20110119Avista Reply Comments.pdf

January 18,2011
c Utilities Commission
ashington Street
, ID 93702
Email: jean.jewel1ß)puc.idaho.gov
Reply Comments of A vista Corporation
IPUC Docket No. GNR-E-I0-04
Dear Ms. Jewell:
~~~'V'STßl
Corp.
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Please find enclosed for filing an original and seven copies of the Reply Comments of
A vista Corporation in the above-referenced docket. Please let me know if you have any
questions regarding this fiing.
Enclosures
cc: Service List
Sincerely,-~.
Michael G. Andrea
Senior Counsel
MICHAL G. ANREA (ISB No. 8308)
A vista Corporation
1411 E. Mission Ave., MSC-23
Spokae, W A 99202
Telephone: [phone]
michaeL andrea (g avistacorp.com
cc: V
lOB JAN 19 AM it: 59
BEFORE TH IDAHO PUBLIC UTITS COMMSSION
IN TH MA ITR OF THE JOIN PETITION )
OF IDAHO POWER COMPAN, AVISTA )
CORPORATION, AN ROCKY MOUNAI )
POWER TO ADDRESS AVOIDED COST )
ISSUES AN JOIN MOTION TO ADJUST )
TH PUBLISHED AVOIDED COST RATE )ELIGffILITY CAP. )
)
)
CASE NO. GNR-E-l0-
REPLY COMMNTS OF A VISTA
CORPORATION
Pursuant to the Notice issued by the Idao Public Utilities Commssion ("Commssion")
on December 3, 2010 in Order No. 32131 ("Notice"), Avista Corporation ("Avista") respectflly
submits the following reply comments in support of reducing the eligibilty cap for the published
avoided cost rate.
I. Background
On November 5,2010, Avista Corpration along with Idao Power Company and
PacifiCorp, dba Rocky Mountan Power, (collectively, the "Utilities") filed a Joint Petition
requesting the Commssion to initiate an investigation into varous avoided cost issues regardig
PURPA Qualifying Facilties ("QFs") under the Public Utility Regulatory Policies Act of 1978
("PUR A"). Among the issues rased in the Joint Petition, the Utilities reuested that the
Commssion issue an order adjusting the published avoided cost rate eligibilty cap for QFs from
10 average megawatt ("aM") to 100 kilowatt ("kW") effective immedately.
Page - 1 REPLY COMMENTS OF AVISTA CORPORATION
On December 3, 2010, the Commission issued the Notice in which it, among other things,
set a modified procedure comment schedule with which to develop a record for its decision
regarding the Joint Petition and Motion's request to lower the published avoided cost rate
eligibility cap. Order No. 32131, Case No. GNR-E-1O-04. In the Notice, the Commission
bifurcated this proceeding into two phases. In the first phase, the Commission wil address only
the Utilities' request to reduce the eligibility cap. Initial comments for this first phase were due
on December 22,2010. Reply comments are due on Januar 19,2011.
II. Reply Comments
The Federal Energy Regulatory Commission ("FERC") requires states to have a standard
rate offering for projects with a design capacity of i 00 kW or less.! States may require standard
rates for purchases from QFs that have a design capacity greater than 100 kW.2 In the recent
past, the Commission has set the eligibility cap for the published avoided cost rates at 10 aMW.
QFs larger than 10 aMW are eligible for an avoided cost rate that is determined through
negotiations with the utility using the utility's "IRP Methodology" as the basis for determining
the applicable avoided cost rate.
3
As Comiission Staff notes in its comments, "one of the primary justifications for
limiting eligibilty for published rates to 10 aMW has been to recognize that developers of small
QFs are less likely to be large, well-funded organizations, capable of sophisticated contract
negotiations.,,4 It is not merely developers of small QFs that are taking advantage of published
avoided cost rates.s Rather, developers of large wind projects are splitting those projects into
1 Staff Comments at 3; 18 C.F.R. § 292.304(c)(l).218 C.F.R. § 292.304(c)(2).
3 Staff Comments at 3-4.
4 Staff Comments at 4.
5 Staff Comments at 4 (stating: "It has become quite common for large wind projects to be strctured as multiple,
separate QFs, each 10 aMW in size, but collectively 60, 80 or 120 MW in size. In fact, nearly all new wind
Page - 2 REPLY COMMENTS OF AVISTA CORPORATION
separte smaller QFs in order to tae advantage of the published avoided cost rate (ths pratice
is someties referred to herein as "disaggregation,,).6 Ths practice raises several concerns.
