20071228Vol I Prehearing Conference.pdf

,ORIGlNAL.BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY'S PETITION TO INCREASE
THE PUBLISHED RATE ELIGIBILITY CAP
FOR WIND-POWERED SMALL POWER
PRODUCTION FACILITIES; AND
TO ELIMINATE THE 90%/110%
PERFORMANCE BAND FOR WIND-POWERED
SMALL POWER PRODUCTION FACILITIES
IN THE MATTER OF THE PETITION OF
ROCKY MOUNTAIN POWER FOR AN ORDER
REVISING CERTAIN OBLIGATIONS TO
ENTER INTO CONTRACTS TO PURCHASE
ENERGY GENERATED BY WIND- POWERED
SMALL POWER GENERATION QUALIFYING
FACILITIES
f,.
IN THE MATTER OF THE PETITION OF
AVISTA CORPORATION FOR AN ORDER
REVISING AVISTA CORPORATION'S
OBLIGATIONS TO ENTER INTO
CONTRACTS TO PURCHASE ENERGY
GENERATED BY WIND-POWERED SMALL
POWER GENERATION FACILITIES
BEFORE
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NO. IPC-E-07-03
NO.
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0"f-07
NO. AVU-E-07-02
PREHEARING
CONFERENCE
COMMISSIONER MACK A. REDFORD (Presiding)
COMMISSIONER MARSHA H. SMITH
COMMISSIONER JIM KEMPTON
PLACE:Commission Hearing Room
472 West Washington
Boise, Idaho
DATE:December 11, 2007
VOLUME I - Pages 1 - 42
CSB REPORTING
Constance S. Bucy, CSR No. 187
23876 Applewod Way * Wilder, Idaho 83676
[phone] * [phone]
Email csb~heritagewifi.com.
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1 APPEARANCES
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3 For the Staff:Scott Woodbury Esq.
Deputy Attorney General
472 West Washington
Boise, Idaho 83720-0074
Barton L. Kline, Esq.
Idaho Power Company
Post Office Box 70
Boise, Idaho 83707-0070
Jordan Whi te , Esq.
Rocky Mountain Power
201 S. Main Street
Suite 2300
Salt Lake City, Utah 84111
Michael G. Andrea, Esq.
Avista Corporation
1411 E. Mission Ave., MSC-23
Spokane, Washington 99202
RICHARDSON & 0' LEARY
by Peter J. Richardson, Esq.
Post Office Box 7218
Boise, Idaho 83702
William M. Eddie, Esq.
Advocates for the West
610 SW Alder Street
Suite 910
Portland, Oregon 97205
Rich Rayhill
Ridgeline Energy, LLC
720 West Idaho Street
Suite 39
Boise, Idaho 83702
Glenn Ikemoto
Idaho Windfarms, Inc.
672 Blair Avenue
Piedmont, Calif. 94611
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For Idaho Power:
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8 For Rocky Mountain Power:
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For Avista Corporation:
For Exergy DevelopmentGroup of Idaho:
For Renewable Northwest
Proj ect & NW Energy
Coalition:
For Ridgeline Energy:
For Idaho Windfarms:
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APPEARANCES
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1 A P PEA RAN C E S (Continued)
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3 For Cassia Gulch Wind Park
& Cassia Wind Farms &
Intermountain Wind:
McDEVITT & MILLER
by Dean J. Miller, Esq.
Post Office Box 2564
Boise, Idaho 83701-2564
Gerald Fleischman
11535 West Hazeldale Court
Boise, Idaho 83713
Brian D. Jackson
Renaissance Engineering
& Design
2792 Desert Wind Road
Oasis, Idaho 83647-5020
M.J. Humphries
Blue Ribbon Energy, LLC
2630 Central Avenue
Idaho Falls, Idaho 83406
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For Gerald Fleischman:
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For Renaissance
Engineering & Design:
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For Blue Ribbon Energy:
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APPEARANCES
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1 BOISE, IDAHO, TUESDAY, DECEMBER 11, 2007, 9:00 A. M.
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4 COMMISSIONER REDFORD: This is the Idaho
5 Public Utili ties Commission. My name is Mack Redford and
6 I'm the Chairman of this hearing. Seated to my left is
7 Marsha Smith, Commissioner, and to my right is Jim
8 Kempton, Commissioner. We are here on a prehearing
9 conference as governed by Rule 211 of the Idaho Public
10 utilities Rules of Procedure and I would remind the
11 parties that this hearing pursuant to the Rule is for the
12 purpose of formulating or simplifying the issues
13 contained in sessions of fact or identification of
14 documents to avoid unnecessary proof, scheduling
15 discovery, et cetera.
16 The cases we're involved with are Case
17 No. IPC-E-07-03 which involves Idaho Power's petition to
18 increase the public rate eligibility cap; Case No.
19 PAC-E-07-07 in the matter of the petition of Rocky
20 Mountain Power; Case No. AVU-E-07-02 in the matter of the
2 1 petition of Avista Corporation for its order regarding
22 obligations to enter into contracts to purchase energy
23 generated by small wind developers.
24 First of all, I'd like to note for the
25 parties that this hearing is a prehearing conference only
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1 and it's not for the purpose of arguing the merits of the
2 various cases. I would like to note and for the record
3 take the appearance of the parties.
4 MR. WOODBURY: Scott Woodbury, Deputy
5 Attorney General, for Commission Staff and I would
6 indicate I have spoke this morning with Michael Andrea,
7 counsel for Avista, and he is enroute. There were fog
8 problems in Spokane and so he'll be late to the
9 hearing.
10 COMMISSIONER REDFORD: Okay. Sir?
11 MR. KLINE: Yes, I'm Bart Kline appearing
12 on behalf of Idaho Power Company.
13 COMMISSIONER REDFORD: Thank you.
14 MR. EDDIE: William Eddie here on behalf
15 of Renewable Northwest Proj ect and Northwest Energy
16 Coalition.
17 MR. MILLER: Thank you, Mr. Chairman.
18 Dean J. Miller of the firm McDevitt & Miller appearing on
19 behalf of Cassia Wind and John Deere Renewables in the
20 Idaho Power case and on behalf of Intermountain Wind in
21 the Rocky Mountain Power case.
22 MR. WHITE: Jordan White on behalf of
23 Rocky Mountain Power.
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MR. RICHARDSON: Peter Richardson, Mr.
Chairman, on behalf of Exergy Development Group of Idaho,
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1 Inc. We're a party in all three dockets.
