20110427Avista Answer to Motion to Strike.pdf

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Avista Corporation's Answer to Motion to Strike Portions of the Direct Testimony
of Clint Kalich
IPUC Docket No. GNR-E-ll-Ol
Dear Ms. Jewell:
Please find enclosed for fiing an original and seven copies of Avista Corporation's
Answer to Motion to Strike Portions of the Direct Testimony of Clint Kalich for filing in the
above-referenced docket. Please let me know if you have any questions regarding this fiing.
Sincerely,/;.
Michael G. Andrea
Senior Counsel
Enclosures
cc: Service List
MICHAL G. ANREA (ISB No. 8308)
A vista Corporation
1411 E. Mission Ave., MSC-23
Spokae, W A 99202
Telephone: [phone]
michaeL. andrea CW avistacorp.com
RECEIVED
ioii APR 27 PH I: S9
Attorney for A vista Corporation
BEFORE TH IDAHO PUBLIC UTITS COMMSSION
IN THE MATTR OF THE COMMISSION'S )INVESTIGATION INO )
DISAGGREGATION AN AN )
APPROPRITE PUBLISHED AVOIDED )COST RATE ELIGffILITY CAP )
STRUCTU FOR PURA QUALIFING )FACILITffS )
)
)
)
CASE NO. GNR-E-ll-01
AVISTA CORPORATION'S
ANSWER TO MOTION TO STR
PORTIONS OF TH DIRCT
TESTIONY OF CLIN KAICH
Pursuant to Rule 57.03 of the Idao Public Utilities Commssion's ("IPUC" or
"Commssion") Rules of Procedure, A vista Corporation ("A vista") submits its answer to
Renewable Nortwest Project's ("RN") Motion to Stre Portons of the Direct Testimony of
Clint Kalch and fied in the above-referenced proceedng, in which the Nortwest and
Intermountan Power Producer's Coaltion ("NIPPC") joins ("Motion").
The issues set for ths phase of the proceedg include the Commssion's request for
information and investigation of a published avoided cost rate eligibilty cap strcture that
prevents disaggregation and includes "criteria within which small wind and solar QFs can obtan
a published avoided cost rate without allowing large QFs to obtan a rate that is not an accurate~,
reflection of a utility's avoided cost for such projects." Notice of Inquir, Notice of Intervention
Deadline, Notice of Scheduling, Notice of Techncal Hearng, issued Februar 25, 2011
Page - 1 AVISTA CORPORATION'S ANSWER TO MOTION TO STR PORTIONS OF
TH DIRCT TETIONY OF CLIN KACH
("Notice") at 3 (emphasis added). RN and NIPPC move to stre testimony that bear diectly
on issues set for ths proceeng-i.e., whether a published avoided cost rate eligibilty cap
strctue can be adopted by the Commssion that (1) allows QFs as large as 10 aM to tae
advantage of published avoided cost rates; (2) prevents disaggregation; and (3) does not alow
large QFs to obtan a rate that is not an accurate reflection of a utility's actual avoided cost for
such projects. See Notice at 3. RN and NIPPC generally seek to stre substatial portons of
Mr. Kalich's testiony that demonstrates that the current published avoided cost rate exceeds the
utility's actual avoided costs, which provides the economic incentive that is the priar drver
behind developers disaggregating their projects to tae advantage of those rates. Therefore, in
adopting any published avoided cost rate eligibilty cap strcture that provides published rates to
QFs as large as 10 aMW, it is importt that the Commssion be made aware that such high rates
are the drver of disaggregation. Furter, absent a modification to the published avoided cost
rates, there is signficant dager that raising eligibilty from the present 100 kW that wil allow
large QFs to tae advantage of published rates that do not accurately reflect the utility's actual
avoided costs.
RN and NIPPC also seek to stre testimony that demonstrates that QFs larger than 100
kW are "large" QFs and that the Commssion can satisfy its stated goals of (1) providing
published avoided cost rates to small QF projects, (2) preventing disaggregation, and (3)
ensuring that large QFs do not obta a rate that is not an accurate reflection of a utility's avoided
cost for such projects by retaning the 100 kW published avoided cost rate eligibilty cap.
The Kalich Testimony that RN and NIPPC seek to stre is squarely withn the scope of
the Commssion's request for information and investigation of a published avoided cost rate
eligibilty cap strcture that provides published rates to small QFs, prevents disaggregation and
Page - 2 AVISTA CORPORATION'S ANSWER TO MOTION TO STR PORTIONS OF
TH DIRCT TESTIONY OF CLIN KAICH
ensures that large QFs do not "obta a rate that is not an accurate reflection of a utility's avoided
cost for such projects." See Notice at 3. The Motion is without merit and, therefore, Avista
respectflly requests that the Commssion issue an order denying the Motion in its entity.
