20110120IPC Reply Comments.pdf

DONOVAN E. WALKER
Senior Counsel
dwalkerØìidahopower.com
1SIDA~POR~
An IDACORP company
January 19, 2011
VIA HAND DELIVERY
Jean D. Jewell, Secretary
Idaho Public Utilties Commission
472 West Washington Street
P.O. Box 83720
Boise, Idaho 83720-0074
Re: Case No. GNR-E-10-04
IN THE MATTER OF THE JOINT PETITION OF IDAHO POWER COMPANY,
AVISTA CORPORATION, AND PACIFICORP DBA ROCKY MOUNTAIN
POWER TO ADDRESS AVOIDED COST ISSUES AND TO ADJUST THE
PUBLISHED AVOIDED COST RATE ELIGIBILITY CAP
Dear Ms. Jewell:
Enclosed for filng please find an original and seven (7) copies of the Reply
Comments of Idaho Power Company in the above matter.
Very truly yours,.t(~
Donovan E. Walker
DEW:csb
Enclosures
1221 W. Idaho St. (83702)
P.O. Box 70
Boise, I D 83707
DONOVAN E. WALKER (ISB No. 5921)
LISA D. NORDSTROM (ISB No. 5733)
Idaho Power Company
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
dwalkerayidahopower.com
Inordstromayidahopower.com
s Ci.'\
zon JAN l 9 PH 4: 56
Attorneys for Idaho Power Company
Street Address for Express Mail:
1221 West Idaho Street
Boise, Idaho 83702
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE JOINT PETITION )
OF IDAHO POWER COMPANY, AVISTA ) CASE NO. GNR-E-10-04
CORPORATION, AND PACIFICORP DBA )
ROCKY MOUNTAIN POWER TO ) REPLY COMMENTS OF
ADDRESS AVOIDED COST ISSUES AND ) IDAHO POWER COMPANY
TO ADJUST THE PUBLISHED AVOIDED )
COST RATE ELIGIBILITY CAP. )
)
Idaho Power Company ("Idaho Powet' or "Company"), by and through its
attorney of record, Donovan E. Walker, and in response to the Notice of Modified
Procedure issued in Order No. 32131 on December 3,2010, and the various comments
filed on or before December 22, 2010, now respectfully submits the following Reply
Comments.
I. INTRODUCTION
On November 5, 2010, Idaho Power Company, Avista Corporation, and
PacifiCorp d/b/a Rocky Mountain Power ("the Utilities") filed a Joint Petition requesting
REPLY COMMENTS OF IDAHO POWER COMPANY - 1
the Idaho Public Utilties Commission ("Commission") initiate an investigation into
various avoided cost issues regarding the Public Utilty Regulatory Policies Act of 1978
("PURPA") Qualifying Facilties ("QF"). Additionally, the Utilties requested that the
Commission issue an Interlocutory Order adjusting the published avoided cost rate
eligibilty cap for QFs from 10 average megawatts ("aMW") to 1 00 kilowatts ("kW")
effective immediately.
On December 3, 2010, the Commission issued Notice of the Joint Petition and
Notice of Modified Procedure, Intervention Deadline, and Oral Argument setting 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 eligibilty cap. Order No. 32131, Case No. GNR-E-10-04. Initial Comments were
due on December 22, 2010; Reply Comments were due January 19, 2011; and Oral
Argument is scheduled for January 27, 2011. The Commission also ordered that its
decision regarding whether to reduce the published avoided cost rate eligibilty cap
become effective on December 14, 2010. Id., at 6-7. In that Notice, the Commission
stated that it "wil first take up the request to reduce the eligibilty cap." Id., at 5. The
Commission set out three specific topics that it is interested in receiving comments
upon:
(1) the advisabilty of reducing the published avoided costeligibility cap; (2) if the eligibilty cap is reduced, the
appropriateness of exempting non-wind QF projects from the
reduced eligibilty cap; and (3) the consequences of dividing
larger wind projects into 10 aMW projects to utilze the
published rate.
Id.
REPLY COMMENTS OF IDAHO POWER COMPANY - 2
Idaho Power filed initial Comments addressing these three topics, supporting the
initial request to reduce the published avoided rate eligibilty cap, and seeking
application of that published rate eligibilty reduction to all PURPA QF projects.
Comments were also filed by Avista, Rocky Mountain Power, and Commission Staff.