2 COMMISSIONER REDFORD: Thank you. I
3 noticed that there are other people listed as parties,
4 Renewable Northwest Proj ect and that is
5 MR. EDDIE: That's me.
6 COMMISSIONER REDFORD: Okay, thank you.
7 I'm just trying to get everything straight. Ridgeline
8 Energy, LLC? No one appearing for Ridgeline? Idaho
9 Windfarms? Would you like to come up and take a seat,
10 sir?
11 MR. IKEMOTO: Thank you.
12 COMMISSIONER REDFORD: And you're Glenn
13 Ikemoto?
14 MR. IKEMOTO: Yes.
15 COMMISSIONER REDFORD: Okay, and Avista
16 Corporation, he's on his way. Snake River Alliance? No
17 one appearing for Snake River. Gerald Fleischman?
18 MR. FLEISCHMAN: I'm over here.
19 COMMISSIONER REDFORD: Okay. Renaissance
20 Engineering? Blue Ribbon Energy? And you are, sir?
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MR. HUMPHRIES: M.J. Humphries.
COMMISSIONER REDFORD: Thank you. INL
23 Biofuels, we received a letter from INL that states that
24 they are not able to attend, but the statement, I
25 believe, urges the Commission to approve the contracts
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1 which have previously been entered into in all of these
2 cases. That is the total number of parties. I note that
3 Mr. Richardson's client is appearing in all the cases; is
4 that correct?
5 MR. RICHARDSON: That's correct,
6 Mr. Chairman.
7 COMMISSIONER REDFORD: From a procedural
8 standpoint, I would like to ask Mr. Woodbury to give us,
9 give the Commission, a procedural update on where we are
10 in this case.
11 MR. WOODBURY: Thank you, Mr. Chairman.
12 This case has a long background. It's almost like long
13 ago and far away in a distant galaxy, but this matter was
14 last before the Commission a few weeks ago as a matter on
15 the agenda for a stipulation that had been presented in
16 the three dockets by way of resolution and it appeared to
17 the Commission at that time that there was not full
18 support for the stipulation, and so as a result, there
19 were some discussions in the decision meeting and the
20 Commission set this matter for this prehearing conference
21 today.
22 I could indicate to the Commission that
23 significant changes have occurred since last time it was
24 before you, that looking at the notice of parties in the
25 three dockets, with the exception of Brian Jackson who I
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1 haven't talked to and nobody has been able to get ahold
2 of, the stipulation has either been signed, parties have
3 indicated that they will sign or that they support but
4 can't sign and so the sole, I guess, outlier here in the
5 three dockets is Exergy Development Group of Idaho and
6 it's my understanding in talking to Bart Kline, and I'm
7 sure the others, is that we hope that the Commission
8 hasn't taken the stipulation off the table because it's
9 the intent and preference of those that have signed the
10 stipulation and expressed support for it that it be
11 considered by the Commission as a resolution of the wind
12 integration issue in the three dockets.
13 COMMISSIONER REDFORD: Thank you,
14 Mr. Woodbury. I can assure you that the agreements or
15 stipulations have not been taken off the table. We are
16 in a position right now as far as all three cases as to
17 the -- to their cases and based upon the stipulation, we
18 would rule that those cases are fully submitted as to the
19 parties that have executed them. It's my position that
20 once these cases have been fully submitted, it's now our
21 responsibility to review the contracts and approve them
22 or not approve them depending on what the Commission
23 determines, so it leaves one issue and that is the issue
24 of Exergy.
25 Oh, first of all, as to the parties that
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1 have not appeared or participated, I'm not going to do
2 anything further with those cases or their comments
3 because I believe the cases are fully submitted and they
4 had an opportunity to appear and participate and
5 apparently they decided they didn't want to, so as far as
6 the -- and at the last hearing, Mr. Richardson on behalf
7 of Exergy complained and reraised his concerns with
8 regard to the contract and the method in which the rates
9 had been established. I believe, Mr. Richardson, it was
10 your position that we shouldn't just take the rates as
11 presented without further testimony or further
12 proceedings to make further determination as to the
13 make-up of those rates and costs; is that a fair
14 statement?
15 MR. RICHARDSON: Yes, Mr. Chairman.
16 COMMISSIONER REDFORD: Well, in that case,
17 Mr. Richardson, since you were the remaining party that
18 does not agree, we believe it's your duty to move
19 forward, it's your burden of moving forward, and so what
20 we'd like to take up at this time is if you intend to
21 move forward, we'd like a little brief overview of what
22 it is you intend to produce, the witnesses you have,
23 further testimony, experts, consultants, et cetera, if
24 you would do so, please.
25 MR. RICHARDSON: Thank you, Mr. Chairman.
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1 It's our fundamental position, Mr. Chairman, that Idaho
2 Power has no wind integration costs at this time and that
3 to set a rate today based upon an assumption that has
4 proved to be incorrect for the last two-and-a-half years,
5 that is, that Idaho Power will have a lot of new wind
6 resources on line, would be in violation of this
7 Commission's obligation to set rates based upon known and
8 measurable changes or known and measurable issues. Idaho
9 Power's reply to our answer and motion did not address
10 that fundamental legal question.
11 We would intend if we go forward to
12 hearings, our expert witness is sitting next to me,
13 Dr. Reading, he will be testifying as to Idaho Power's
14 lack of wind integration costs and methodologies for
15 identifying future wind integration costs should they
16 actually materialize on Idaho Power's system.
17 COMMISSIONER REDFORD: And there would be
18 a sole witness?
19 MR. RICHARDSON: At this point we have
20 identified Dr. Reading and we are currently actively in
21 the process of identifying additional witnesses. Dr.
22 Reading is a Ph. D. economist and I think is qualified to
23 testify as to Idaho Power's wind integration costs or
24 lack thereof.
25 COMMISSIONER REDFORD: Will you be
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1 cross-examining any of the parties i witnesses or
2 statements?
3 MR. RICHARDSON: I would like the
4 opportuni ty to do so, Mr. Chairman.
5 COMMISSIONER REDFORD: Well, I'm trying to
6 get a handle on the breadth of the hearing.
7 MR. RICHARDSON: Mr. Chairman, one of our
8 fundamental concerns is that the settlement stipulation
9 was, is based solely on Idaho Power i s view of Idaho
10 Power's wind integration costs and it i S our hope that the
11 Commission will ask its Staff to take a critical look at
12 those numbers and present a new look at this issue. It IS
13 a very complex case and for the Commission to rely on one
14 party who has an interest in the outcome of the
15 proceeding without looking at or inviting or actually
16 requiring the Staff and other parties to put on a case
17 showing what their view of Idaho Power's and the other
18 utilities i wind integration costs is falling short of our
19 obligations to set rates that are fair, just and
20 reasonable based upon known data.
