20101222Comments.pdf

KRISTINE A. SASSER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BARNO. 6618
RECEf
inio DEC 22 PH 3: 04
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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. )
)
CASE NO. GNR-E-IO-4
COMMENTS OF THE
COMMISSION STAFF
COMES NOW the Staff of the Idaho Public Utilities Commission, by and through its
Attorney of record, Kristine A. Sasser, Deputy Attorney General, and in response to the Notice
of Joint Petition, Notice of Modified Procedure, Notice of Intervention Deadline and Notice of
Oral Argument issued in Order No. 32131 on December 3, 2010, in Case No. GNR-E- 1 0-4,
submits the following comments.
BACKGROUND
On November 5, 2010, Idaho Power Company, AvistaCorporation, and PacifiCorp dba
Rocky Mountain Power (Utilties) fied a JointP~tition requesting that the Commission initiate
an investigation to address various avoided costissuesl related to the Public Utility Regulatory
1 Although the Joint Petition identifies numerous issues to be examined, no fonnal consensus on identification of
issues has been reached by the paries. Furthennore, Staff does not necessarily believe that all of the issues
identified in the Joint Petition need to be addressed in furter proceedings.
STAFF COMMENTS 1 DECEMBER 22,2010
Policies Act of 1978 (PURP A). While the investigation is underway, the Petitioners also
requested that the Commission "lower the published avoided cost rate eligibility cap from 10
aMW to 100 kW (to) be effective immediately. . . ." Petition at 7.
The Joint Petition was fied following a public workshop in Case No. GNR-E-09-03
convened for the purose of discussing a surrogate avoided resource (SAR) methodology for
wind-specific qualifying facilties (QFs). The Joint Petition asserts that there was a discussion at
the November 3,2010 workshop regarding the need to temporarily reduce the eligibilty cap
while an investigation of numerous avoided ,cost issues is conducted. The Petitioners maintain
that the Commission has made similar reductions in the past on an interim basis, citing
Commission Order Nos. 29872 in Case Nò. IPC-E-05-22.
The Joint Petition asserts that many of the same reasons that justified the Commission's
action to lower the eligibility cap to 100 kW in the 05"'22 case are present in this case. The
Petitioners stress that the reasons and justifications are amplified in the present situation because
"the number of projects, their combined MWs, the dollar impacts, and the potential
consequences to the system and to customers are much larger and much more pronounced than
even those that existed (in 2005)." ¡d. at 3.
The Petition states that Idaho Power èi.rrentlyhas more than 208 MW of wind generation
and an additional 264 MW ofCommission-apprôved QF wind contracts (many of which are
scheduled to be online by December 31, 2010). The Petition asserts that Idaho Power could have
1 100 MW of wind powered generation on its system in the near term that would exceed the
minimum loads experienced on Idaho Power's system this year. "Cumulatively, this amount of
generation would exceed any other single source' ôfgeneration - hydro, coal, natual gas, or
renewables - that exists on Idaho Power'ssysiem."ld at 4:
Rocky Mountain asserts that it is in a similar situation. The Petition declares that in
2005, Rocky Mountain had a single 20MW windQF contract and less than 50 MW of wind QF
requests in Idaho. "As of today, (Rocky Mountain) has 64 MW of wind QF contracts executed;
however, none have achieved commercial operation, and another 358 MW of stadard wind QF
contracts are proposed." Rocky Mountain maintains that the majority of these proposed standard
wind QF contracts are configured to use the Goshen Idaho electrical system "where integration
of the QF resource as a Network Resource forsetvingloadcould be impacted by transmission
constraints across Path C if the wind power is,expòrted to RMP's northern Uta load." ¡d at 4.
STAFF COMMENTS 2 DECEMBER 22, 2010
The Petition states that many current QF projects are "large, utilty-scale wind fars that
are broken up into 10 aMW increments in order to qualify for the published (avoided cost)
rates." ¡d at 5. The Petition maintains that the typical wind developer is no longer
"unsophisticated" about the QF :process and small projects (0.5- 1.5 MW) "are no longer the
norm." ¡d The Petitioners assert that it is "coi:anplace" for wind developers seeking QF
contracts with Idaho Power and Rocky Mountain to aggregate "six or more 'projects' totaling
100 to 150 MW of nameplate rating, and the multiple projects to all share interconnection
facilities to one common utilty delivery point." ¡d The Petitioners request that the Commission
take action on its request to lower the eligibilty cap immediately "on fewer than foureen days
notice, if possible. See, RP 256."