Additionally, several public comments were filed before and after the comment deadline
and many of the intervening parties also filed comments.
II. IDAHO POWER'S REPLY COMMENTS
A. There is Sufficient Evidence to Warrant Commission Action.
Many of the comments allege that the utilties have not put forth suffcient
evidence to justify Commission action as requested in the Joint Petition. Idaho Power
disagrees. First, while not exhaustive, the Joint Petition sets forth sufficient facts that
are of such a magnitude and extreme public interest as to support the relief requested
on a stand-alone basis. Commission Staff agrees, and struck upon the heart of the
matter when it stated:
Forcing utilties to acquire generation they do not need
increases rates for customers. Moreover, it negates the
integrated resource planning process wherein a utilty's
needs can be appropriately matched with resources at the
lowest cost. By default, PURPA has become one of the
primary means for the utilties in Idaho to acquire new
generation, but Staff is not convinced that it is the most
effective, least costly way, or that it is in the best interests of
ratepayers.
Staff Comments, p. 5. Staff went on to recommend:
Staff supports the utilties' Petition seeking to reduce the
avoided cost eligibilty cap from the current 10 aMW to 100
kW. Staff is convinced that the problem described by the
utilities in their Petition is real and requires immediate
attention by the Commission. There is clear evidence in all
three utilties' service territories that large wind projects are
REPLY COMMENTS OF IDAHO POWER COMPANY - 3
purposely being disaggregated into smaller 10 aMW projects
in order to be eligible for published avoided cost rates. This
issue alone, Staff believes, provides sufficient justification for
lowering the eligibilty cap for published rates.
Id. Staff ultimately acknowledges, "Published avoided cost rates, at least as currently
computed, are no longer the throttle controllng new development because they may not
reflect either the true value or need for new generation." Id., at 7. This conclusion was
also reached, and examined, by Idaho Power in its Comments, "Idaho Power is forced
to purchase this (QF) power with no regard to whether it is needed on its system, with
no regard to whether it is called for in the Company's IRP (Integrated Resource
Planning) process, and with no regard to whether there are other lower cost alternatives
for its customers." Idaho Power Comments, p. 24.
Second, with the submission of its initial Comments in this case, Idaho Power
believes that what was already a sufficient case requiring immediate Commission action
has been further shown to be a compellng case of immediate and grave public interest.
As of December 20, 2010, the total amount of QF wind generation proposed for Idaho
Powets system (840 megawatts ("MW")) exceeds all of the previously developed QF
wind generation operating on Idaho Powets system since the passage of PURPA in
1978 by more than 2 Y2 times (326 MW). The total amount of non-wind QF generation
operating on Idaho Powets system is dwarfed by comparison with a total of 219 MW.
Furthermore, as stated in Idaho Powets initial Comments, the nature and flaws inherent
with the Surrogate Avoided Resource ("SAR") methodology used to establish the
published avoided cost rate, combined with the disaggregation and configuration of
what are or should be larger projects into 1 0 aMW increments in order to qualify for the
published rates, when applied to just 614 MW of the proposed QF projects, results in an
REPLY COMMENTS OF IDAHO POWER COMPANY - 4
increased cost to customers estimated at more than $48 milion annually to pay for QF
generation over current forward energy market rates. This potentially drastic disparity in
customer rates as well as the continued, unchecked growth of QF wind projects on
Idaho Powets system justifies immediate Commission action.
B. The Commission Has the Authority to Modify the Published Rate
Eligibilty Cap. to Establish Avoided Cost Rates. and to Approve.
Reject. andlor Reform PURPA QF Contracts in the Public Interest.
The Northwest and Intermountain Power Producers Coalition ("NIPPC") alleges
infirmities with the Commission's procedure and questions the Commission's authority
to grant the relief requested by the Utilties. The Commission has the jurisdiction,
authority, and, in fact, the obligation to act in such a situation as outlined in the Joint
Petition and Comments of the Utilties. Quite clearly, the Commission has the authority
to set avoided cost rates, to order electric utilities to enter into fixed-term obligations for
the purchase of energy from QFs, and to implement Federal Energy Regulatory
Commission ("FERC") rules. PURPA, 16 U.S.C. § 824a; 18 C.F.R. § 292; Connecticut
Light and Power Co., 70 F.E.R.C.1f 61,012,61,024 (1995).