21 COMMISSIONER REDFORD:I understand that
22 and we appreciate what you've said and our obligation,
23 but the matter, however, as to the other parties has been
24 submitted on a stipulation which has its foundation in
25 the comments and documents which have been previously
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.1 filed. Having said that, however, we have no problem in
2 granting you full access to the parties for further
3 cross-examination.I am simply trying to get a handle
4 on -- and having said that, I want to remind everyone
5 that while the case has been fully submitted, it has --
6 it's our obligation now to make a determination as to
7 whether we accept those contracts or not and to say that
8 they are -- I can't tell you whether the contracts will
9 be approved as written and as stipulated to and there may
10 be some admonition as to changes we want.
11 I would remind all the parties that this
12 is a long-term contract and I'm sure everyone appreciates.13 that once you i ve signed the contract, notwithstanding
14 what happens in the next 20 years, that you i re bound by
15 that contract. I don't have to tell you that, I i m sure,
16 and 11m sure that the contract basis for all of you has
17 been thoroughly evaluated from a financial standpoint and
18 you believe that the numbers contained therein are fair
19 and for many can be used for the purpose of gaining
20 long-term financing. That i s just Mack Redford on where
21 you are as to your contracts, and I i m sure there is no
22 misunderstanding that the term of the contract is 20
23 years, so we i re at a point right now where I would like
24 to have a little further explanation, if I could,.25 Mr. Richardson, you intend to call -- is it Reedy, Dr.
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.1 Reedy?
2 MR. RICHARDSON: Dr. Reading.
3 COMMISSIONER REDFORD: You're going to
4 have Dr. Reading. Is he going to -- have you fi led
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5 prefiled testimony for Dr. Reading?
6 MR. RICHARDSON: No, Mr. Chairman, there's
7 not been a schedule for prefiling intervenor testimony
8 yet set in this docket.
9 COMMISSIONER REDFORD: Okay. Well, in the
10 event we decide to proceed to allow you to move forward,
11 we will either set that or we may in the alternative to
12 speed up this matter authorize you to present Dr. Reading.13 in person as opposed to prefiling testimony.I think one
14 of the things that needs to be expressed as well which is
15 a concern to the Commission, and I'm sure it i S a concern
16 to everyone, this matter has gone on inordinately long
17 and I i m sure that the Commission has to take some
18 responsibility for the length of this proceeding, but on
19 the other hand, I think some of the parties need to share
20 that and I realize and appreciate that everyone has been
21 struggling with integrated costs and how to determine
22 them and on what basis, so if we proceed further, we
23 would like to have from you a statement, if we could, as
24 to how you intend to present to move forward in this.25 matter, and so far I've heard you're going to present
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1 Dr. Reading and that you mayor may not want to
2 cross-examine the parties and you've asked the Commission
3 Staff to reevaluate their position; is that ~hat you Ire
4 asking?
5 MR. RICHARDSON: That's correct,
6 Mr. Chairman. In terms of the settlement, I do need to
7 make a statement for the record. I learned late
8 yesterday afternoon from Mr. Woodbury that other parties
9 had executed or approved the settlement.I learned this
10 morning from Mr. Woodbury, he gave me a list of the
11 parties who had either signed on or indicated their
12 willingness to accept settlement and the Commission's
13 rules prohibit Staff from engaging in active settlement
14 agreements unless they involve all the parties. I was
15 not involved in any of those discussions and this morning
16 Mr. Woodbury stated that he hasn't had a chance to talk
17 to Mr. Jackson and in his discussions, he mentioned that,
18 my understanding, in talking with Mr. Kline from the
19 Company, so in terms of the new issues, the new landscape
20 in terms of all the other parties having signed the
21 settlement, indeed Exergy was an outlier because we were
22 not involved in those discussions.
23 COMMISSIONER REDFORD: Did you have a
24 question?
25 I do. Mr.COMMISSIONER SMITH:
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.1 Richardson, I would note that on June 27th, 2007, there
2 was a notice of Staff intent to engage in settlement
3 negotiations that did go to you.
4 MR. RICHARDSON: I received that notice,
5 Madam Commissioner, but I have not been involved in any
6 of these other settlement discussions the Staff has
7 apparently been engaging in and I believe the spirit of
8 that rule requires all parties to be apprised when Staff
9 is actively rounding up parties for settlement. We
10 weren't involved in this latest round.
11 COMMISSIONER SMITH: Do you have any
12 knowledge that Staff was actually engaged in those or.13 that they merely called people and were told that they
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14 had concluded they were going to sign?
15 MR. RICHARDSON: Well, the only indication
16 I have is that Mr. Woodbury called me yesterday and was
17 indicating who would sign. This morning in his opening
,18 statement he indicated he was actively calling people and
19 engaged in discussions with the Company. That sounds to
20 me like settlement discussions.
21 COMMISSIONER SMITH: Thank you, Mr.
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22 Chairman.
23 COMMISSIONER REDFORD: Well, I would beg
24 to differ with you just a little bit. I think that1.25 Mr. Woodbury and, of course, Mr. Woodbury can speak for
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1 himself, but the purpose for Mr. Woodbury i s calls was to
2 get the position of the other parties who had not signed
3 on to the stipulation and it was for the purpose of
4 preparing for today' s hearing and I would let
5 Mr. Woodbury speak for himself as to what the content of
6 those discussions were and whether he was engaged in an
7 effort to gain further positions from the Company as to
8 the stipulation or what. Mr. Woodbury, can you let us
9 know?
10 MR. WOODBURY: Thank you, Mr. Chairman. I
11 would indicate that Staff made an attempt earlier on to
12 determine whether there was a possibility for settlement
13 and we came back and we had workshops in which all the
14 parties were provided notice and we participated in those
15 and Staff came back to the Commission indicating that it
16 didn i t appear that a settlement were possible, was
17 possible.It was Mr. Eddie on behalf of Advocates fot
18 the West that continued to pursue settlement in this
19 matter, contacting the parties, preparing the stipulation
20 documents, circulating them to the parties.
21 Staff didn't actually sign. Staff
22 provided a letter of support for the stipulation and so
23 as far as whether we were involved in the crafting of the
24 documents, that was the utilities and Mr. Eddie, and Mr.