In the Notice of Joint Petition, Notice of Modified Procedure, Notice of Intervention
Deadline and Notice of Oral Argument issued in Order No. 3213 1 on December 3, 2010, the
Commission declined to immediately reduce the published avoided cost rate eligibilty cap. The
Commission directed that the Petitioners' request to reduce the eligibility cap be processed by
Modified Procedure and scheduled an oral argument. In paricular, the Commission directed the
paries to address the following: (l) the advisability of reducing the published avoided cost
eligibility cap; (2) if the eligibilty cap is reduced, the appropriateness of exempting non-wind
QF projects from the reduced eligibiltycap:aiid~3) the consequences of dividing larger wind
projects into 10 aMW projects to utilze the'published rate.
STAFF ANALYSIS
PURPA requires that states put into effect ~tadard rates for purchases from QFs with a
design capacity of 100 kilowatts (kW) or less. At the same time, however, PURPA allows states
to put into effect standard rates for purchases from QFs with a design capacity of more than 100
kW. Reference 18 CFR 292.304(c)(1 and 2).
Since PURP A was first împlemented in Idaho in the early 1980s, the Commission, in
setting avoided cost rates, has elected to draw a clear distinction between large and small QF
projects. Avoided cost rates for small QFs have been set in a generic maner based on assumed
costs of a Surogate A voided Resource or "SAR". These generic avoided cost rates are
commonly referred to as the "published rates"
For large QFs, the CommissionestabHshed'a different methodology for determining
avoided cost rates. In that methodology, rates are computed using the results of each utilty's
STAFF COMMENTS 3 DECEMBER 22, 2010
production cost model as, a staring point for negotiations. In the case of Idaho Power and
Avista, the AURORA model is used as the production cost model, and for PacifiCorp, its GRID
model is used. This methodology,is commonly referred to as the "IRP methodology". The IRP
methodology recognizes the individual generation characteristics of projects and, in theory,
produces different rates for different projects. Use of the IRP methodology has been limited to
only two projects since PURP A was first implemented in Idaho. In large par, this is because
rates computed under the IRP methodology haveJ~nded to be less than published rates most of
"'/¡ :,
the time and because most project developers have had a perception that it is too diffcult to
negotiate contracts for large projects.
Thoughout most of the history of PURP A in Idaho, the Commission has set 10 average
megawatts (aMW) as the limit for eligibilty for published rates, instead of the lower 100 kW
capacity mandated by PURP A. 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-financed organizations, capable of sophisticated contract negotiations. By making
published rates available for small projects, rate negotiations can be eliminated and contracting
costs can be minimized.
The advisabilty of reducing the published avoided cost eligibilty cap
The development of large wind projects in Idaho over the past six years has blured the
distinction between large and small QFs. Windptòjects are unique from other generation
technologies because they normally consist of multiple turbines, each with its own generator,
often scattered over large areas. Because of this characteristic, wind projects capable of
generating more than 10 aMW per month can be subdivided into multiple legal entities and
reconfigured into smaller projects in order to qualify for the historically higher published
avoided cost rates. It has become quite common forlarge wind projects to be structured as
multiple, separate QFs, each 10 aMW in size, but collectively 60,80 or 120 MW in size. In fact,
nearly all new wind contracts submittediforCommission approval in recent years are collections
of two or more adjacent 10 aMW projects, each with common ownership and developers.
Although large wind projects are not inherently undesirable, aggregation of multiple QFs
does raise concerns. First, considering each 10 aMW QF individually for puroses of eligibilty
for avoided cost rates creates an artificial mismatch between the method used to establish a
project's avoided cost rates and the collective size of the project. For example, it could be argued
STAFF COMMENTS DECEMBER 22, 2010
that in fairness, a collection of six adjacent QFs being developed all at the same time and with a
common owner should have its avoided cost rates computed using the IRP methodology as a
single project.