As stated in Idaho Powets Comments, the incentive mandated by PURPA is not
to incent renewable energy projects with an incentive price that is paid to a QF and, in
fact, an incentive price for QFs is ilegal under PURPA. Idaho Power Comments, p. 4.
PURPA requires the Commission to set prices at the utility's avoided cost, which is to
reflect the incremental cost to an electric utilty of electric energy or capacity or both,
which, but for the purchase from the QF, such utilty would generate itself or purchase
from another source. The incentive to QF development from PURPA is not in the price
that a QF is entitled to but in the fact that the utilty is required to contract with the QF.
REPLY COMMENTS OF IDAHO POWER COMPANY - 5
See 16 U.S.C. § 824a-3(a). Idaho Power adheres to this federal PURPA mandate by
making available Firm Energy Sales Agreements ("FESA") for any QF seeking to sell
energy to Idaho Power. The Commission accomplishes the purpose of PURPA by
requiring Idaho Power to enter into FESAs, or contracts, with QF projects, requiring
specific terms and conditions to be included in these FESAs with QFs, and by requiring
its review and approval of all QF FESAs prior to the agreement becoming effective.
As the designated regulatory authority for public utilties in the state of Idaho, the
Commission plays a unique and special role in the contracting process and validity of
contracts entered into by the public utilties that it regulates. In the state of Idaho,
contracts are afforded constitutional protection against interference from the State.
Idaho Const. Art. I, § 16. However, despite this constitutional protection, the
Commission may annul, supersede, or reform the contracts of the public utilties it
regulates in the public interest. Agricultural Products Corp. v. Utah Power & Light Co.,
98 Idaho 23, 29, 557 P.2d 617, 623 (1976) ("Interference with private contracts by the
state regulation of rates is a valid exercise of the police power, and such regulation is
not a violation of the constitutional prohibition against impairment of contractual
obligations."); See also Federal Power Comm's v. Sierra Pac. Power Co., 350, U.S.
348, 76 S.Ct. 368, 100 L.Ed. 388 (1956); United Gas Pipe Line Co. v. Mobile Gas
Service Corp., 350 U.S. 332, 76 S.Ct. 373, 100 L.Ed. 373 (1956) (U.S. Supreme Court
finding that rates fixed by contract could be modified only "when necessary in the public
interest"). The Commission may interfere in such a way with the contracts of a public
utility only to prevent an adverse affect to the public interest. Agricultural Products, 98
REPLY COMMENTS OF IDAHO POWER COMPANY - 6
Idaho at 29. "Private contracts with utilties are regarded as entered into subject to
reserved authority of the state to modify the contract in the public interest." Id.
Here, there are just such public interest implications as those contemplated and
required by the Sierra-Mobile doctrine and Agricultural Products and its progeny, as to
invoke and authorize the Commission - in the exercise of its legislative, state police
power and authority to protect the public in the contractual rates that it sets and the
public utilty contracts that it reviews for the purchase of energy from QF projects under
PURPA.
NIPPC's alleged procedural issues related to the Commission's effective date of
December 14, 2010, and NIPPC's alleged issues related to the filed rate doctrine and
retroactive ratemaking are moot and inconsequential in a case such as this with such
large and grave public interest ramifications as to invoke the Commission's authority to
annul, supersede, or reform contracts with public utilties.
In addition, NIPPC's reliance on Arkansas Louisiana Gas v. Hall as a prohibition
from this Commission engaging in retroactive ratemaking is misplaced. NIPCC
Comments at pp. 9-10. Arkansas Louisiana Gas involved parties (one of which was a
utility) attempting to agree, via private contract, to rates different than tariffed rates.
That case did not challenge whether a utilty regulator has the authority to modify
contracts entered into by public utilities so as to ensure the public interest is served. In
fact, the Supreme Court reiterated its position that regulators may, under "extraordinary
circumstances. . . abrogate existing contractual arrangements." 453 U.S. 571,582. As
explained above and in Idaho Powets Comments, the unchecked proliferation of QF
projects in combination with a current published avoided cost rate that is substantially
REPLY COMMENTS OF IDAHO POWER COMPANY - 7
higher than current market rates is creating an extraordinary circumstance for Idaho
ratepayers. There is nothing in Arkansas Louisiana Gas that supports NIPCC's
contention that the filed rate doctrine somehow prohibits this Commission from
modifying contracts entered into by public utilties if doing so serves the public interest.