Those concerns include, among others, as Commssion Sta recognzed: (1) an arcial
mismatch between the method used to establish a project's avoided cost rates and the collective
size of the project; (2) ineffcient turbine layouts that do not maximize the value of Idaho's wind
resource; and (3) utilities are forced to acquire generation from large QFs at stadard rates
without regard to the utility's need for new generation.7
Ultimately, forcing utilities to pay standard published avoided cost rates to larger QFs
can, as Staf recognized, have adverse implications, including higher rates for the utilities'
customers.8 A vista has QF reuests in Idaho for 450 MW of development, 350 MW of which is
for wind QFs.9 The addition of such resources to Avista's system is substatial relative to
A vista's estimated Idaho peak load of 617 MW, and minimum load of 232 MW. A vista has a
diect interest in ths proceeding.1O Accordingly, Avista urges the Commssion to adopt Stas
recommendation to lower the published avoided cost rate eligibilty cap from 10 aM to 100
kW effective December 14,2010, while the Commssion furter investigates ths issue. In
addition to the intenm recommendation to reduce the eligibilty cap from 10 aM to 100 kW
while the Commssion conducts its investigation of ths issue, Staf provides four long-term
alternatives to address the disaggrgation problem. Avista, as discussed more fully below,
supports Stas first proposed alternative oflowenng the eligibilty cap indefinitely as the best
solution to the disaggregation issue. Although Sta recommends that the eligibilty cap only be
contrcts submittd for Commission approval in recent years ar collections of two or more adjacent i 0 aM
rrojects, each with common ownership and developers.").Staf Comments at 4.7 Sta Comments at 4-5.
8 See Sta Comments at 5.
9 Appendix A lists Avista's PURA requests.
10 See also Sta Comments at i i -12.
Page - 3 REPLY COMMENTS OF AVISTA CORPORATION
lowered for wind resources, Avista respectfully requests that, at a minimum, the eligibilty cap
be lowered for wind and solar resources.
A. The Eligibilty Cap for Published A voided Cost Rate Should be Lowere
Indermitely.
A vista support Stafs alternative solution to the Utilities' recommendation of lowenng
the eligibilty cap indefinitely. Ths approach is preferable to the other alternatives beause it
wil allow trly small QFs to tae advantage of published avoided cost rates while at the same
time ensunng that the rates paid to larger QFs more accurately reflect the utility's actual avoided
costs.
Sta suggests that the IRP Methodology used to determne the avoided cost rate for
developers above the eligibilty cap reuires the use of complicated and propneta production
cost models and that developers might be suspicious of the model results and would be unable to
replicate or venfy the model output.
11 A vista is sensitive to these concerns. A vista does not,
however, agree that the use of the IRP Methodology for projects greater than 100 kW wil be
excessively burdensome or complex. The IR Methodology is presently well founded and
developed in a public process. The method comes from a biennal process that has been, in the
case of Avista, in use since 1989. Avista also encourages Commssion Sta to parcipate in its
11 A vista notes that the Nortwest and Intermountan Power Prducers Coalition ("NIPC") argues that lowenng the
eligibilty cap would frustrate the purse of PUR A. In support of its argument, NIPC cites a U.S. Supreme
Court cas, FERC v. Mississippi, 456 U.S. 742 (1982), that NIPC reads to state that "one of the fundamenta
reasons for the mandatory purchase reuirement is that the Utilities have been found to be reluctat to purchase
electrcity from 'nontritional facilties.'" NIPC Comments at 7. The reduction of the eligibilty cap wil not
change the mandatory purchase reuirement under PURA; lowenng the eligibilty cap only bear on the question
of the size limit for QFs that ar able to avail themselves to published avoided cost rates it does not have any
relevancy to the issue of whether a utility has an obligation under PURA to purchase the output from a QF.
