20150311IPC to IIPA 1-11.pdf

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DONOVAN E. WALKER
Lead Counsel
March 11,2015
VIA HAND DELIVERY
Jean D. Jewell, Secretary
ldaho Public Utilities Commission
472 West Washington Street
Boise, ldaho 83702
Re: Case No. IPC-E-15-01
Modify Terms and Conditions of Prospective PURPA Energy Sales
Agreements - ldaho Power Company's Response to the ldaho lrrigation
Pumpers Association, lnc.'s First Data Request
Dear Ms. Jewell:
Enclosed for filing in the above matter please find an original and three (3) copies
of ldaho Power Company's Response to the ldaho Inigation Pumpers Association, lnc.'s
First Data Request.
Also enclosed are four (4) copies of a confidential disk containing information
responsive to the data request. Please handle the confidential information in
accordance with the Protective Agreement executed in this matter.
Donovan E. Walker
DEW:csb
Enclosures
1221 W. ldaho 5t. (83702)
PO. Box 70
Boise, lD 83707
DONOVAN E. WALKER (lSB No. 5921)
ldaho Power Company
1221Wesl Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
dwalker@idahopower. com
Attorney for ldaho Power Company
IN THE MATTER OF IDAHO POWER
COMPANY'S PETITION TO MODIFY
TERMS AND CONDITIONS OF
PROSPECTIVE PURPA ENERGY
SALES AGREEMENTS
l:
I iTiLll i ::.:i il[l;,ii,,
CASE NO. |PC-E-15-01
IDAHO POWER COMPANY'S
RESPONSE TO THE IDAHO
IRRIGATION PUMPERS
ASSOCIATION, INC.'S FIRST
DATA REQUEST
i'i"i 38
BEFORE THE IDAHO PUBL]C UTILITIES COMMISSION
COMES NOW, ldaho Power Company ("ldaho Powe/' or "Compotry"), and in
response to the ldaho lrrigation Pumpers Association, lnc.'s First Data Request to ldaho
Power Company dated February 18,2015, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO
IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST - 1
REQUEST NO. 1: PIease supply a copy of all of the Company responses to
interrogatories/requested made by the Staff or any other party in this case.
RESPONSE TO REQUEST NO. 1: Al! of ldaho Powe/s responses to other
parties' discovery requests in this matter have previously been provided to counse! for
the ldaho lnigation Pumpers Association, lnc.
The response to this Request is sponsored by Christa Bearry, Legal
Administrative Assistant, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO
IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST - 2
REQUEST NO. 2: Assuming that the Mid-C historic prices on Exhibit 10 of Mr.
Allphin's testimony are derived from each day's "lntercontinental Exchange ("lCE") daily
firm Mid-C prices", please supply the raw data that was used develop the historic figures
portrayed on that exhibit. Also supply any formulas or other data used to develop the
historical fi gures portrayed.
RESPONSE TO REQUEST NO. 2: The information requested was provided in
the Company's response to J. R. Simplot Company's Request for Production Nos. 10
and 12 and the associated attachments.
The response to this Request is sponsored by Randy Allphin, Energy Contracts
Coordinator Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO
IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST.3
REQUEST NO. 3: Please provide an explanation regarding the appropriateness
of using "lntercontinental Exchange ("lCE') daily finn Mid-C prices" data in the
Company's Schedule 86 (Cogeneration and Small Power Production Non-Firm Energy):
a. Are the "lntercontinental Exchange (.lCE') daily firm Mid-C prices" based
on hourly data?
b. For the purposes of Mr. Allphin's Exhibit 10, was the "lntercontinental
Exchange ("lCE') daily firm Mid-C prices" data simply arithmetically averaged for the
purpose of the exhibit?
c. Are the "lntercontinental Exchange (.lCE') dai[ firm Mid-C prices"
calculated "after the fact", or are they use as "day ahead" or some other fonruard pricing
mechanism?
d. Why has the Company chosen to use the "lntercontinenta! Exchange
('lCE') daily firm Mid-C prices" as a proxy for costs on the ldaho Power system?
e. How accurate do the "lntercontinental Exchange ('lCE') daily firm Mid-C
prices" reflect the prices that the Company faces in the open market or of the cost of its
own generation?