Moreover, and as explained above, PURPA and FERC have delegated broad,
discretionary authority to this Commission when it comes to implementing PURPA. This
Commission is charged with upholding the public interest. Thus, this Commission has
both the statutory authority and well-established precedent from the state and federal
judiciary to invoke the Commission's authority to annul, supersede, or reform contracts
with public utilties so that the public interest is served.
C. Reduction of the Published Rate Eligibility Cap Upholds Federal Law.
NIPPC alleges that reducing the eligibilty cap violates federal law. NIPPC
Comments at pp. 6-8. This is incorrect. Federal law requires the Commission to put
into effect standard rates for utilty purchases from QFs with a design capacity of 100
kW or less. 18 C.F.R. § 292.304(c)(1). Standard rates for QFs larger than 100 kW are
completely discretionary with the Commission. 18 C.F.R. § 292.304(c)(2). Federal law
specifically requires that rates for QF purchases "be just and reasonable to the electric
consumer of the electric utilty and in the public interest." 18 C.F.R. § 292.304(a)(1 )(i).
Federal law requires that utilty customers be economically indifferent to the effects of
whether power is purchased from a QF or otherwise generated or purchased by the
utilty. Southern California Edison Co., 71 F.E.R.C. 1f 61,269, 1995 WL 327268
(F.E.R.C. 1995) ("The intention (of PURPA) was to make ratepayers indifferent as to
REPLY COMMENTS OF IDAHO POWER COMPANY - 8
whether the utilty used more traditional sources of power or the newly-encouraged
alternatives.").
When the utilty is forced to buy QF power at a price in excess of its true avoided
cost, or when the energy is not needed to serve loads, customers are no longer
indifferent. When it is demonstrated that the QF purchases, regardless of need, wil
result in substantially increased costs for customers over less costly, and more reliable,
alternative sources of energy, the public interest demands correction of the inequity.
Such inequity has been shown to exist with the current application of the SAR
methodology to the large amount of QF generation proposed for Idaho Powets system.
Federal and state law does not prohibit and, in fact, requires corrective action.
D. Published Rates are Not Guaranteed. But Subject to the Public
Interest.
Several comments reference the "certainty" of the published avoided cost rate for
long-term planning, financing, and other considerations. NIPPC warns that "This wil
surely chil the market for QFs . . .." NIPPC Comments p. 12. As stated above,
"Private contracts with utilties are regarded as entered into subject to reserved authority
of the state to modify the contract in the public interest." Agricultural Products, 98 Idaho
at 29. All PURPA QF contracts are filed for review by the Commission. All PURPA QF
contracts contain provisions that state the FESA is subject to the jurisdiction of the
Commission and is only effective, and final, upon Commission approval of all terms and
provisions of the contract without change or condition. Only after a PURPA QF contract
has been executed by both parties and approved by the Commission are the terms,
conditions, and pricing within that specific QF contract certain.
REPLY COMMENTS OF IDAHO POWER COMPANY - 9
Published avoided cost rates change. For example, rates are changed when
new natural gas forecasts are released. Methodologies change, and have done so
numerous times since the inception of PURPA. The alleged notion that the published
rates are "certain" and required for projects to rely upon for project planning and
financing is misplaced. The published rates that are in place at the time a project is in
initial development is not necessarily the published rates that wil be in effect at the time
the project executes the contract. Additionally, as stated above, nothing in the FESA is
even final until after Commission review and approvaL. Anyone that relies upon a
FESA, including the rates contained therein, as locked in stone prior to Commission
review and approval of the same does so at their own peril and risk. Commission
review is not a rubber stamp formality once the FESA is signed. It is, and must be, a
meaningful review of the terms and conditions, reasonableness, and prudency of the
contractual relationship and obligations. It must be a meaningful review of whether, as
a whole, the FESA is in the public interest.
E. The IRP-Based Avoided Cost Price is Not Always Below the SAR-
Based Avoided Cost Pricing.