Therefore, NIPC's argument that reucing the eligibilty cap will frstrte PURA is without ment. Morever,
FERC's regulations expressly reuire stadar published rates only for Qualifying Facilties with a design capacity
of 100 kW or less. 18 C.F.R. § 292.304(c)(l).
Page - 4 REPLY COMMENTS OF A VISTA CORPORATION
process to the extent that Sta and/or developers thnk that such parcipation may be helpful in
assunng developers that Avista is faily implementing its IR MethodologyY
Commssion Sta reommends that the Commssion lower the eligibilty cap only for
wind resources.13 As stated above, A vista respetflly reuests that, at a minium, the
Commssion consider lowering the eligibilty cap for wind and solar resources. As explaied
furter in Appendi B to these comments, there is signficant day-to-day varabilty associated
with solar resources. There is also substatial varabilty for solar resources across the on-pe
hours. Solar provides a limited capacity contnbution in the peak winter months, and a less than
15% nameplate contnbution in the summer months. Finally, as Sta notes, developers of solar
resources may have the abilty to configure their projects to circumvent the intent of the
published avoided cost rate eligibilty cap.
14
A vista encourages the Commssion to adopt the alternative of limiting the eligibilty cap
for published avoided cost rates to 100 kW for, at a minium, all wind and solar QFs on an
indefinite basis. Ths alternative provides the best solution to the disaggregation issue. To the
extent that the Commssion does not apply the 100 kW eligibilty cap to resoures other than
wind, A vista reuests that the Commssion make clear that it wil revisit that issue in the futue
in the event that it is shown that developers of such other resources ar disaggregating projects to
avail themselves to published avoided cost rates.
12 A vista does not anticipate that the Commission Sta will need to dedicate substantial time or resources to ths
proess. Rather, Avista believes that Sta parcipation in the first one or two contrcts for which the IR pross is
use afr the eligibilty cap is lowered may help developers to feel comfortble with that pross.
13 Staf Comments at 12.14 Sta Comments at 6.
Page - 5 REPLY COMMENTS OF AVISTA CORPORATION
B. A vista Support Stas Alternative to Reintroduce an A voided Cost
Computation Methodology that Takes the Utility's Need for New Generation
into Account.
A vista supports the concept of reintroducing utility need into the QF pncing equation.
Pnor to 2002, the Commssion acknowledged that, when a utility is surplus, new QF generation
wil only serve to furter its surplus, and that the surplus has only the value inherent in the
wholesale marketplace. IS The fully-embeded cost of generation reflected in tOdaY'S published
avoided cost rates are too high-especially if the utility is in a surplus penod. As Sta
recognzes, it could be successfully argued that power offered for sale to a utility dunng its
surlus penod has no value.
16
To ensure that the load and resource positions are clear when each PUR A contrct is
negotiated, A vista proposes that the load and resource position published in its latest integrted
resource plan ("IR") be used. A vista proposes to keep the load and resource position constant
for the two-year penod that an IRP is current. Avista believes that it is especially importt for
utility need be reintroduced into the QF pncing equation, if the Commssion does not lower the
eligibilty cap indefintely.
C. A vista Do Not Support Implementing a Larger Separation Rule.
A vista does not support Stas alternative of implementing a larger separtion rule to
address the disaggregation issue.17 Staf explains that a separtion requirement that is greater
than one-mile might conflct with federal law. IS' Although, as explained below, Avista believes
that the Commssion can require separation greater than one-mile as a condition to eligibilty to
15 See Sta Comments at 8-9.
16 Sta Comments at 9.
17 Sta Comments at 9-10.18 Sta Comments at 10.
Page - 6 REPLY COMMENTS OF A VISTA CORPORATION
published avoided cost rates for QFs greater than 100 kW, Avista is concerned that such a
separation rule wil be diffcult to implement and enforce.