Second, configuring severaladjacentsets of wind turbines so that each set is at least a
mile apar in order to qualify under PURP À as separate QFs forces inefficient turbine layouts.
Such patchwork development fails to optimally' utilze the available wind resource.
Third, large wind proj ects that are structured' as multiple 10 aMW facilties become
eligible for guaranteed rates, therefore they do not have to compete on price with other non-QF
projects that may be bid in utilty RFPs. Historically, Idaho's published rates have exceeded
rates paid to projects selected in utilty RFP processes.
Finally, utilties are forced to acquire generation from large wind QFs at standard rates
regardless of the utilty's need for new generation. Although Idaho Power and PacifiCorp have
near-term capacity needs, neither Idaho Power, Avîsta nor PacifiCorp has a near-term need for
energy resources? Forcing utilties to acquire generation they do not need increases rates for
customers. Moreover, it negates the integrated resource planing process wherein a utilty's
needs can be appropriately matched with resources at the lowest cost. By default, PURP A 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,leaStcostls way, or that it is in the best interests of
ratepayers.
Staff supports the utilties' Petition seekihg.to:reduce the avoided cost eligibilty cap from
the curent 10 aMW to 100 kW. Staffis convinced that the problem described by the utilties in
their Petition is real and requires immediate attention by the Commission. There is clear
evidence in all three utilties' service terrtories that large wind projects are purosely 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. In addition, however,thèièare other issues such as those preliminarly
identified in prior workshops that need to be addressed, not the least of which is ownership of
Renewable Energy Credits (RECs). An immediate lowering of the eligibilty cap will relieve the
2 Because wind generation is intermittent and cannnt be called upon when needed, it is generally regarded to have
little or no capacity value. By contrast, a gas~firedpèaking resource, because it can be dispatched when needed and
not dispatched when not needed, is considered primarily a capacity resource. A base load resource is considered to
have capacity and energy value.
STAFF COMMENTS 5 DECEMBER 22,2010
pressure curently faced by the utilties to acquire new unneeded generation, while also allowing
time for other issues to be resolved.
An immediate lowering of the eligibilty cap wil simply limit the availabilty of the
published avoided cost rates. Projects larger than the cap can stil be developed under PURP A,
but they wil be required to have rates determined using the IRP methodology as a staing point
for negotiations.
The appropriateness of exempting non-wind QF projects from the reduced eligibilty cap
The Joint Petition proposes that the eligibilty cap for published rates be reduced pending
an investigation of numerous avoided cost issues, .and goes on to describe problematic issues
almost exclusively related to large wind projects. However, the Petition does not specify
whether a reduced eligibilty cap should apply. to only wind QFs. In comments submitted so far
in this case by intervenors and other interested paries, it has been suggested that because large
wind projects are the only types of projects causing concerns, that other resource types (e.g.,
hydro, wood waste, municipal waste, and biogas) should be exempted if the Commission decides
to grant the Joint Petition to lower the eligibilty cap from 10 aMW to 100 kW.
Although many of the issues identified by paries in prior workshops apply equally to all
resource types, Staff believes that those that are most problematic and most in need of immediate
attention pertain almost exclusively to wind. I~ ju~t the past two years, the Commission has
approved four large wind contracts, while 20 are now pending. Every one of the wind contracts
are for projects 10 aMW in size, with one exception having a nameplate capacity of 80 MW. In
that same time period, the Commission has approved seven contracts for biogas digesters at
dairies, varing in size from 1.5 to 4.5 MW. Two contracts for small hydro projects, both less
than one MW have been approved, while three others are curently pending - all less than 10
aMW. In addition, the Commission has approved one contract for a 10 aMW facilty to be
fueled by wood waste, and is curently presented with a 3.2 MW contract for a facilty at Ada
County's Hidden Hollow Landfill. Finally, one 10 aMW contract has been approved for a
photovoltaic project within the past two years.
While each resource type brings its 'own unique characteristics, few lend themselves to
being developed as large projects and disaggregated into 10 aMW pieces in order to qualify for
published avoided cost rates. Except for some unusual circumstances, wind and perhaps solar
are generally the only resources types that can be easily disaggregated into smaller projects.