The IRP-based methodology does not automatically result in an avoided cost
calculation that is lower than published avoided cost rates based on the SAR
methodology. As stated by Commission Staff and Idaho Power, the IRP-based
methodology recognizes and considers the individual generation characteristics of
projects and thus produces different rates for different projects. Idaho Power
Comments, pp. 8-10; Commission Staff Comments, p. 4. The IRP-based methodology
arrives at a price that better reflects a value that the generation represents on the
utilty's system, unlike the SAR-based methodology, which promotes a project to
REPLY COMMENTS OF IDAHO POWER COMPANY - 10
generate as much and as often as it can, regardless of the value to the utilty or the
utilty's need for the energy. A resource that provides energy when the utilty needs
energy to serve load, during peak hours, wil see a corresponding increase in pricing
through the AURORAmp(I ("AURORA") based i RP-methodology. Additionally, if a
resource provides energy when the utilty does not need it, and is otherwise surplus, a
corresponding reduction in the rates results for the minimal - or no - value that this
energy provides to the utilty and its customers.
For example, a project like a geothermal resource may run flat-out during all
months and all hours providing energy during peak times when it is needed most, but
also providing energy at off-peak times when it is not needed, thus providing little to no
value. The energy price determined through the IRP-based methodology at least
provides some recognition of this fact and sets a price accordingly, unlike the SAR
methodology. Wind, for example, particularly because of its low capacity factor,
intermittency, and poor generation profile relative to peak loads, generally does not
come out of the IRP-based pricing methodology with a price that is as high as that of the
SAR method. See Case No. IPC-E-10-24, Rockland Wind Project, (for the recently
approved Rockland Wind project, the energy price identified by the AURORA run was
$62.71, or $56.21 after a discount of $6.50 per MW-hour for wind integration).
Consequently, this results in the great aversion that wind developers have to negotiating
a QF contract under the IRP-based methodology and the resulting disaggregation of
what should legitimately be larger projects into 10 aMW increments to qualify for the
published rates instead.
REPLY COMMENTS OF IDAHO POWER COMPANY - 11
Another example on the other end of the spectrum would be a representative
solar project. When a typical southern Idaho solar project is run through AURORA, the
IRP-based avoided cost methodology results can be somewhat surprising. A recent run
of a 20 MW nameplate solar energy project, on-line in 2012, results in a 20-year
levelized price of just over $97 per megawatt-hour ("MWh"). Consequently, the
comments, arguments, and accusations that Idaho Power is simply trying to push the
IRP-based methodology because it always results in a price that is less than the
published rate are not true. The IRP-based methodology results in an AURORA energy
price that is less than published rates for those resources that provide little to no value
to the Company's system and the loads that it is required by law to meet.
F. The Published Rate Eligibilty Cap Reduction Should Apply to All QF
Projects.
Commission Staff recommends that the Commission reduce the published rate
eligibility cap to 100 kW, but only for wind QFs. While Idaho Power appreciates and
respects Staffs position, the Company believes that all PURPA QF projects should be
included in the published avoided cost rate eligibilty cap reduction for the simple reason
that they all suffer from, and contribute to, the same SAR-methodology problems
mentioned above and discussed in Idaho Powets initial Comments. All QFs generate
during light load hours and contribute to the price and cost differentials already
discussed. The lack of any consideration of the utilty's need for the energy, or load, in
relation to when the QF supplies generation that the utilty must take from it does not
change because the QF is a non-wind resource.
Additionally, with the cumulative nature of more than thirty years of QF projects
entering onto Idaho Powets system, as well as the more recent phenomenon of larger
REPLY COMMENTS OF IDAHO POWER COMPANY - 12
and larger projects that intentionally break themselves into 10 aMW increments so as to
qualify for published rates, it can no longer be said that the financial impact to the
utilty's customers from any QF project, no matter how small, has a "small" impact to the
rates that customers must pay for electricity. While the scale of non-wind QFs is much
smaller, many of the same problems are, and the same financial harm is, caused by
non-wind QFs just the same. A reduction in the published rate eligibilty should apply
equally to all QF projects.
G. AURORA Modeling Capabilties.
As stated, Idaho Power believes that all QF projects, even smaller projects,
suffer from, and contribute to, the same SAR-methodology problems mentioned above
and discussed in Idaho Powets initial Comments. However, in researching the
AURORA modeling capabilties, the softare provider has advised that there may be
some issues with the softare producing dependable results for projects that are less
than 2 MW. One of reasons being that the pricing in the IRP-based methodology is a
result of subtracting the base model results (that do not include the proposed project)
from the model results, including the proposed project. If the project is small enough
that it does not trigger changes in the base model operations, Le., it is lost in the
rounding to MWs or MWhs, then the base model results could be identical to the
modeled results that include the project. This would result in an AUROA pricing of zero.