25 Eddie can speak as to who other had involvement, but
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1 Staff reviewed those documents. Staff was informed, I
2 guess, by its participation in this process since late
3 2005, felt that the settlement that was reached was very
4 close to where Staff felt we should wind up and so
5 Mr. Richardson feels like he i s been left out. We
6 provided an indication prior to the workshop that Staff
7 facilitated that we were going to engage in settlement
8 negotiations. We haven i t been meeting behind closed
9 doors with the utili ties or anybody else.
10 COMMISSIONER REDFORD: Okay, I think we've
11 worked that issue long enough. Mr. Richardson, I'd like
12 to know in the event that we rule that you can proceed
13 further, we'd like for you to outline and give us an
14 indication of what issues you intend to present as far as
15 you i re opposing the stipulation which contains the
16 outline and the framework for the settlement, what parts
17 of that are you intending to challenge? And the reason I
18 ask you this is just for the simple purpose of trying to
19 narrow, if we can, issues or is it your position that the
20 entire stipulation is bad and you want to challenge it
21 all?
22 MR. RICHARDSON: Well, as I noted earlier,
23 Mr. Chairman, it's our position that we need to set wind
24 integration rates based upon actual wind integration
25 costs. That will be an issue we will look at. We will
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1 look at how to set up a mechanism to identify those costs
2 and incorporate them into some sort of a variable wind
3 integration rate based upon actual wind integration
4 levels and new contracts and perhaps offering that to
5 existing contracts in exchange for concessions, so in
6 essence, Mr. Chairman, we will be looking at the full
7 breadth of what it costs to integrate wind into the
8 system, and I keep going back to the point that today we
9 don i t have wind integration costs and to set rates based
10 upon an assumption that we have eight or nine or 1,000
11 megawatts of wind on the system is fundamentally wrong
12 and we need to address that.
13 COMMISSIONER REDFORD:I understand you,
14 but can I state that notwithstanding the entirety of the
15 settlement, your purpose is to challenge the methodology
16 by which the rates were set and make a determination as
17 to whether there are there is such a thing as
18 integrated costs and trying to determine what the
19 integrated costs are today?
20 MR. RICHARDSON: Both today and going
21 forward, set up a system, a mechanism so that we can have
22 a transparent process for identifying those wind
23 integration costs as Idaho Power actually does bring wind
24 on to its system.
25 COMMISSIONER REDFORD: So what you're
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1 telling me is that as to the other issues that may be
2 brought up in those stipulations, you i re not interested
3 in challenging those, you're simply wanting to challenge
4 those two other issues, the method of determining if
5 there are such -- there is such a thing as integrated
6 costs now and in the future and if there is an integrated
7 cost, what the costs and the elements contain because I'm
8 just trying to narrow things down.
9 MR. RICHARDSON: That i s a good summary,
10 Mr. Chairman. We would also be examining the assumptions
11 and inputs into the Idaho Power wind integration study
12 wi th an idea of checking for the reasonableness of those
13 as well and the other -- we're primarily focused on Idaho
14 Power, but we are parties in all three dockets.
15 COMMISSIONER REDFORD: How long do you
16 think that the proceeding that you're envisioning would
17 last? I mean, what i s the length?
18 MR. RICHARDSON: Dr. Reading could be
19 prepared to file prefiled testimony in four weeks,
20 Mr. Chairman.
21 COMMISSIONER REDFORD: And as far as the
22 hearing is concerned, how long do you think the hearing
23 will take?
24 MR. RICHARDSON: It depends upon,
25 Mr. Chairman, if other parties decide that they would
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1 like to a take a critical look at Idaho Power's filing or.2 the other two utili ties' filings as well. I don i t think
3 a hearing would take very long.
4 COMMISSIONER REDFORD: Well, in terms of
5 setting the hearing date and its duration, I i m going to
6 ask everyone else what they think as to the time of the
7 hearing. Can you give me an estimate in days or half
8 days or hours or whatever?
9 MR. RICHARDSON: I would estimate two
10 days, Mr. Chairman, maybe two-and-a-half days.
11 COMMISSIONER REDFORD: Mr. Woodbury, do
12 you have any position on how long a hearing would take in
13 the event we do have one? And I want to ask you, if we.14 do have a hearing, would you be calling witnesses?
15 MR. WOODBURY: And I i m unclear as to
16 whether or not the Commission would be requiring prefiled
17 testimony by all parties in support of the stipulation.
18 If that is the case, Staff can file testimony within two
19 weeks and I don i t anticipate any cross of other parties,
20 and I think that we could get through Mr. Reading, cross
21 of him, wi thin maybe an hour, so I don't anticipate that
22 the hearing would go two days. I anticipate no more than
23 a day. It depends upon the length of Mr. Richardson IS
24 cross of other parties.
,25 COMMISSIONER REDFORD: If we do allow.
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1 wri tten comments, of course, the parties have an
2 opportuni ty to file reply comments and we would in
3 order to shorten this, if there were four weeks to file
4 comments, I would suggest that probably we i d shorten the
5 reply time to try to get this matter set.
6 Mr. Ikemoto, do you have any idea what you
7 would be intending and how long you think the proceeding
8 would last?
9 MR. IKEMOTO: I think my concern,
10 Mr. Chairman, is that there's another case out there
11 modifying the calculation of avoided costs that has an
12 intersection with the issues in this case and to the
13 extent we can address those issues, we would want to
14 testify, yes.
15 COMMISSIONER REDFORD: Well, I can tell
16 you that I think that that case was the Idaho Power case
17 that discusses avoided costs.
18 MR. IKEMOTO: Yes, 07-15.
19 COMMISSIONER REDFORD: Okay. Well, that
20 case has been fully submitted and is ready for a
21 decision, so I don't think that would be raised at the
22 next hearing; however, if there are tangential issues
23 that come up as a result of the other hearing that might
24 impact that, certainly, we would not be adverse to
25 hearing it, so would you concur that it would take less
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1 than two days or more?
2 MR. IKEMOTO: Yes.
3 COMMISSIONER KEMPTON: Mr. Chairman, I'd
4 like to ask a couple of questions, if I could, that might
5 focus on some of the answers to the questions you're
6 asking. Mr. Richardson, Idaho Power submitted their
7 report addendum that is a part of the record. Did you
8 participate in the work sessions from which that addendum
9 was developed?
10 MR. RICHARDSON: Yes, I did,
11 Mr. Commissioner, and if I could make amends here, if
12 Dr. Reading is the only witness, it's going to take less
13 than a day.