STAFF COMMENTS 6 DECEMBER 22,2010
Because wind projects have been, by far, collectively the largest and most plentiful projects in
recent years, they represent the greatest immediatec()ncern for the utilties. Consequently, Staff
recommends that if the Commission grant~the Petition to lower the eligibilty cap, it apply its
decision only to wind projects.
Staff believes that PURPA allows the Commission to exercise discretion to lower the
eligibilty cap for published rates for wind only. FERC's rules implementing PURPA provide
that "standard rates for purchases"(i.e., published rates), "may differentiate among qualifying
facilties using various technologies on the basis of the supply characteristics of the different
technologies." Reference 18 CFR 292.304(c)(3)(ii). Staff believes it is a logical extension for
the Commission to be able to differentiate among technologies in determining eligibility for
specific rates. In fact, in Case No. IPC-E-05-22, when the Commission temporarily lowered the
eligibility cap for published rates, it applied the lowered eligibilty cap only to wind resources.
Order No. 29839.
The consequences of dividing larger windprojectsjnto 10 aMW projects to utilize the
published rate
The consequences of dividing, larger :wtnd projects into 10 aMW projects to utilze the
published rate are that the utilties and their rat~payers may end up paying more than is fair or
necessary for acquiring new resources and that the utilties wil be forced to acquire more new
resources than are needed. For most of the history ofPURPA development in Idaho, the primar
driver for new PURPA development was ,whether the published avoided cost rates were high
enough to cover the cost of the projects while stil allowing an attractive retur for investors. As
a result, the pace of new development, for the most par, increased or decreased with changes in
avoided cost rates. Now, however, avoided .cost rates represent just one of several revenue
streams for project developers. Federal and statetax policies have provided tremendous
incentives for new development. In addition, the advent of RECs has created another new
revenue stream that greatly increases the viabilty of new projects. Published avoided cost rates,
at least as currently computed, are no longer thethrøttle controllng new development because
they may not reflect either the true value or need for new generation.
Staff is convinced that something must.be done to address the concerns raised by the
Utilties in their Petition. Staff does notbelieve1,that the Commission contemplated receiving
comments on anything other than the three issues identified in the Notice of December 3,2010.
STAFF COMMENTS 7 DECEMBER 22,2010
Nevertheless, Staff believes that, should the Commission grant the Utilties' Petition to lower the
eligibilty cap to 100 kW, a longer-term solution must be found. Staff offers the following
comments in an effort to advance the process.
Long-term Alternatives
1. Lower the eligibilty cap indefinitely
One alternative is to lower the eligibilty cap indefinitely. This would require all
proposed projects that are larger than the cap to individually negotiate contracts with the utilty
using the IRP methodology as the starting point furråte negotiations. Although Staffhas no
objection to this method in principle, Staff has concerns about whether it could be successfully
implemented for small projects. First, the IRPmethodology requires use of a complicated,
proprietar production cost modeL. Developers would likely be suspicious of the model results,
and would be unable to replicate or verify the model output. Second, ruing a production cost
,
model for each proposed new project would not be a simple task that could be completed
quickly. Third, it could be difficult to justify different results for individual small projects,
which could in tur, lead to complaints about discrimination. Finally, requiring small projects to
negotiate contracts would defeat a longstanding objective of the Commission to minimize
negotiation costs and complexity for small projects.
Another option would be to lower the eligibilty cap indefinitely to some level between
10 aMW and 100 kW. For example, the cap could be lowered to 5 aMW to allow relatively
small projects to continue to be eligible for published rates, but force large projects to negotiate
rates based on the IRP methodology. Large wind projects could stil disaggregate into smaller
projects for puroses of qualifying for published rates, but it would be much more diffcult for
them to do so.
2. Re-visit past avoided cost computation methodology to take the need for new generation
into account
Prior to 2002, avoided cost computations took into account each utility's "surplus period",
i.e., that period of time until the utility's load-resource balance indicated a need to acquire new
resources. During the surlus period, avoided cost rates were based on estimated market prices,
and after the surlus period, rates were based onthe costs of a combined cycle combustion
turbine. This practice was abandoned in Case No. GNR-E"'02-1 (reference Order No. 29124)
STAFF COMMENTS 8 DECEMBER 22,2010
because, among other reasons, the difficulty in defining and measuring "surlus period",, ¡ .
administrative burdens, minimal impact on rates, and extreme variations in market prices.