First, it is Avista's view that a five-mile (or other separation requirment exceedng the
one-mile FERC limit) separation rule applied to QFs greater than 100 kW would not confct
with federal law. FERC's one-mile separation requirement requires that QFs be separated by at
least one mile.19 The FERC separation reuirement does not speak to the cntena that the
Commssion may adopt for eligibilty for published avoided cost rates for QFs that are greater
than 100 kW.2° In that regard, FERC's only requirement for stadard published rates is that they
be available to QFs that are 100 kW or less.21 States can, however, authonze published avoided
cost rates for QFs larger than 100 kW.22 Under such circumstaces, the FERC regulation does
not prohibit states from adopting additional eligibilty requirements-such as separation
requirements greater than one-mile.23 Therefore, the Commssion could madate for purpses of
published avoided cost rate eligibilty a separation of, for example, five miles or more for QFs
larger than 100 kW. So long as projects of 100 kW or less remain eligible for published avoided
cost rates without regard to the increased separtion requirement, such a rule would not confict
with federal law.
Although it is legally possible to increase the separation requirement for those QFs
greater than 100 kW that want to avail themselves to published avoided cost rates, Avista does
not prefer ths approach. A vista is concerned that developers may find simple ways to
circumvent any such increased separation requirement by creating the appeaance of different
1918 C.F.R. § 292.204(a).
20 Compare 18 C.F.R. § 292.304(c) with 18 C.F.R. § 292.204(a).
21 18 c.F.R. § 292.304(c)(I).
22 18 C.F.R. § 292.304(c)(2).
23 See 18 C.F.R § 292.304(c)(2).
Page - 7 REPLY COMMENTS OF AVISTA CORPORATION
ownership or control between projects. For example, where there is a large project it could be
split up into multiple projects with one or more landowners owning the first project, another
owning the second project, etcetera. A developer could also develop one large project, split that
project into multiple projects, and hand "ownership" of the pieces of the broken-up project to the
landowners or other business entities. The developer could then charge large development fees
to transfer most of the value of the entie development to the developer without retaning
"ownership." In either of these examples the separation rule could be rendered effectively moot.
For the reasons discussed above, Avista does not generally support an increased
separation rule. However, if the Commssion determnes that the eligibilty cap for published
avoided cost rates should be greater than the 100 kW cap requested by the Utilities, Avista
requests that the Commssion consider a separation rule of five miles or more in conjunction with
any eligibilty cap greater than 100 kW.
D. Avista Do Not Prefer, But Would Support A New Methodology for Large
QF Project Rates.
A vista would support an effort to develop a new methodology for large QF project rates.
However, Avista does not prefer ths alternative.
Sta references the recent "Wind SAR" proceedng as an alternative to establish avoided
cost rates for QF. 24 In that proceeding, the effort was abandoned in favor of ths proceeng
before an alternative Surrogate A voided Cost Resource (SAR) methodology was reached.
Expenence indicates that any attempt to develop a resource-specific or other new SAR
methodology wil be difficult and wil require substatial investment of time and resources by all
pares. Even if a new SAR methodology can be developed, it is not clear that any such
methodology wil solve the disaggregation issue. For these reasons, A vista is not convinced that
24 Staff Comments at 1 1.
Page - 8 REPLY COMMENTS OF A VISTA CORPORATION
pursuing a new methodology, such as multiple SARs, is the best solution to the disaggregation
problem. However, to the extent that the Commission does not lower the eligibility cap
indefinitely such that large developers canot continue to disaggregate to avail themselves to
published avoided cost rates, A vista believes resource~specific SARs might be the only other
workable solution.
III. Conclusion
A vista appreciates the opportunity to submit these reply comments on the issue of
PURPA published rate eligibility. Avista supports Commission Staffs recommendation to
reduce the eligibility cap for published avoided cost rates to 100 kW, effective December 14,
2010, while the Commission conducts its investigation. Avista also supports Staffs first
alternative long~term solution-to reduce the eligibility cap to 100 kW indefinitely-as the
simplest and best approach to solve the disaggregation issue. A vista respectfully requests that
the Commission reduce the published avoided cost rate eligibility cap to 100 kW. Although
Staff recommends lowering the eligibility cap only for wind QFs, A vista requests that, at a
minimum, the Commission lower the cap for both wind and solar QFs.