14 COMMISSIONER REDFORD: But you're the one
15 that controls that in terms of whether you want to
16 cross-examine some of the other parties ' witnesses.
17 MR. RICHARDSON: If the other parties are
18 just filing testimony saying that they think the
19 stipulation is a good thing, there's not going to be a
20 lot of cross-examination.
21 COMMISSIONER REDFORD: Okay.
22 COMMISSIONER KEMPTON: Mr. Chairman?
23 COMMISSIONER REDFORD: Yes.
24 COMMISSIONER KEMPTON: May I continue? In
25 those work sessions, were your points overruled by the
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1 workings of the group itself?
2 MR. RICHARDSON: The workshops were in the
3 nature of settlement negotiations and there was a robust
4 exchange of ideas, Mr. Commissioner, so in terms of were
5 my ideas overruled, my ideas certainly did not prevail
6 because here I am opposing the settlement, but I would
7 say that the Company was very cooperative and provided
8 information in the workshops and were productive in terms
9 of vetting some of the issues in Idaho Power's filing.
10 COMMISSIONER KEMPTON: Mr. Richardson,
11 when you asked Staff, what I would like to avoid in this
12 is having everybody go back to ground zero and start
13 developing cost estimates once again.I think there's
14 been a tremendous amount of work, not only with what
15 Idaho Power has done but in the region in general and
16 those have all addressed integration costs to include
17 integration costs for Bonneville Power Administration, so
18 that doesn't suggest that I am arguing against your
19 position, I am simply stating a fact.
20 It would be helpful if we confined your
21 areas of concern to the information that has been
22 developed as a result of these, of the work group in this
23 addendum report that Idaho Power gave, because if we can
24 focus where your concern is on specific information that
25 was brought into that, unless you want to provide the
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1 reason for rej ecting the information that was considered
2 in that group, I think on that basis we can probably
3 shorten this issue of who has to develop what kind of
4 information to present to the Commission.
5 I think a lot of that has been developed.
6 If you rej ect that information, if you're specifically
7 opposed to it, I think you should present the evidence on
8 which you base that conclusion. I don't see how we can
9 go back and regenerate a whole new cost data sheet and
10 come back and argue the positions from ground zero.
11 MR. RICHARDSON: Mr. Commissioner, we will
12 not start from ground zero. We will use the documents
13 that Idaho Power has presented as the launching point for
14 our presentation.
15 COMMISSIONER KEMPTON: So you're not
16 asking Staff to develop new information, you're willing
17 to use what's on the record now?
18 MR. RICHARDSON: We'll use what's on the
19 record now and either supplement it or cri tici ze it or
20 offer alternatives.
21 COMMISSIONER SMITH: Mr. Richardson, it
22 seems to me that there's a threshold question here that
23 maybe could save us a lot of trouble and that is your
24 posi tion is that the Commission is somehow legally
25 foreclosed from setting any kind of rate in the absence
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1 of wind penetration, do I have that right?
2 MR. RI CHARDSON : You do, Madam
3 Commissioner.
4 COMMISSIONER SMITH: Okay; so it seems to
5 me that what the Commission could do is just hit that
6 question straight on and give you an answer, whether we
7 agree with your position, in which case then we go to
8 hearing or whether we disagree with your position, in
9 which case you could go to the Supreme Court, so I guess
10 my question is what information do you think we need to
11 squarely face that question and provide an answer?
12 MR. RICHARDSON: I think you have the
13 information you need to fairly squarely face that
14 question in my answer to the joint settlement and motion
15 to accept answer out of time in which I set out the legal
16 argument relative to the ability of the Commission to set
17 rates based upon an assumed wind integration of several
18 mul tiple hundreds of megawatts when they do not exist.
19 COMMISSIONER SMITH: And this is the
20 posi tion that you stated was not responded to in the
21 filing of Idaho Power?
22 MR. RICHARDSON: That's correct.
23 COMMISSIONER SMITH: Mr. Kline, do you
24 feel a need to respond to Mr. Richardson's filing on that
25 issue?
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1 MR. KLINE: Well, to some extent,
2 Madam Commissioner, it is a little bit of a moving
3 target. I know that at the decision meeting
4 Mr. Richardson indicated that Idaho Power currently has
5 12 megawatts of wind operating on its system. That
6 number has increased substantially even since that early
7 November decision meeting and more wind is coming on all
8 the time. The Company has more than 300 megawatts of
9 contracts for wind resources, so to some extent I think
10 that we could augment the record to make sure that the
11 Commissioners understand what is coming down the pike and
12 whether or not Idaho Power will have wind integration
13 costs based on that increased amount of wind that is
14 coming on.
15 COMMISSIONER SMITH: Well, I have some
16 sympathy with Mr. Richardson's position that a contract
17 isn't something on line and occasionally in the past
18 contracts have not resulted in actual kilowatts being
19 delivered to Idaho Power's system.
20 MR. KLINE: Yes, Commissioner Smith. Of
21 the 200 megawatts of contracts, approximately 150 of them
22 belong to Mr. Richardson's client, so at this point he
23 certainly hasn't told us that he's not going to develop
24 those proj ects. We have every reason to believe that
25 they will move forward, but it seems like a very
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1 difficul t position for them to be saying that we
2 shouldn't rely on those resources coming on line.
3 COMMISSIONER SMITH: Well, I would
4 appreciate suggestions from either Mr. Richardson,
5 Mr. Kline or anyone else on how to get this updated
6 information. Could it be in the nature of a stipulation
7 of facts by the parties as to what's on line as of the
8 date of filing, what's contracted as of the date of
9 filing so that the Commission could have the updated
10 facts in front of us to, I think, answer what I see as a
11 preliminary question of whether we have the impediment
12 argued by Mr. Richardson or whether we don't?
13 MR. KLINE: I certainly could put together
14 a stipulation of the wind, the status of the various wind
15 contracts and wind resources on our system and the
16 on-line dates, all of that kind of information. I can't
17 imagine that Mr. Richardson would obj ect to the facts
18 that we would present, but we could get you a stipulation
19 tomorrow.
20 COMMISSIONER SMITH: Well, my whole point
21 of this exercise would be that if the Commission
22 disagrees with Mr. Richardson's position, there's no
23 point to go forward and subj ect everyone to a hearing.
24 If we agree, however, then it's a different ball game and
25 maybe we ought to answer that question first before
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1 people go to a lot of work.
2 COMMISSIONER REDFORD: Mr. Kline, you
3 stated that you had 12 megawatts on line?