RESPONSE TO REQUEST NO. 3: Idaho Public Utilities Commission
("Commission") Order No. 33053 issued on June 10, 2014, describes the approved
methodology of using the ICE index to establish the Company's Schedule 86 energy
prices.
a. Yes. Please see the Company's response to the ldaho lrrigation Pumpers
Association lnc.'s (.llPA") Request No. 2 for specific details.
b. Please see the Company's response to llPA's Request No. 2.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO
IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST - 4
c. PIease see the Company's response to llPA's Request No. 2.
d. The ICE index values are commonly used by the electrical industry for
valuing electrical energy market values. ln addition, the ldaho Power Schedule 86
referenced in this Request uses the ICE index, which has been reviewed and approved
by the Commission for other Public Utility Regulatory Policies Act of 1978 ('PURPA')
related energy pricing.
e. The ICE index provides a common starting point for all parties to use in
evaluating market energy values. The price of any purchase or sale is a mutually
agreed to price by both parties, which may or may not be identical to the ICE or any
other index value. Over time the ICE index values have been seen as a reasonable
estimation of the market value of energy. ln the process of evaluating energy sales or
purchases, ldaho Power considers the cost of its own generation as well as many other
factors (i.e., environmental compliance, regulations, system reliability, etc.).
The response to this Request is sponsored by Randy Allphin, Energy Contracts
Coordinator Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO
IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST - 5
REQUEST NO. 4: lf the Mid-C historic prices on Exhibit 10 of Mr. Allphin's
testimony are not "lntercontinental Exchange ("lCE') daily firm Mid-C prices", please
indicate what index was used, and supply the raw data that was used develop the
historic figures portrayed on that exhibit. Also supply any formulas or other data used to
develop the historical figures portrayed.
RESPONSE TO REQUEST NO. 4: The Mid-C historic prices are from the ICE
index. Please see the Company's response to IIPA's Request No 2.
The response to this Request is sponsored by Randy Allphin, Energy Contracts
Coordinator Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO
IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST - 6
REQUEST NO. 5: If Mr. Allphin's Exhibit 10 was not based upon
"lntercontinental Exchange (.lCE') daily firm Mid-C prices" data, please provide the
similar answers to Request 3 above for the index that was used.
RESPONSE TO REQUEST NO. 5: Please see the Company's response to
IIPA's Request No.4.
The response to this Request is sponsored by Randy Allphin, Energy Contracts
Coordinator Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO
IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST. T
REQUEST NO. 6: Assuming that there are times when the Company's access
to Mid-C is limited, when would those times generally occur?
RESPONSE TO REQUEST NO. 6: ldaho Power's access to Mid-C is limited
when transmission outages or derates occur on the Northwest to ldaho transmission or
transmission impacting the usability of those paths. These outages or derates can
occur during any season, but are most limiting during periods of high demand from west
to east, which typically occurs in the June, July, and August months.
The response to this Request is sponsored by Tessia Park, Director Load
Serving Operations, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO
IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST - 8
REQUEST NO. 7: Assuming that there are times when the Company's access
to Mid-C is limited, why would Mid-C be a good index of the prices that the Company
faces in the open market or of the cost of its own generation.
RESPONSE TO REQUEST NO. 7: As physical access to the Mid-C trading hub
may be limited at times due to transmission congestion, the Mid-C index prices are stil!
a commonly used basis for energy transactions with other utilities on other transmission
paths because the Mid-C markets are typically the least-cost market for purchases.
The response to this Request is sponsored by Randy Allphin, Energy Contracts
Coordinator Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO
IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST - 9
REQUEST NO. 8: How will access to Mid-C be impacted by the Boardman to
Hemmingway Transmission line?
RESPONSE TO REQUEST NO. 8: ldaho Power's capacity allocation for the
Boardman to Hemingway line is given in Table 6.2 on page 77 of the 2013 lntegrated
Resource Plan ("lRP"). As provided in the referenced table, ldaho Powe/s west to east
capacity wil! be 200 megawatts ("MW") in the winter and 500 MW in the summer and
east to west capacity will be 85 MW.
The response to this Request is sponsored by Phil DeVol, Resource Planning
Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO
IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST - 1O
REQUEST NO. 9: On pages 4-5 of the Application, there is listed eight items
that "warrant additional examination and possible revision". For each of the eight items
listed, please provide any summary documents developed by or for the Company that
describe why the Company believes that each of these eight items may be helpful and
thus, "warrant additional examination and possible revision".