DATED this 18th day of Januar 2011.
n~
Michael G. Andrea
Attorney for A vista Corporation
Page - 9 REPLY COMMENTS OF A VISTA CORPORATION
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APPENDIXB
Appendix B
Analysis of Solar Contributions to Utilty Needs
Introduction
Many advocates of solar point to its on-peak generation profile and conclude that this bias warrants a
higher price than wind and lessens the reliabilty impacts of the resource. There is evidence that, unlike
wind, solar does on average provide generation during periods where utilty loads are higher than for
wind. However, this fact does not eliminate the operational and valuation concerns associated with
solar. Absent some storage medium, which is unlikely for QF projects which wil be comprised of
photovoltaic panels, solar does not greatly reduce the capacity needs of the utilty. Yet solar appears to
have many of the operational problems associated with wind resources; it is an unpredictable variable
resource. Much of this unpredictabilty comes from various weather variables that affect output,
including cloud-cover, precipitation, temperature and dust. Avista presents the following analyses in
support of its view that eligibilty for published avoided cost rates for solar, like wind, QFs should be
limited to 100 kW.
Solar Experiences Significant Day-to-Day Variabilty
Avista in 2009 installed 3.5 kW-DC photovoltaic solar facilty on the top of its corporate headquarters.
Chart 1 below details the hourly summer profile of Avista's solar facility in 2010. Chart 2 illustrates the
same for a winter profile, defined as January 2010. As can be seen in both cases, the variabilty across
the on-peak hours is substantiaL. In the case of winter, the average capacity factor is 7.2% for solar, yet
variabilty during on-peak hours is between zero and 87%. In the winter, output for solar can be zero
even during solats peak output hours (12:oop-4:oop).
Chart 1
Avista Solar Facilty Daily Summer Output Shape (August 2010)
100.0%
90.0%Day of Month
80.0%
-1-4-7-10-13--16-19-22-"m~_*25
-'"-28
31
-2-5-8-11-14-17-20-23-26
"29
-- Average
-3-6-9-12-15-18-21-24
",.27
'""'--30
70.0%
60.0%
50.0%
40.0%
21.3% Average capait Factor
30.0%
20.0%
10.0%
0.0% .. ,-.~ .. ~ -, -+ ~ .. i-1"-v-+
; ~,;, ~ ~" ~;; ~; ~ ~; ~ ~ ~; ~ ~ ~
In the summer the average solar capacity factor of Avista's facility was 21.3%, with a range in the on-
peak hours of between zero and 86%. During the summer when average production is the highest,
output during the resource's highest production hours (1:00p-5:00p) ranged greatly, between 11.6% and
87.4% in 2010, versus an average of 61.9%.
Page 2
Chart 2
1--Avista Solar Facilty Daily Winter Output Shape (January 2010)
100.0%
90.0% ____~ Day of Montb__________~____________-1 -2 -3-4 -5 -680.0% ------ -7 -8 -9-10 -11 -12-13 -14 -1570.0% -16 -17 -18-19 -20 -21-22 -23 -2460.0% - --25 -26 ------27--28-29 ---30
31 -- Average
50.0%
40.0%
7.2% Average Capacity Factor
30.0%
20.0%
10.0%
0.0% .. ,-+o. 'I -, -.~ ~-i-~.. ~
G', G' ~ ~" ~;~ #; ~ ~ p ~ ~ ~;~ ~ ~
,.~-~ ,-~ .."1-..,--
Solar is Not Correlated to System Needs (Peak Demand)
Solar output is not consistent or "reliable." As a result, Avista's other resources wil have to stand ready
to backup the solar resource. In 2010 the correlation of Avista's solar facility to Avista's daily peak
demand was -33%, indicating no correlation. Chart 3 below provides the peak daily output profile of
Avista's solar test facility during 2010.