4 MR. KLINE: Actually, it's considerably
5 more than that now.
6 COMMISSIONER REDFORD: How much more?
7 MR. KLINE: On line right now about 120
8 well, on line right now or by the end of this month, on
9 line about 120 megawatts, another 80 megawatts under
10 construction right now and another 200 that are
11 contracted and for which we have no reason to believe
12 they won't come on line when they say they're going to.
13 A number of those contracts got caught up in the
14 integration, transmission issue down in the Twin Falls
15 area. Now that this Commission has resolved that issue,
16 they seem to be moving forward.
17 COMMISSIONER REDFORD: Have you forecasted
18 into the future how many megawatts you will have in, say,
19 five years? 10 years? 20 years?
20 MR. KLINE: We have not, Commissioner
21 Redford. A lot of that depends on the economics of the
22 wind development industry. I think there are certainly
23 lots of indication that there will be more wind developed
24 in Idaho, but at this point I don't think we have any
25 further proj ections of what it would be. Mark Stokes is
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1 here with me and Mark is in our planning department at
2 Idaho Power and do you have any better information?
3 MR. STOKES: Just for information, in our
4 integrated resource planning process, we do not forecast
5 what will come to us through PURPA because it is an
6 unknown to us, so we don't attempt to forecast that.
7 COMMISSIONER REDFORD: What was the amount
8 of power on your system from wind farms that was used to
9 develop your integrated costs?
10 MR. STOKES: We looked at several
11 pepetration levels. In the initial study, we looked at
12 300 megawatts, 600 megawatts, 900 megawatts and 1,200
13 megawatts.
14 COMMISSIONER REDFORD: And I believe in
15 your report you said your system could not handle 1,200
16 megawatts?
17 MR. STOKES: Yes, that's correct. In the
18 resul ts of the initial study, the modeling that we did
19 went haywire when we got up to that high of a penetration
20 level, so in the continuation of work that we did to
21 prepare the report addendum, we dropped the 1, 200
22 megawatt level from consideration.
23 COMMISSIONER REDFORD: So your integrated
24 cost was based upon how many megawatts?
25 MR. STOKES: The cost figure that we
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1 presented is based on an interpolated result between 300
2 megawatts and 600 megawatts that were a result of the
3 study and it was interpolated based on the amount of wind
4 that we expect to have on line based on what's already on
5 line and that we have signed contracts for.
6 COMMISSIONER REDFORD: And your system has
7 the capacity to take 600 megawatts?
8 MR. STOKES: We believe that 600 may be
9 approaching the upper limit of what we we believe the
10 upper capability of our current system to be somewhere
11 between the 600 and 900 megawatt level.
12 COMMISSIONER REDFORD: Just so I'm
13 straight, you said you interpolated and interpolate can
14 be a variety of different things. I'm not going to
15 consider interpolation because I don't know how you did
16 that, but it's safe to say that your creation of the
17 information was based upon somewhere between 300 and 600
18 megawatts coming on to your system for which you have
19 capaci ty; is that correct?
20 MR. STOKES: Yes. Just to clarify, it's
21 generally understood that the higher the penetration
22 level goes the higher the integration cost is.
23 COMMISSIONER REDFORD: And have you
24 calculated the cost to replace the power in the event the
25 variable wind generators or that the wind generators
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1 would not be able to supply?
2 MR. STOKES: I f the proj ects were not to
3 be constructed?
4 COMMISSIONER REDFORD: No, if they
5 promised ten megawatts and only gave you eight, then your
6 integrated cost would be based then on what you'd have to
7 pay to buy that power or generate that power; right?
8 MR. STOKES: Mr. Chairman, the integration
9 cost comes in the form of the amount of regulating
10 reserves that we have to hold on our system to account
11 for the flexibility in that wind.
12 COMMISSIONER REDFORD: You're talking
13 about hydro?
14 MR. STOKES: Yes, we modeled our Hells
15 Canyon complex to come up with the results.
16 COMMISSIONER REDFORD: And was your
17 regulating cost based upon the cost you would lose on
18 those hydro projects if you had to supplement the wind
19 generation?
20 MR. STOKES: Yes, exactly.
21 COMMISSIONER REDFORD: I'm getting far
22 afield and I shouldn't do that. I think to wind this up,
23 the Commission is going to take all these considerations
24 together and we're going to make a decision very soon:
25 one, as to whether this case is fully submitted,
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1 notwithstanding Mr. Richardson's position, or we will
2 after we've heard all the people, unless anyone has
3 anything else to present, we've heard that the hearing,
4 if there is one, is going to be based upon the testimony
5 of one witness and possibly the cross-examination of some
6 other witnesses and there will be prefiled testimony by
7 Dr. Reading and in the event we have a hearing, everyone
8 else will have an opportunity to have a shortened period
9 for reply comments.
10 It seems to me that your reply comments
11 probably are mostly contained in your prefiled statements
12 or the testimony and also your comments, so I think -- I
13 can't believe that we would have more than a day of this
14 hearing, but, of course, what we will do is reserve the
15 right to, if it goes over to the next day, we'll hold
16 that day open. I would -~ as far as the narrowing of the
17 issues, we will make a ruling as to what the issues are
18 if we decide to allow this to go further based upon what
19 you've said, Mr. Richardson. I want to make sure that
20 you understand what it is I'm saying, and I'm sure you
21 do, about it's your duty to move forward.
22 MR. RICHARDSON: I understand,
23 Mr. Chairman.
24
25
COMMISSIONER REDFORD: Okay. I don't mean
to lecture you on that, and for others in the room, you
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10
1 would have the opportunity after Mr. Richardson presents
2 his case then to cross-examine Mr. Reading or present
3 further evidence by way of rebuttal. I don't think that
4 there is anything else to go -- yes, Mr. Miller?
5 MR. MILLER: Mr. Chairman, I would like
6 the opportunity just to make a brief statement for the
7 record, but I don't want to interrupt the flow of your
8 discussion, so just before the hearing is concluded, I
.
9 would like just an opportunity for a brief statement.
COMMISSIONER REDFORD: Thank you, and
11 you'll have the opportunity to do that, so that we can
12 kind of sum up, I just want to tell you where we're
13
14
going. We're going to make first a threshold
determination as to whether or not the cases are fully
15 submi tted without regard to Mr. Richardson's client's
16 position, and in that case, the matter would be
17 determined on what's been presented to the Commission to
18 date.