RESPONSE TO REQUEST NO. 9: The selected quote within this Request of
"wanant additional examination and possible revision" does not accurately reflect the
statement contained within pages 4 and 5 of the Petition. The key word "could" has
been excluded from this quote. Additionally, ldaho Power does not state "may be
helpful and thus" at any time in this paragraph. The omission and addition of this
language significantly changes the statement of this paragraph. The paragraph from
which this quote was extracted states in its entirety:
Several issues related to the Commission's implementation
of PURPA in the state of ldaho could wanant additional
examination and possible revision. These items could
include: (1) further modification to the existing avoided cost
pricing methodologies to more appropriately reflect need and
resource sufficiency in the price; (2) implementation of new
avoided cost pricing methodologies which move to a market-
based or competitively bid-based avoided cost mechanism,
such as that utilized in Washington; (3) exemption from
PURPA under S 210, part M; (4) Commission pursuit of a
waiver from the requirements of S 210, subpart C, for ldaho
Power pursuant to 18 C.F.R. 5292.402; (5) refinement of the
Commission's 907ol11Oo/o definition of firmness to require
firm scheduled deliveries for entitlement to rates established
at the time of contracting or legally enforceable obligation, as
opposed to rates determined at the time of delivery, similar
to the implementation in Texas; (6) further refinement of the
eligibility for rates established at the time of contracting or
legally enforceable obligation by requiring QFs to be within
90 days of delivering power before the utility is obligated to
the price, again similar to the implementation in Texas; (7)
modification of contractual term limitations; and (8)
]DAHO POWER COMPANY'S RESPONSE TO THE IDAHO
IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST - 11
establishment of caps, or MW targets, upon the amount of
new or repowered projects a utility is required to procure
over a given period of time, similar to those in place in
California. While the Company believes each of these
issues may warant further examination, at this time, ldaho
Power's specific request with this Petition is that the
Commission modify the terms and conditions of prospective
purchases from PURPA QFs by reducing the cunent 2O-year
contract term for ldaho Power energy sales agreements to a
maximum of two years, and direct any other relief it deems
appropriate and in the public interest.
Petition, pp.4-5.
ldaho Powe/s Petition, as quoted above, states that its request in this case is
limited to addressing the issue of the appropriate contract term. ldaho Powe/s request
was further restricted to only those projects that exceed the published rate eligibility cap.
Petition, p. 1. Each of the items listed by the Company and quoted above are items that
the Company believes are deficiencies in the implementation of PURPA in the state of
ldaho that cause harm to ldaho Power customers.
Any documents that exist evaluating these listed items were prepared by, or
under the direction and control, of legal counsel and are thus attomey-work product and
attorney-cl ient privileged communications.
The response to this Request is sponsored by Randy AIlphin, Energy Contracts
Coordinator Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO
IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST. 12
REQUEST NO. 10: Please provide from January 2011 through the most recent
data available, hourly data similar to that provided in response to lnigator Request 8 in
Case IPC-E-11-08.
RESPONSE TO REQUEST NO. 10.a-v: Please see confidential Attachments 1
through 4 provided on the confidential CD. Included on the confidential CD are
individual workbooks for each of the years 2011 through 2014, including monthly tabs
for each year. The specific Request No. 10 responses (1O.a-v) are identified by the red
column headings as noted below.
a. For total system input, use column Q.
b. For system input from Company-owned generation (stating hydro, coal,
gas, and other generation separately), use column P.
c. For system input from firm purchases, stating each purchase separately
by source and type of purchase (LF, lF, SF, etc.), and
d. The cost of each firm purchase listed in "c" above, use column O. The
cost will show in column V.
e. For system input from non-firm and/or economy purchases, stating each
purchase separately, and
t. The cost of each non-firm and/or economy purchase listed in "e" above,
use column N. The cost will show in column V.
g. For system input from exchanges into the system, stating each exchange
separately, use column M.
h. For system input from unit purchases, use column L.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO
IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST.l3
i. For other system inputs, stating for each "othe/' input the type and the
source of the input, use column K.
j. Jurisdictional (ldaho and Oregon) sales data is unavailable on an hourly
basis.
k. For system Iosses, use column J.
l. Please see response below (prepared by others).
m. For long-term firm wholesale sales (LF), stating each one separately, use
column l.
n. For intermediate-term firm wholesale sales (lF), stating each one
separately, use column H.