While Idaho Power believes using the IRP-based methodology for any project
above 100 kW is the right answer, there are some limitations to modeling projects below
a certain size. To remedy this situation, Idaho Power proposes to work with Staff to
reach an appropriate solution for analyzing these smaller projects. Initially, Idaho Power
REPLY COMMENTS OF IDAHO POWER COMPANY - 13
anticipates scaling smaller projects up to a larger size, retaining the original project's
generation profile, and calculating the IRP-based avoided cost rate. In any event, the
point is that there are some technical issues that wil need to be resolved for those small
projects that fall into a range from 10 kW to around 2 MW. Idaho Power is confident
that it can, along with Commission Staff, develop a workable solution consistent with the
approved IRP-based methodology.
II. CONCLUSION
A situation has developed with the rapid and large scale proliferation of proposed
QF generation for Idaho Powets system at levels that exceed the total load on the
Company's entire system during minimum load hours - and exceeds 1/3 of the total
system load for the Company's all-time system peak load. This large scale of proposed
QF generation also comes with a large scale price and cost to Idaho Powets
customers. This cost, regardless of the question of whether the generation is needed or
not, exceeds the cost of other available generation sources by an estimated $48 milion
on an annual basis, and is not in the public interest. The price and cost disparity that
has been demonstrated to exist with just a portion of the now pending contractual
PURPA QF obligations filed for review with the Commission is of such a magnitude as
to invoke the Commission's inherent authority to annul, supersede, or reform in the
public interest the contracts of the public utilties it regulates.
As stated in the Company's Comments, it does not expect the parties, nor the
Commission, to solve all of the issues or problems identified with avoided costs and QF
generation at this moment. However, we are fortunate that an existing, approved
avoided cost methodology, the IRP-based methodology, exists and, as demonstrated, is
REPLY COMMENTS OF IDAHO POWER COMPANY - 14
a very reasonable method for addressing some of the most pressing problems raised in
this proceeding - particularly that of introducing some concept of need and value of
these generation sources on Idaho Powets system - while these important issues are
considered by the parties and the Commission.
Idaho Power respectfully urges the Commission to reduce the published avoided
cost rate eligibility cap for PURPA QFs from 10 aMW to 100 kW.
DATED at Boise, Idaho, this 19th day of January 2011.
~~Lt
Attorney for Idaho Power Company
REPLY COMMENTS OF IDAHO POWER COMPANY - 15
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 19th day of January 2011 I served a true and
correct copy of REPLY COMMENTS OF IDAHO POWER COMPANY upon the
following named parties by the method indicated below, and addressed to the following:
Commission Staff
Donald L. Howell, II
Kristine Sasser
Deputy Attorneys General
Idaho Public Utilties Commission
472 West Washington
P.O. Box 83720
Boise, Idaho 83720-0074
Avista Corporation
Michael G. Andrea
Clint Kalich
Avista Corporation
1411 East Mission Avenue - MSC-23
P.O. Box 3727
Spokane, Washington 99220-3727
PacifiCorp d/b/a Rocky Mountain Power
Daniel E. Solander
J. Ted Weston
Rocky Mountain Power
201 South Main Street, Suite 2300
Salt Lake City, Utah 84111
Bruce Griswold
PacifiCorp
825 NE Multnomah
Portland, Oregon 97232
Exergy, Grand View Solar, J. R. Simplot,
Northwest and Intermountain Power
Producers Coalition, & Board of
Commissioners of Adams County, Idaho
Peter J. Richardson
Greg Adams
RICHARDSON & O'LEARY, PLLC
515 North 2ih Street
P.O. Box 7218
Boise, Idaho 83702
REPLY COMMENTS OF IDAHO POWER COMPANY - 16
-- Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
-- Email don.howeiiaypuc.idaho.gov
kris. sasseraypuc. idaho .gov
Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
-- Email michael.andreaayavistacorp.com
ci int. kal ichayavistacorp. com
Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
-- Email daniel.solanderaypacificorp.com
ted. westonaypacificoro.com
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-- Email bruce.griswoldaypacifiCorp.com
Hand Delivered
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_ Overnight Mail
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-- Email peterayrichardsonandoleary.com
gregayrichardsonandoleary. com
Exergy Development Group
James Carkulis, Managing Member
Exergy Development Group of Idaho, LLC
802 West Bannock Street, Suite 1200
Boise, Idaho 83702
Grand View Solar II
Robert A. Paul
Grand View Solar II
15960 Vista Circle
Desert Hot Springs, California 92241
J.R. Simplot Company
Don Sturtevant, Energy Director
J.R. Simplot Company
One Capital Center
999 Main Street
P.O. Box 27
Boise, Idaho 83707-0027
Northwest and Intermountain Power
Producers Coalition
Robert D. Kahn, Executive Director
Northwest and Intermountain Power
Producers Coalition
1117 Minor Avenue, Suite 300
Seattle, Washington 98101
Renewable Energy Coalition
Thomas H. Nelson, Attorney
P.O. Box 1211
Welches, Oregon 97067-1211
John R. Lowe, Consultant
Renewable Energy Coalition
12050 SW Tremont Street
Portland, Oregon 97225
Cedar Creek Wind, LLC, & Dynamis
Energy, LLC
Ronald L. Willams
WILLIAMS BRADBURY, P.C.