19 Second, we've established that
20 Mr. Richardson will have the burden of moving forward,
21 which for everyone that means he has the obligation to
22 present his evidence first. We've established that the
23 hearing will probably take, if we have a hearing, it will
24 be one day with the possibility of going into another day
25 and we will also issue in our Order based upon what we've
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10
1 heard today what the narrow issues are, and Ilm very
2 serious, the Commission is very serious, in making sure
3 that if we do have a hearing it will be tightly defined
4 as to what's going on, so when you're preparing, whatever
5 you're preparing, make sure you stick to that prehearing
6 Order which we'll put out and we'll try to get that
7 information out to you right away by way of Order.
8 I don't have anything further right now.
9 Mr. Miller?
MR. MILLER: I just wanted to briefly make
11 a statement for the record which is this: that in
12 evaluating a complex settlement such as this, parties
13
14
have to take into account a variety of considerations and
John Deere has done that and based on that believes that
15 the overall end result is reasonable, and as you noted,
16 it takes an important step in restarting the PURPA
17 program in Idaho. Having said that the overall result is
18 reasonable should not, though, be interpreted necessarily
19 as an agreement or that the methods used to arrive at the
20 overall result are reasonable.
21 Specifically, it should not be deemed to
22 consti tute an acknowledgment by John Deere of the
23 validity or invalidity of any particular method, theory
24 or principle of regulation or cost recovery, nor should
25 it be deemed that the principles or theories arrived at
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1 in the stipulation are appropriate for resolving issues
2 in any other further proceedings in the future, so in
3 short, John Deere just wants to make clear that it's
4 supporting the overall result, but is not expressing an
5 opinion on the validity of the methods used to arrive at
6 that result and the position of Intermountain Wind in the
7 PacifiCorp case would be the same.
8 COMMISSIONER REDFORD: Thank you very
9 much, Mr. Miller, for that kind of fuzzy statement, warm
10 fuzzy statement.
11 MR. MILLER: The best we could do.
12 MR. IKEMOTO: Mr. Chairman?
13 COMMISSIONER REDFORD: Yes, Mr. Ikemoto.
14 MR. IKEMOTO: I just would like to express
15 that my concern is that we're really dealing with a
16 single issue here, how do you account for uncertainty
17 wi thin the framework of PURPA and we have here that the
18 issue has been bifurcated and all these proceedings deal
19 wi th how do we account for uncertainty on the cost side,
20 the operational side, and we're coming to a conclusion of
21 whether or not to include the cost of integration, which
22 is the cost of uncertainty, on the cost side. The other
23 proceeding, 07-15, deals with whether we should also
24 include the cost of uncertainty on the benefit side in
25 terms of capturing it wi thin avoided costs, and I'm very
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1 uncomfortable that we have this overriding issue split up
2 into pieces and you're saying that 07-15 is fully
3 submitted and yet -- I guess I don't know how to express
4 that.I'm uncomfortable that this thing got divided into
5 two pieces.I don't think it belongs in two pieces.
6 COMMISSIONER REDFORD: Thank you,
7 Mr. Ikemoto, and rest assured that the Commission has
8 taken that into consideration and we certainly want to
9 make sure that there is -- regardless, the result is that
10 one issue of avoided costs and the other issue of
11 integrated costs don't somehow get wrapped into each
12 other.I think we see this as in the previous case as
13 one on avoided costs which are historically set in a
14 certain way and then integrated costs which is a separate
15 item for which I like to say that integrated costs are
16 the costs for balancing the system in the event that
17 there's a shortfall in wind production, so we have been
18 grappling with this as well and I think we're cogni zant
19 of everything that's going on, but I understand and I
20 hear what you're saying.
21 Is there anyone else that would like to
22 comment before we adjourn? Yes, sir, Mr. Eddie.
23 MR. EDDIE: Mr. Chairman, on behalf of
24 Renewable Northwest Proj ect and Northwest Energy
25 Coalition, I just wanted to make a couple of brief
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1 statements. This issue is a tremendously intellectually
2 interesting issue and one that's very difficult to stop
3 talking about. Lots of things come up. Lots of things
4 get wrapped into the discussion. We had extensive
5 workshops. We worked very hard in those workshops and do
6 a settlement to get where we are, and part of the purpose
7 for my clients in joining the settlement and promoting
8 the settlement was to end the discussion, to try to move
9 forward to the planning process, the integrated resource
10 planning process, and to avoid a hearing and it's a
11 little bit disconcerting to anticipate a hearing where
12 I'm not sure what exactly will be discussed or promoted
13
14
from Mr. Richardson's client.
Part of the reason that we're a little bit
15 alarmed by that is that we are now deeply engaged in the
16 Bonneville Power Administration's wind integration rate
17 case which is ongoing. It's likely to be a protracted
18 and complicated case as well and it will be a burden for
19 my clients and our expert to unravel from that case and
20 come back into this case to perhaps rebut testimony from
21 Exergy or others and so I would like to join in
22 supporting Commissioner Smith's concept of addressing
23 this threshold issue.Is there a cost today? We
24 certainly believe that it is reasonable to say that there
25 is a cost today based on the wind that's on the system
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1 and the wind that's under Commission-approved contracts
2 and address that discreet issue and move forward from
3 there. If the Commission agrees with my client, with the
4 Company, I think a hearing would be unnecessary. Thank
5 you.
6 COMMISSIONER REDFORD: Thank you. Any
7 other comment? Yes, sir.
8 MR. RAYHILL: Mr. Chairman, my name is
9 Rich Rayhill. I'm with Ridgeline Energy.
10 COMMISSIONER REDFORD: Why don i t you move
11 up here and use this microphone.
12 MR. RAYHILL: My name is Rich Rayhill.
13 I'm with Ridgeline Energy and I would just like the
14 record to reflect that I showed up. I apologize for
15 being late.
16 COMMISSIONER REDFORD: Thank you. We
17 accept your apology. Yes, sir.
18 MR. ANDREA: Mr. Chair, Commission, my
19 name is Mike Andrea. I'm with Avista. I apologize for
20 having walked in late, our flights were a little bit
21 delayed this morning. I've got Mr. Kalich with me as
22 well and I wanted to make sure that you were aware that
23 we are here this morning and available to answer any
24 questions you might have for Avista. I also wanted to
25 voice my support for the settlements that we've entered
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35 COLLOQUY
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1 into. As Mr. Eddie has expressed and others have
2 expressed, a great deal of work has gone into those and
3 we think they are a good result in this case. Thank
4 you.
5 COMMISSIONER REDFORD: Thank you. Of
6 course, you're aware that your tardiness will be severely
7 punished.