Nevertheless, despite its difficulties, consideration of a surlus period had merit because
it recognized that power sold to the utility during its surlus period had less value. Perhaps a
similar method should be reconsidered if the benefits of the method outweigh the difficulties.
This concept has been recognized by FERC in its rules implementing PURP A as
reflected in the excerpt below:
A qualifying facility may seek to nave a utilty purchase more energy or
capacity than the utilty requires to meet it~ total system load. In such a case,
while the utilty is legally obligatedto1purchase any energy or capacity
provided by a qualifying facilty, the purchase rate should only include
payment for energy and capacity which the utilty can use to meet its total
system load. These rules impose no requirement on the purchasing utilty to
deliver usable energy or capacity to another utilty for subsequent sale.
(Reference FERC Order No. 69 Docket NO.RM79..55 Small Power Production and
Cogeneration Facilties; Regulations ¡mpi~mentingSection 210 of the Public Utilty Regulatory
Policies Act of 1978; § 292.303 Electric utility obligations under this subpart; Federal Register,
Vol. 45, No. 38, Monday February 25, 1980, p.12219).
Based on the above FERC guidance, Staff believes it could be successfully argued that power
offered for sale to the utilty during its surlus period has no value, and that the utilty has no
obligation to resell the capacity or energy that it does not need.
3. Implement a five-mile separation rule
As discussed earlier, many paries including Staff, believe that the utilties' concerns are
primarily with large wind projects, specifically those that choose to reconfigure themselves into
multiple legal entities in order to qualify for published avoided cost rates. FERC rules
implementing PURP A require facilties to be located at least one mile apar in order to be
certified as separate QFs. Reference, 1 8 CFR 292.204(a)(2). The Commission, in prior cases,
has ruled that project developers are entitled to one power sales agreement for each QF
certificate issued by the FERC. Reference Order No. 26772. Consequently, by disaggregating a
large project into several small ones, it is easily possible to qualify for published rates regardless
STAFF COMMENTS 9 DECEMBER 22, 2010
of the collective size of the projects, and essentially render the Commission's 10 aMW eligibilty
cap meaningless.
In an attempt to address the disaggregation issue, a proposal effectively limiting QFs with
common ownership from being located closerthanfive miles of each other in order to be eligible
to receive published rates was made by Idaho Power in Case No. IPC..E-07-04. Although Staff
supported the intent of the proposed rules, it recommended denial of the Company's proposal,
believing that project developers would devise ways to circumvent the proposed rules. Staff
stated its belief that it would be bad policy to adopt a new rule if there are serious doubts from
the beginning about whether it wil actually achieve its intended objective.
The Commission denied Idaho Power's Petition stating that published rates were not
necessarily a more accurate representation of the value ofQF power than IRP-based rates, and
that no persuasive evidence had been presented demonstrating that the IRP methodology would
consistently produce avoided costs that are either higher or lower than the published rates. The
Commission stated fuher that "The Company, we find, has not convincingly demonstrated that
this calculated type of project reconfiguration is occuring in Idaho or that the present
requirements for published rate eligibility are now being or wil be abused by wind and
geothermal or other PURP A qualifying technolog¡'es~ ... we canot find that without change
abuse will occur and the public interest wil1not be served. It is a change that we find would
encourage and might actually promote gamesmanship." Reference Order No. 30415.
Rules requiring a five-mile separation for eligibilty for published rates, identical to those
proposed in Case No. IPC-E-07-04, have been adopted in Oregon and have been in place for
several years. To Staffs surrise, the rules seem to be effective in preventing disaggregation and
have not led to gamesmanship. However, Staff consulted with a FERC senior staff attorney,
asking specifically about whether rules such as those adopted in Oregon would be in conflct
with federal law. In the opinion of the attorney, a five-mile separation rule such as Oregon's
would likely not withstand legal challenges. Consequently, Staff is not prepared to propose
revisiting the same proposal made by Idaho Power in 2007 even though many circumstances
have changed. However, Staff would be wiling to fuher explore similar options if one can be
found that passes legal scrutiny and offers an effe,ctive means of addressing the disaggregation
issues raised in this case.