1015 West Hays Street
Boise, Idaho 83702
Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
-- Email jcarkulisayexergydevelopment.com
Hand Delivered
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-- Email robertapaul08aygmail.com
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-- Email don.sturtevantaysimplot.com
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-- Email rkahnaynippc.org
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-- Email nelsonaythnelson.com
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-- Email jravenesanmarcosayyahoo.com
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-- Email ronaywillamsbradbury.com
REPLY COMMENTS OF IDAHO POWER COMPANY - 17
Cedar Creek Wind, LLC
Scott Montgomery, President
Cedar Creek Wind, LLC
668 Rockwood Drive
North Salt Lake, Utah 84054
Dana Zentz, Vice President
Summit Power Group, Inc.
2006 East Westminster
Spokane, Washington 99223
Dynamis Energy, LLC
Wade Thomas, General Counsel
Dynamis Energy, LLC
776 East Riverside Drive, Suite 15
Eagle, Idaho 83616
Idaho Windfarms, LLC
Glenn Ikemoto
Margaret Rueger
Idaho Windfarms, LLC
672 Blair Avenue
Piedmont, California 94611
Interconnect Solar Development, LLC
R. Greg Ferney
MIMURA LAW OFFICES, PLLC
2176 East Franklin Road, Suite 120
Meridian, Idaho 83642
Bil Piske, Manager
Interconnect Solar Development, LLC
1303 East Carter
Boise, Idaho 83706
Intermountain Wind LLC
Dean J. Miler
McDEVITT & MILLER LLP
420 West Bannock Street
P.O. Box 2564
Boise, Idaho 83701
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-- Email scottaywesternenergy.us
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-- Email dzentzaysummitpower.com
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-- Email wthomasaydynamisenergy.com
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-- Email glenniayEnvisionWind.com
MargaretayEnvisionWind .com
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-- Email gregaymimuralaw.com
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-- Email bilpiskeaycableone.net
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-- Email joeaymcdevitt-miler.com
REPLY COMMENTS OF IDAHO POWER COMPANY - 18
Paul Martin
Intermountain Wind LLC
P.O. Box 353
Boulder, Colorado 80306
North Side Canal Company and Twin
Falls Canal Company
Shelley M. Davis
BARKER ROSHOLT & SIMPSON, LLP
1010 West Jefferson Street, Suite 102
P.O. Box 2139
Boise, Idaho 83701-2139
Brian Olmstead, General Manager
Twin Falls Canal Company
P.O. Box 326
Twin Falls, Idaho 83303
Ted Diehl, General Manager
North Side Canal Company
921 North Lincoln Street
Jerome, Idaho 83338
Board of Commissioners of Adams
County, Idaho
Bil Brown, Chair
Board of Commissioners of
Adams County, Idaho
P.O. Box 48
Council, Idaho 83612
Birch Power Company
Ted S. Sorenson, P.E.
Birch Power Company
5203 South 11 th East
Idaho Falls, Idaho 83404
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-- Email paulmartinayintermountainwind.com
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-- Email smdayidahowaters.com
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-- Email olmsteadaytfcanal.com
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-- Email nscanaiaycableone.net
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-- Email bdbrownayfrontiernet.net
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-- Email tedaytsorenson.net
~t1Cc
Donovan E. Walker
REPLY COMMENTS OF IDAHO POWER COMPANY - 19