docket. On page 1 of the Company's
Application in this docket, the Company states:
"ldaho Power requests that the Commission issue an order: (1) eliminating the
IPUC requirement to comply with the Public Utility Commission of Oregon ("OPUC")
resource procurement rules in favor of a competitive, but expedited process;...
ldaho Power goes on to explain in part lll of its Application that the Oregon
resource procurement rules are unable to timely address the dynamic circumstances that
the Company is currently facing and presents in part lV of its Application its alternate
Request for Proposa! and Certificate of Public Convenience and Necessity process.
The response to this Request is sponsored by Tim Tatum, Vice President of
Regulatory Affairs of ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST AND FIRST REQUEST FOR ADMISSION
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER- 14
REQUEST NO. 18: At page 15 of the Company's Application, ldaho Power asserts
that "fhe OPUC Ru/es do not align with the state of ldaho 's sysfem of public utility
regulation." Please provide copies of all pleadings filed by ldaho Power before the OPUC
in which it objected to the OPUC's Rules referenced above because those rules "do nof
align with the state of ldaho's sysfem of utility regulation." Please identiff, and provide
documentation, as to when ldaho Power first came to the realization that the OPUC Rules
referenced above, "do not align with the state of ldaho's sysfem of utility regulation."
RESPONSE TO IGIP REQUEST NO. 18: Please see the Company's response to
lClP Request No. 13 describing the OPUC's presumption of a utility self-build bias. The
Company has not filed pleadings with the OPUC using the specific term cited by lClP.
The Company is making that assertion to the ldaho Public Utilities Commission in this
case.
The response to this Request is sponsored by Tim Tatum, Vice President of
Regulatory Affairs of ldaho Power Company.
Respectfully submitted this 1Sth day of March 2022
fuzdat4-
DONOVAN E. WALKER
Attorney for ldaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST AND FIRST REQUEST FOR ADMISSION
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 15
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 1Sth day of March 2022,1 served a true and correct
copy of the within and foregoing Idaho Power Company's Response to the Second
Production Request and First Request forAdmission of the lndustrial Customers of ldaho
Power upon the following named parties by the method indicated below, and addressed
to the following:
Dayn Hardie
ldaho Public Utilities Commission
Po Box 83720
Boise, ldaho 83720-0074
Peter J, Richardson
RICHARDSON ADAMS, PLLC
515 N.27th Street
Boise, ldaho 83702
Dr. Don Reading
6070 Hill Road
Boise, lD 83703
ldaHydro
C. Tom Arkoosh
Amber Dresslar
ARKOOSH LAW OFFICES
913 w. River Street, Suite 450
P.O. Box 2900
Boise, lD 83701
ldaho Conservation League
Benjamin J. Otto
Emma E. Sperry
710 North 6th Street
Boise, ID 83701
Greg M. Adams
RICHARDSON ADAMS, PLLC
515 N.27th Street
Boise, ldaho 83702
Spencer Gray
NIPPC
P.O. Box 504
Mercer lsland, WA 98040
Emailed to:
davn. hardie@puc. idaho.qov
Emailed to:
[e-mail]
Emailed to:
d read [e-mail]
Emailed to:
tom. a [e-mail]
amber.d resslar@arkoosh. com
erin. [e-mail]
Emailed to:
botto@ida hoconservation.oro
esperrv@ id a hocon se rvatio n. o ro
Emailed to:
q reo @richa rdsonadams.com
Emailed to:
[e-mail]
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST AND FIRST REQUEST FOR ADMISSION
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER- 16
Abigail R. Germaine
Elam & Burke, P.A.
251 E. Front St., Suite 300
P.O. Box 1539
Boise, ID 83701
Scott Miller
Western Power Trading Forum
1540 River Park Dr., Suite 211
Sacramento, CA 95815
Max Greene
Renewable Northwest
421 SW 6th Ave., Suite 1400
Portland, OR 97204
Jim Kreider
STOP BB2H Coalition
60366 Marvin Road
La Grande, OR 97850
Jack Van Valkenburgh
Van Valkenburgh Law, PLLC
P.O. Box 531
Boise, !D 83701
Ed Jewell
Boise City Attorneys Office
P.O. Box 500
Boise, lD 83701
Wil Gehl
Boise City Dept. of Public Works
P.O. Box 500
Boise, !D 83701
Emailed to:
[e-mail]
Emailed to:
[e-mail]
Emailed to:
[e-mail]
Emailed to:
[e-mail]
Emailed to:
iack@va nva lkenbu ro h law.com
Emailed to:
eiewell@citvofboise,o rq
boisecitvatto rnev@citvofboise. orq
Emailed to:
wqeh [e-mail]
Christy Davenport, Lega! Assistant
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST AND FIRST REQUEST FOR ADMISSION
OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 17