o. For short-term wholesale sales (SF), stating each one separately, use
column G.
p. For unit sales, wholesale (LU) or otherwise, stated separately, use column
F.
q. For non-firm and/or economy wholesale sales (OS), stated separately,
and
r. The revenue collected each hour from each non-firm and/or economy
purchase listed in "p" above, use column E.
s. For exchanges out of the system, stating each exchange separately, use
column D.
t. For other system outputs, stating for each "othe/' output the type and
recipient of the output, use column C.
u. For inadvertent power flows into or out of the system, use column B.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO
IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST - 14
v. For the power available (at input level) to supply retail load once
wholesale, exchange, wheeling, and inadvertent have been subtracted, use column A.
The confidential CD will only be provided to those parties that have executed the
Protective Agreement in this matter.
The response to this Request was prepared by Nancy Grzadzieleski, Operations
Accountant II, ldaho Power Company, under the direction of Randy Allphin, Energy
Contracts Coordinator Leader, ldaho Power Company.
RESPONSE TO REQUEST NO. 10.1 and w-v:
I. The requested data for requirements wholesale sales (RO) does not exist.
The wholesale customer sales for the requested period are 0.
w. Hourly losses assigned to each retail jurisdiction are not available. Loss
factors for peak demand and energy by voltage for each jurisdiction are contained in the
"RefTables" tab of the Excel workbooks (Attachments 5 through 8) provided on the
confidential CD. These are system loss factors by voltage level and are not calculated
on an hourly basis.
x. Hourly losses assigned to wholesale sales are not available. Loss factors
for peak demand and energy by voltage are contained in the "Reffables" tab of the
Excelworkbooks (Attachments 5 through 8) provided on the confidentia! CD. These are
system loss factors by voltage level and are not calculated on an hourly basis.
y. Hourly retai! load by jurisdiction is not available. The Excel workbooks
(Attachments 5 through 8) provided on the CD contain the monthly energy and
coincident demand information for 2011-2014 with and without losses.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO
IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST - 15
The confidential CD will only be provided to those parties that have executed the
Protective Agreement in this matter.
The response to this Request was prepared by Mary Arnold, Load Analytics and
Research Leader, ldaho Power Company, under the direction of Randy A!!phin, Energy
Contracts Coordinator Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO
IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST.l6
REQUEST NO. 11: For each PURPA contract where the price was set (or to be
set) using an IRP Methodology, please provide the following:
a. The date that the QF originally submitted a request for contract approval;
b. The date that the contract was approved by the Commission;
The Commission case number;
The nameplate capacity;
e. The type of project (wind, solar, cogeneration, etc.); and
f. The contracted price for the purchase of the output of the facility.
RESPONSE TO REQUEST NO. 11: Information for "set (or to be set)" is
requested; however, items a through f request information in regards to signed and
Commission-approved contracts and much of the requested information does not yet
exist for contracts that prices are "to be set." Therefore, ldaho Power has provided
information for only projects that include IRP methodology pricing, have been signed by
both parties, and submitted to the Commission requesting it to elther accept or reject
the contract.
a. The qualifying facility does not submit a request for contract approva! with
the Commission as suggested in this Request. lnstead, after both parties have
executed a contract, ldaho Power prepares an application and files this with the
Commission requesting it to either accept or reject the contract. The table below lists
projects submitted to the Commission to date.
Proiect Name Date ldaho Power Application Submitted
c.
d.
American Falls Solar ll, LLC
American Falls Solar, LLC
Boise City Solar, LLC
Clark Solar 1, LLC
Clark Solar 2,LlC
Clark Solar 3, LLC
1012012014
1012012014
07t25t2014
10t17t2014
'10117120'14
10t1712014
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO
IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST - 17
Clark Solar 4, LLC
Grand View PV Solar Two
Mountain Home Solar, LLC
Murphy Flat Power, LLC
Orchard Ranch Solar, LLC
Pocatello Solar 1, LLC
Simco Solar, LLC
Tuana Springs Expansion
Rockland Wind Farm
High Mesa Wind Project
Proiect Name Aporoval Date Case Number
Nameplate Type of
Gapacitv (MW) Proiect
10t1712014
07t25t2014
1011712014
10t20t2014
1012012014
10t17t2014
10t2012014
08/1 1/2009
09/08/2010
1112212011
b-e. The table below lists projects approved by the Commission to date.