8 MR. ANDREA: Excuse me?
9 COMMISSIONER REDFORD: Your tardiness will
10 be severely punished.
11 MR. ANDREA: I would expect nothing less.
12 Thank you, sir.
13 MR. JACKSON: My name is Brian Jackson.
14 I'm with Renaissance Engineering & Design.I also wanted
15 to apologize for being late. I just had one comment to
16 add and it's in conjunction with Mr. Ikemoto's comment.
17 I'm concerned from a ratepayer standpoint.I do
18 consul ting work for farmers and ranchers and small wind
19 developers that are in this category. As we get down to
20 the last detail of an integration cost issue, which is
21 certainly not inappropriate, we are losing a value part
22 of this equation for the ratepayers that wind brings, a
23 risk reduction in fuel prices and fuel costs and other
24 sources of energy that is completely not being accounted
25 for.I don't know how that could be accounted for to
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1 society or to the ratepayers, but as we get down to the
2 last detail on the integration itself and we get down to
3 the last detail on the avoided cost, there's really a
4 third component to society that I believe is really a
5 benefit to the ratepayers from a risk reduction
6 standpoint.
7 The wind is a natural resource that blows
8 across the state. It's there whether we capture it or
9 not and when Idaho is importing 80 percent of its fuel to
10 this state from outside its borders, some element of
11 capturing that energy wi thin the borders without any fuel
12 risk or other elements of deli very, if it can't be
13 accounted for, it should at least be acknowledged, I
14 guess.
15 COMMISSIONER REDFORD: Thank you. Without
16 putting words in your mouth, I think what you're saying
17 is that, notwithstanding the agreements, that one element
18 has not been addressed and that is the value of renewable
19 resources as opposed to non-renewable resources, so
20 you're not opposing the stipulation, you're just
21 reminding us that there should be something taken into
22 account; is that right?
23 MR. JACKSON: Yes, sir. My greatest
24 concern truly from an Idahoan standpoint and
25 multi-generational farming background is we're getting
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1 down to the last detail of accountability on what this
2 wind really is and if we end up with a result that
3 ul timately makes these proj ects not buildable because the
4 financial cost is too great, it's okay for the industry,
5 they'll move on to other states. Other states will get
6 these projects and I think that the risk to the Idaho
7 ratepayers of not developing these resources wi thin our
8 state for Idaho ratepayers is very high.I think the
9 Hells Canyon complex was one of the greatest benefits to
10 Idaho ever developed and it was capturing a natural
11 resource in the state for essentially Idaho ratepayers as
12 well as the others that are benefiting from that low cost
13 hydro resource.
14 I believe that wind today is the same
15 opportunity that we are facing and if we disregard it and
16 ultimately create a result that doesn't -- I mean,
17 everybody knows the costs are increasing dramatically for
18 every single energy resource, including wind.If we
19 don't develop that and it's developed for other
20 ratepayers in other states or it just simply doesn't get
21 developed in Idaho while it does get developed in other
22 states, I believe that is a loss to Idahoans.
23 COMMISSIONER REDFORD: Well, thank you
24 very much and I can share your concern.I believe that
25 is one of the reasons for the PURPA Act and this
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1 Commission is cognizant of exactly what it is you've said
2 and our decisions will surely include that type of
3 consideration.
4 I had one question of Mr. Kline.
5 Mr. Kline, in your last comment you offered to host a
6 workshop sometime in March. If we approve all these
7 agreements, what's the purpose for a workshop?
8 MR. KLINE: I think the offer to host the
9 workshop, Mr. Chairman, was in conjunction with the 07-15
10 case.I think we've workshopped this one just about as
11 much as we can workshop it.
12 COMMISSIONER REDFORD: So your workshop
13 would not include -- it would include avoided cost
14 issues, not integrated cost issues?
15 MR. KLINE: That's correct. We've built
16 into the settlement stipulation an ongoing series of
17 meetings, both informal and formal, to look at
18 integration costs on an ongoing basis, so we already have
19 that process built into the settlement stipulation.
20 COMMISSIONER REDFORD: Well, I think welve
21 worked this pretty much to death, and like Lewis Carroll
22 said, you begin at the beginning and end at the end and I
23 think we're at least approaching the end and the
24 Commission will take these matters into consideration and
25 on the abbreviated hearing that mayor may not take
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39 COLLOQUY
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1 place. We share your concerns that for all of us, we
2 have to take some role in not getting the wind issues
3 resolved in a timely manner. I can express from the
4 Commission and I believe for others that we want the wind
5 integration. We want the use of renewable resources.
6 Presently the utilities provide to us on a voluntary
7 basis their renewable resource portfolio and we're very
8 mindful of that portfolio and whether or not we continue
9 it on a voluntary basis, I don't know.
10 We've established, the state has
11 established, an Energy Commission. The legislature has
12 developed an energy report through a committee in the
13 legislature and so we're taking all of these things into
14 consideration to the extent that we didn't have any
15 authori ty and we're constantly reviewing our role in
16 energy issues, being mindful that there are some things
17 we can do and a lot of things we can't do, so having said
18 that, if there's nothing to come before this hearing, we
19 will stand adjourned or recessed until if there is
20 another hearing and I want to thank all of you for
21 coming. I know we've all -- everyone has done a
22 tremendous amount of work. Being new on the Commission,
23 you've made it through your comments and through the
24 Staff i s comments able for me, one of the newcomers, to
25 understand this very complex issue of integrated costs
CSB REPORTING
Wilder, Idaho 83676
40 COLLOQUY
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1 and other costs and so I thank you for that, so hearing
2 nothing else, why, we will stand adj ourned.
3 (The Hearing adj ourned at 10: 05 a. m. )
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CSB REPORTING
Wilder, Idaho 83676
41 COLLOQUY
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1 AUTHENTICATION
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4 This is to certify that the foregoing
5 prehearing conference held in the matter of Idaho Power
6 Company' s petition to increase the published rate
7 elegibili ty cap for wind-powered small power production
8 facilities, et cetera, commencing at 9:00 a.m., on
9 Tuesday, December 11, 2007, at the Commission Hearing
10 Room, 472 West Washington, Boise, Idaho, is a true and
11 correct transcript of said proceedings and the original
12 thereof for the file of the Commission.
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(llD~ =5Å~~~~~
CONSTANCE S. BUCY
Certified Shorthand Reporter #1 7
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CSB REPORTING
Wilder, Idaho 83676
42 COLLOQUY