Page 3
Chart 3
í Avista Solar Facilty Maximum Daily Capacity Factor (2010)100
90
80
70%
60
5O
20
:10 0 0 0 0 0 ~0..............2 0 2 2 2 2 0 2NN-'ù ëi 'r 'ù 'r 'ù ëi..-..N ..N ..N ~..-';'r 'r ;;;;..
MeAveSt DeMí_____ Max
95% PerterCo
40
30
0 0 0 0 0 0 0 0 0 0 0 0 ~~0 ~0 ~............................0 2 2 0 0 2 0 2 2 0 0 0 2 2 0 2 2 ~N N N N N N N N;;S ';~Õi 'r 'ù 'è ;;r:'è ~Õi ~'ù ëi ;;N N ..r:..'"..N ..N 'è ';..'r ..~'ù 'ù r:r:Õi Õi ëi ëi ..'è ..';..'r......
Although Chart 3 provides a good ilustration of the variabilty of solar, it does not explain the capacity
contribution ofthe resource. Solar, while generating on-peak energy, does not greatly reduce a utiltys
need to construct capacity resources. To ilustrate this, Avista analyzed its peak winter and summer load
days during 2010. In each case it was assumed that a solar facility of the same size as the peak demand
hour was constructed (otherwise the impact would be diffcult to visualize). As Chart 4 shows, during
the summer months the solar facility would reduce the peak need of the utilty by only 13.7% of the
nameplate of alternating current rating of the resource.
Page 4
Chart 4
I 1,8
I
1,60
1,40
1,200
..1,00t:ftilft:i 80E
60
40
200
Impact of 1,556 MW Solar Resource on Summer Peak Demand (2010)
~-~--'_.._'._.'._---'------'._-'-----~'---
_Summer load Peak absent solar I,SS6 MW
-_Solar ~Peak wih solar 1,3-Net (13.7% re/iOn)
_f&
'\--V Ì\/"."/..-.-/\/
\/
'"I-\;
-------------
~..~---.~----------
---',-,---".L T T T L-,--..--T -,-T
MW
~,,;, ~ ~" ~;~ ~ ~ # #, ~ ~ ~; ~~ ~
The facilty generated a significant amount of electrical energy on this hot day, but its output fell
substantially before Avista's load felL. Therefore Avista's peak need for non-solar resources was simply
shifed from hour ending 17 (4:00p-S:OOpm) to hour ending 22 (9:00p-10:00p). A 13.7% reduction was
achieved. A similar analysis was completed by the Northwest Power and Conservation Council's (NPCC)
6th Power Plan using the expected solar output of southern Idaho. NPPC's analysis revealed an even
smaller peak reduction of 9%.
The same analysis performed for the winter, using both Avista's and the NPCC's solar profiles, found
that during the winter solar wil provide no peak capacity reduction.
PageS
CERTIFICATE OF SERVICE
I hereby certify that on this 18th day of January 2011, true and correct copies of
the foregoing Reply Comments of A vista Corporation were delivered to the following
persons via EmaiL.
Jean Jewell
Idaho Public Utilities Commission
472 W. Washington St.
Boise, ID 83702
Email: jean.jewell(£puc.idaho.gov
Dean J. Miler, Esq.
McDevitt, & Miler, LLP
PO Box 2564
Boise, ID 83701-2564
j oe(£mcdevitt -miler .com
Daniel E. Solander
Senior Counsel
Rocky Mountain Power
201 S. Main Street, Suite 2300
Salt Lake City, UT 84111
Email: Daniel.solander(£pacificorp.com
Donovan E. Walker
Lisa Nordstrom
Idaho Power Company
PO Box 70
Boise, ID 83707-0070
Email: dwalker(£idahopower.com
lnordstrom(£idahopower .com
Ted S. Sorenson, P.E.
Sorenson Engineering, Inc.