Commission
American Falls Solar ll, LLC
American Falls Solar, LLC
Boise City Solar, LLC
Clark Solar 1, LLC
Clark Solar 2, LLC
Clark Solar 3, LLC
Clark Solar 4, LLC
Grand View PV Solar Two
Mountain Home Solar, LLC
Murphy Flat Power, LLC
Orchard Ranch Solar, LLC
Pocatello Solar 1, LLC
Simco Solar, LLC
Tuana Springs Expansion
Rockland Wind Farm
High Mesa Wind Project
f. All of the contracts
12t29t2014
12t29t2014
11t14t2014
011o112015
011o1t2015
01to1t2015
01t01t2015
11114t2014
011o112015
12t29t2014
1212912014
01/08/2015
1212912014
10/05/2009
11t24t2010
o2t17t2012
tPc-E-14-35
tPc-E-14-34
rPC-E-14-20
tPc-E-14-28
lPc-E-14-29
lPc-E-14-30
tPc-E-14-31
tPc-E-14-19
tPc-E.,t4-26
tPc-E-14-32
tPc-E-14-36
tPc-E-14-27
tPc-E-14-33
rPc-E-09-24
tPc-E-10-24
tPC-E-11-26
20.00
20.00
40.00
71.00
20.00
30.00
20.00
80.00
20.00
20.00
20.00
20.00
20.00
35.70
80.00
40.00
Solar
Solar
Solar
Solar
Solar
Solar
Solar
Solar
Solar
Solar
Solar
Solar
Solar
Wind
Wind
Wind
listed above contain a fixed schedule of non-levelized
prices; therefore, there are different prices for each year and, in some cases, for each
month and for heavy load and light load hours. Provided below are estimated levelized
prices that are calculated based upon the non-levelized schedule of prices contained in
each of the above-listed contracts. These levelized prices are not specifically stated in
the contracts but are commonly used to provide general information.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO
IRRIGATION PUMPERS ASSOCIATION, !NC.'S FIRST DATA REQUEST - 18
Proiect Name Galculated Levelized Rate ($/MWh)
American Falls Solar ll, LLC
American Falls Solar, LLC
Boise City Solar, LLC
Clark Solar 1, LLC
Clark Solar 2,LLC
Clark Solar 3, LLC
Clark Solar 4, LLC
Grand View PV Solar Two
Mountain Home Solar, LLC
Murphy Flat Power, LLC
Orchard Ranch Solar, LLC
Pocatello Solar 1, LLC
Simco Solar, LLC
Tuana Springs Expansion *
Rockland Wind Farm
High Mesa Wind Project $56.43
*Note: The Tuana Springs Expansion was a negotiated combination of an existing contract with a
new contract for expansion of the existing project. ln these negotiations, the value of the
existing contract was maintained and the expansion was valued at an |RP-based value
and the two prices were then blended together to create the monthly energy prices. The
value listed is the levelized value of this negotiated blended value.
The response to this Request is sponsored by Randy Allphin, Energy Contracts
Coordinator Leader, ldaho Power Company.
DATED at Boise, ldaho, this 11fr day of 2015.
DONOVAN E. WALKER
Attomey for ldaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO
IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST - 19
$62.66
$63.61
$72.15
$s9.97
$61.03
$60.67
$60.87
$73.41
$61.43
$63.80
$62.21
$61.33
$63.94
$75.53
$71.29
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 11h day of March 2015 | served a true and
correct copy of IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO
IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST upon the
following named parties by the method indicated below, and addressed to the following:
Commission Staff
Donald L. Howell, ll
Daphne Huang
Deputy Attorneys General
ldaho Public Utilities Commission
472 West Washington (83702)
P.O. Box 83720
Boise, ldaho 83720-007 4
J. R. Simplot Company and Glearuvater
Paper Corporation
Peter J. Richardson
Gregory M. Adams
RICHARDSON ADAMS, PLLC
515 North 27th Street (83702)
P.O. Box 7218
Boise, ldaho 83707
Dr. Don Reading
6070 Hill Road
Boise, ldaho 83703
Cleanvate r Paper Corporation
ELECTRONIC MA,IL ONLY
Carol Haugen
Clearwater Paper Corporation
Intermountain Energy Partners, LLC
Dean J. Miller
McDEVITT & MILLER, LLP
420 West Bannock Street (83702)
P.O. Box 2564
Boise, ldaho 83701
Hand Delivered
U.S. Mail
Overnight Mail
FAX
Email [e-mail]
daohne. huang@puc. idaho.qov
Hand Delivered
U.S. Mai!