STAFF COMMENTS 10 DECEMBER 22,2010
4. Develop a new methodology for establishing avoided cost rates for large projects
If no other alternatives are considered viable, then perhaps a new methodology could be
developed for establishing rates for large projects. For example, in Case No. GNR-E-09-03, the
predecessor to this case, consideration was given to adoption of a "wind SAR" as a possible
means of establishing fair avoided cost rates for wind QFs while also addressing some of the
limitations of the current methodology. Staff developed a straw man proposal for a wind SAR,
but participants in a November 3, 2010 workshöp.did not offer enough support for continuing to
pursue the proposaL.
;;
Nevertheless, if paries in this case reach ån impasse in pursuing other alternatives,
perhaps satisfactory revisions to the wind SAR proposal could be made, or alternatively, a new
methodology could be devised. For example, a bidding or auction-based approach may be
desirable because it could effectively account for a utilty's need for new generation while relying
on competition to set prices. The details of any new methodology are critical, and would likely
take quite a bit of time to work out. Moreover, Staff believes that any methodology, regardless
of how well-intended or thought out, wil presentimplementation challenges that must be
resolved over time.
Should the Commission's decision apply to all three utilties?
Staff believes that decisions that the Commission makes regarding the Utilties' Petition
should be applied equally to Idaho Power, A vista, and PacifiCorp. In comments submitted so far
in this case, some paries have contended thatJdaho Power is the only utilty of the three with
serious issues that need to be addressed, that ~acifiCQrp's issues are minor, and that Avista has, . -', " :." \
few if any issues because no proposed wind projects were identified in the Utilties' Petition.
Staff disagrees. The Utilties' Petition identified existing projects and both signed and proposed
wind contracts, yet Staff is aware of less matue wind project proposals that were not included in
the Utilties' totals. Moreover, additional future project propoi;als are likely inevitable for all
three utilties. Regardless of the situation eacl;utilty is in now, the same issues wil be critical
for all three utilties going forward.
Staff believes that all of the three utilties are impacted by all of the issues identified in
previous workshops and that likely would be considered in futue proceedings. Staff also
believes that any change to the eligibilty cap for published rates would affect all three utilties
whether a revised cap is applied to them or not. If decisions regarding a revised eligibilty cap
STAFF COMMENTS 11 DECEMBER 22,2010
are not applied equally to all three utilties, project developers could simply shop for the utilty
with the most attractive rates and the highest eligibilty cap. With few if any exceptions, the
Commission has historically applìed its decisions in PURP A avoided cost proceeding equally to
all three utilties. Staff sees no reason to make an exception in this case.
STAFF RECOMMENDATIONS
Staff recommends that the Commission grant the Utilties' Joint Petition to Address
Avoided Cost Issues. Staff also recommends that while the investigation is underway, the
Commission lower the published avoided cost rat~ eligibilty cap from 10 aMW to 100 kW to be
effective as of December 14, 2010, the date identified in Order No. 32131. Furher, Staff
recommends that the eligibilty cap be lowered for wind resources only, and that the curent cap
of 10 aMW remain in place for all non-wind resources. The scope of issues to be addressed in
the investigation, Staff believes, should be broad, and include consideration of whether the
eligibility cap for published rates should be ~etat 100 kW, 10 aMW, or some other level going
forward. In addition, the investigation, should explore new methods for establishing fair and
reasonable avoided cost rates for wind QFs larger than the eligibilty cap for published rates.
1 '1 Nt,Respectfully submitted this ~ - day of December 2010.