5203 South 11 th East
Idaho Falls, ID 83404
Email: ted(£sorenson.net
Page I-CERTIFICATE OF SERVICE
Kris Sassar
Deputy Attorney General
Idaho Public Utilities Commission
472 W. Washington St.
Boise, ID 83702
Email: kris.sassar(ßpuc.idaho.gov
Peter Richardson
Gregory M. Adams
Richardson & O'Leary
515 N. 27th St.
PO Box 7218Boise, ID 83702
Email: peter(£richardsonandoleary.com
greg(£richardsonandoleary.com
Ted Weston
ID Regulatory Affairs Manager
Rocky Mountain Power
201 S. Main Street, Suite 2300
Salt Lake City, UT 84111
Email: ted.weston(£pacificorp.com
R. Greg Ferney
Mimura Law Offices, PLLC
2176 E. Franklin Rd., Suite 120
Meridian, ID 83642
Email: greg(£mimuralaw.com
Robert D. Kah
Executive Director
Northwest and Intermountain Power
Producers Coalition
1117 Minor Ave., Suite 300
Seattle, W A 9810
Email: rkahn(£nippc.org
Glenn Ikemoto
Margaret Ruger
Idaho Windfarms, LLC
672 Blair Ave.
Piedmont, CA 94611
E-mail: glenni(genvisionwind.com
Margaret(genvisionwind.com
Shelley M. Davis
Barker Rosholt & Simpson, LLP
1010 W. Jefferson St., Ste. 102
P.O. Box 2139
Boise, ID 83701-2139
Email: smd(gidahowaters.com
Paul Marin
Intermountain Wind, LLC
PO Box 353
Boulder, CO
Email:
paulmarin(gintermountainwind.com
Ronald L. Wiliams
Wiliams Bradbury, P.C.
1015 W. Hays St.
Boise ID, 83702
Email: .ron(gwillamsbradbury.com
Dana Zentz
VP, Summit Power Group, Inc.
2006 E. Westminster
Spokane, W A 99223
Email: dzentz(gsuminitpower.com
James Carkulis
Managing Member
EXERGY DEVELOPMENT GROUP OF
IDAHO,LLC
802 West Banock Street, Ste. 1200
Boise, Idaho 83702
Email:jcarkulis(gexergydevelopment.com
Page 2-CERTIFICATE OF SERVICE
Thomas H. Nelson
Attorney for Renewable Energy Coalition
PO Box 1211
Welches, OR 97067-1211
Email: nelson(gthnelson.com
Bil Piske, Manager
Interconnect Solar Development, LLC
1303 E. Carter
Boise, ID 83706
Email: bilpiske(gcableone.net
Bil Brown, Chair
Board of Commissioners of Adams County,
Idaho
PO Box 48
Council, ID 83612
Email: dbbrown(gfrontiernet.net
Scott Montgomery
President, Cedar Creek Wind, LLC
668 Rockwood Drive
North Salt Lake, Uta 84054
Email: scott(gwesternenergy.us
Wade Thomas
General Counsel, Dynamis Energy
776 E. Riverside Drive, Suite 15
Eagle, ID 83616
Email: wthomas(gdynamisenerg.com
Robert A. Paul
Grand View Solar II
15960 Vista Circle
Desert Hot Springs, CA
Email: robertapaul(ggmaiL.com
John R. Lowe
Consultant to Renewable Energy
Coalition
12050 SW Tremont Street
Portland, OR 97225
Email: jravenesanmarcosêyahoo.com
Twin Falls Canal Company
c/o Brian Olmstead, General Manager
P.O. Box 326
Twin Falls, Idaho 83303-0326
Email: olmsteadêtfcanal.com
Page 3-CERTIFICATE OF SERVICE
Don Sturevant
Energy Director
1. R. Simplot Company
ONE CAPITAL CENTER
999 Main Street, P.O. Box 27
Boise, Idaho 83707-0027
Email: don.sturtevantêsimplot.com
North Side Canal Company
c/o Ted Diehl, General Manager
921 N. Lincoln St.
Jerome, Idaho 83338
Email: nscanalêcableone.net
flMichael G. Andrea