Ovemight Mai!
FAXX Email [e-mail]
oreq@richard sonadams. com
Hand Delivered
U.S. Mail
Overnight Mail
FAXX Email [e-mail]
_Hand Delivered
U.S. Mail
Overnight Mail
FAX
Email [e-mail]
Hand Delivered
U.S. Mail
Overnight Mail
FAX
Email [e-mail]
heather@mcdevitt-m i I ler. com
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO
IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST - 20
Leif Elgethun, PE, LEED AP
Intermountain Energy Partners, LLC
P.O. Box 7354
Boise, ldaho 83707
ldaho Gonservation League and Sierra Club
Benjamin J. Otto
ldaho Conservation League
710 North 6th Street (83702)
P.O. Box 844
Boise, ldaho 83701
Sierra Club
Matt Vespa
Sierra Club
85 Second Street, Second Floor
San Francisco, California 94105
Snake River Alliance
Kelsey Jae Nunez
Snake River Alliance
223 North 6h Street, Suite 317
P.O. Box 1731
Boise, ldaho 83701
PacifiCorp d/b/a Rocky Mountain Power
Daniel E. Solander
Yvonne R. Hogle
Rocky Mountain Power
201 South Main Street, Suite 24OO
Salt Lake City, Utah 84111
Ted Weston
Rocky Mountain Power
201 South Main Street, Suite 2300
Salt Lake City, Utah 84111
ELECTRONIC MAIL ONLY
Data Request Response Center
PacifiCorp
825 NE Multnomah, Suite 2000
Portland, Oregon 97232
Hand Delivered
U.S. Mail
Overnight Mail
FAX
Email [e-mail]
Hand Delivered
U.S. Mail
Overnight Mail
FAXX Email [e-mail]
_Hand Detivered
U.S. Mail
Overnight Mail
FAX
Email [e-mail]
Hand Delivered
U.S. Mail
Overnight Mail
FAXX Email [e-mail]
km i I ler@sna kerive ra I I ia nce.o ro
Hand Delivered
U.S. Mail
Overnight Mail
FAXX Email [e-mail]
wonne. hoo [e-mail]
Hand Delivered
U.S. Mail
,Ovemight Mail_FAXX Email [e-mail]
_Hand Delivered
U.S. Mail
Overnight Mail
FAXX Email [e-mail]
x
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO
IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST - 21
Twin Falls Canal Company, North Side
Canal Company, and American Falls
Reservoir District No. 2
C. Tom Arkoosh
ARKOOSH LAW OFFICES
802 West Bannock Street, Suite 900 (83702)
P.O. Box 2900
Boise, ldaho 83701
Avista Gorporation
Michae! G. Andrea
Avista Corporation
1411 East Mission Avenue, MSC-23
Spokane, Washington 99202
Clint Kalich
Avista Corporation
1411 East Mission Avenue, MSC-7
S pokane, Washingto n 99202
ldaho lrrigation Pumpers Association, lnc.
Eric L. Olsen
RACINE, OLSON, NYE, BUDGE & BAILEY
CHARTERED
201 East Center
P.O. Box 1391
Pocatello, ldaho 83204-1391
Anthony Yankel
29814 Lake Road
Bay Village, Ohio 44140
Renewable Energy Goalition
Ronald L. Williams
WILLIAMS BRADBURY, P.C.
1015 West Hays Street
Boise, ldaho 83702
!rion Sanger
SANGER LAW, P.C.
1117 SW 53'd Avenue
Portland, Oregon 97215
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erin.ceci [e-mail]
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IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO
IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST - 22
The Amalgamated Sugar Company
Scott Dale Blickenstaff
The Amalgamated Sugar Company, LLC
1951 South Satum Way, Suite 100
Boise, ldaho 83702
Micron Technology, Inc.
Richard E. Malmgren
Micron Technology, lnc.
800 South FederalWay
Boise, ldaho 83716
Frederick J. Schmidt
Pamela S. Howland
HOLLAND & HART, LLP
377 South Nevada Street
Carson City, Nevada 89701
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phowland @ ho I land hart.com
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO
IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST - 23