~~~ (1. £i44U~
. . . stine A. Sasser
Deputy Attorney General
Technical Staff: Rick Sterling
i:umisc:commentsgnre 1 O.4ks _dh comments.doc
STAFF COMMENTS 12 DECEMBER 22,2010
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 22ND DAY OF DECEMBER 2010,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN CASE
NO. GNR-E-I0-04, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
DONOV AN E WALKER
LISA D NORDSTROM
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: dwalkert!idahopower.com
Inordstromt!idahopower .com
DANIEL E SOLANDER
ROCKY MOUNTAIN POWER
201 S MAIN ST STE 2300
SALT LAKE CITY UT 84111
B-MAIL: daniel.solandert!pacificorp.com
MICHAEL G ANDREA
A VISTA CORPORATION
1411 E MISSION AVE
SPOKANE WA 99202
E-MAIL: michael.andreat!avistacorp.com
PETER J RICHARDSON
GREGORY MADAMS
RICHARDSON & O'LEARY
515N 27TH STREET
BOISE ID 83702
E-MAIL: petert!richardsonandolear.com
gregt!richardsonandolear .com
ROBERT D KAHN
NW & INTERMOUNTAIN POWER
PRODUCERS COALITION
117 MINOR AVE STE 300
SEATTLE WA 98101
E-MAIL: rkaht!nippc.org
DON STURTEVANT
ENERGY DIRECTOR
J R SIMPLOT COMPANY
PO BOX 27
BOISEID 83707-0027
E-MAIL: don.sturevantt!simplot.com
ROBERT A PAUL
GRAND VIEW SOLAR II
E-MAIL ONLY:
robertapault!gmail.com
jA.MES CARKULIS
ENXERGYDEVELOPMENT GROUP OF
IDAHOLLC
802 W BANNOCK ST STE 1200
BOISE ID 83702
E-MAIL: jcarkulist!exergydevelopment.com
RONALD L WILLIAMS
WILLIAMS BRADBURY PC
1015 W HAYS ST
BOISE ID 83702
E-MAIL: ront!willamsbradbury.com
SCOTT MONTGOMERY
PRESIDENT
CEDAR CREEK WID LLC
668 ROCKWOOD DR
N SALT LAKE UT 84054
E-MAIL: scottt!westernenergy.us
CERTIFICATE OF SERVICE
DANA ZENTZ
VICE PRESIDENT
SUMMIT POWER GROUP INC
2006 E WESTMINSTER
SPOKANE WA 99223
E-MAIL: dzentzaYsumitpower.com
THOMAS H NELSON
RENEWABLE ENERGY COALITION
PO BOX 1211
WELCHES OR 97067
E~MAIL: nelsonaYthnelson.com
JOHNRLOWE
RENEWABLE ENERGY COALTIION
12050 SW TREMONT ST
PORTLAND OR 97225
E-MAIL: jravensanmarcosaYyahoo.com
R GREG FERNEY
MlMURA LAW OFFICES PLLC
2176E FRANKLIN RD
STE 120
MERIDIAN ID 83642
E-MAIL: gregaYmimuralaw.com
BILL PISKE MGR
INTERCONNECT SOLAR
DEVELOPMENT LLC
1303 E CARTER
BOISE ID 83706
E-MAIL: bilpiskeaYcableone.net
DEAN J MILLER
McDEVITT & MILLER LLP
PO BOX 2564
BOISE ID 83701
E-MAIL: joeaYmcdevitt-miler.com
PAUL MARTI
INTERMOUNTAIN WIND LLC
PO BOX 353
BOULDER CO 80306
E-MAIL:
paulmartinaYintermountainwind.com
WADE THOMAS
DYNAMIS ENERGY LLC
776 E RIVERSIDE DR
STE 15
EAGLE ID 83616
E-MAIL: wtomasaYdynamisenerg.com
SHELLEY M DAVIS
BARKER ROSHOLTET AL
STE 102
1010 W JEFFERSON ST
BOISE ID 83701
E-MAIL: smdaYidahowaters.com
BRAIN, OLMSTEAD
GENERAL MANAGER
TWIN FALLS CANAL CO
PO BOX 326
TWIN FALLS ID 83303
E-MAIL: olmsteadaYtfcanaL.com
TED DIEHL
GENERAL MANAGER
NORTH SIDE CANAL CO
921 N LINCOLN ST
JEROME ID 83338
E-MAIL: nscanalaYcableone.net
ijILL BROWN CHAIR
BÖARD OF COMMISSIONERS
OF ADAMS COUNTY ID
PO BOX48
COUNCIL ID 83612
E-MAIL: d~brownaYfrontiernet.net
r~LQ2b.Y~SEêRY
CERTIFICATE OF SERVICE