I. Background
On Februar 25,2011, the Commssion issued the Notice in the above-captioned
proceeng "seek(ing) information regarding criteria withn which small wind and solar QFs can
obtan a published avoided cost rate without allowing large QFs to obtan a rate that is not an
accurate reflection of a utilty's avoided cost for such projects" and specifically "solicit(ing)
"information and investigation of a published avoided cost rate eligibilty cap strcture that: (1)
allows small wind and solar QFs to avail themselves of published rates for projects producing 10
aMW or less; (2) prevents large QFs from disaggregating in order to obtain a published avoided
cost rate that exceeds a utility's avoided cost." Notice at 3. Pursuant to the Notice, diect
testiony and exhibits were due on March 25, 2011. Rebutta testiony was due on April 22,
2011. A techncal hearng is scheduled in ths matter for May 10, 2011.
On March 24, 2011, Avista submitted the Direct Testimony of Clint Kalich ("Kalch/
Direct") for filing in ths proceeding. On April 13, 2011, RN fied its Motion seeking to stre
substantial portons of the Kalich Direct on the sole ground that such portons "are outside the
scope of the present phase of ths proceedng(.)" Motion at 3. On April 14, 2011, NIPPC fied a
motion in which, in relevant par, it joined in RN's Motion. The portons of the Kaich Direct
that RN and NIPPC seek to stre bear diectly on the issues in ths proceeding. The Motion is
without merit and, therefore, should be denied in its entiety.
Page - 3 AVISTA CORPORATION'S ANSWER TO MOTION TO STR PORTIONS OF
TH DIRCT TETIONY OF CLIN KAICH
ll. Argment
As stated above, the Commssion has expressly requested "inormation and investigation
of a published avoided cost rate eligibilty cap strcture that: (1) allows small wind and solar
QFs to avail themselves of published rates for projects producing 10 aM or less; (2) prevents
large QFs from disaggregating in order to obta a published avoided cost rate that excees a
utility's avoided cost", and (3) that does not allow "large QFs to obtan a rate that is not an
accurate reflection of a utility's avoided cost for such projects." Notice at 3. The portons of Mr.
Kalich's diect testimony that RN and NIPPC seek to stre is diectly responsive to the
Commssion's request for information and investigation in ths proceedng.
A. Testimony Regarding the Published A voided Cost Rate to Be Used in a
Published A voided Cost Rate Eligibilty Cap Structure is Within the Scope of
this Phase of this Proceeding.
RN and NIPPC generally seek to stre broad portons of Mr. Kalich's testimony that
demonstrate that: (i) the current published avoided cost rate is too high; (2) such published
avoided cost rate provides the economic incentive that is drving developers to disaggregate their
projects to tae advantage of those rates; and (3) at a minimum, to prevent disaggregation, the
published avoided cost rate to be applied in any published avoided cost rate eligibilty cap
strctue that provides published rates to QFs as large as 10 aMW, must not excee the utilities'
actual avoided costs. Mr. Kalich's testimony regarding the published avoided cost rate that wil
be applied in any published avoided cost rate eligibilty cap strcture that may be adopted in ths
proceedng is clearly withn the scope of the Commssion's request for information regarding an
published avoided rate eligibilty cap strcture that prevents disaggregation and ensures that QFs
are not able to obtain a rate that excees the utility's actual avoided cost. See Notice at 3. Ths
is especially tre given that, as noted in the Kalich Direct, the economics associated with the
Page - 4 A VISTA CORPORATION'S ANSWER TO MOTION TO STR PORTIONS OF
TH DIRCT TESTIONY OF CLINT KAICH
current published avoided cost rate is a fundamenta drver of the disaggregation problem that the
Commssion is seeking to prevent in ths proceedng. See, e.g., Kalch Testiony at 6; see also
Notice at 3.
1. Page 5, Line 1 through Page 9, Line 23 of Mr. Kach's Direc
Testimony Should Not be Strcken.
RN and NIPPC seek to stre page 5, line 1 though page 9, line 23 of the Kalich Direct
on the ground that, "(t)his section of testiony argues that the current published avoided cost
rates are too high for varable energy resources, from the utility perspective. Accordingly, it is
beyond the scope of issues identified for consideration in ths proceeng." Motion at 3.
In ths section of the Kalich Direct, Mr. Kalich testifies that the varable energy resources
being constrcted by QF developers are fundaentaly different from a combined cycle
combustion turbine ("CCCT") and, as a result, the rate paid for such varable generation based
on a surrogate avoided cost CCCT does not approximate tre utility avoided costs for varable
generation resources. Kalich Direct at 5:1-6:8, 9:1-9:23. Mr. Kalich furter explains that
published avoided cost rates that excee the utilities' actual avoided costs is the fundamenta
drver of the disaggregation problem that the Commssion seeks to solve in ths phase of the
proceeng. Kalich Direct at 6:9-8:10. Mr. Kalich concludes that "if the Commssion
reestablishes a 10 aM eligibilty cap for published avoided cost rates, ths mismatch between
the published avoided cost rate and the utilities' actual avoided cost for a similar resource is the
theshold issue that must be addressed to solve Idao's PURA issues-including
disaggregation." Kalch Direct at 8:6-8:10. Any argument that such testimony, which is on the
centr element of any published avoided cost rate eligibilty cap strctue-i.e., the published
avoided cost rate to be used in that strcture-is not withn the scope of the Commssion's
Page - 5 AVISTA CORPORATION'S ANSWER TO MOTION TO STR PORTIONS OF
TH DIRCT TESTIONY OF CLIN KAICH
request for information "of a published avoided cost rate eligibilty cap strcture" is without
merit.
1
2. Page 10, Line 20 through Page 22, Line 10 of Mr. Kach's Direct
Testimony Should Not be Stricken.
RN seeks to stre page 10, line 20 though page 22, line 10 of the Kalich Testimony on
the ground that, "(t)his section of text argues that current published avoided costs result in
exorbitat profits for wind developers. Accordingly, it is beyond the scope of issues identified
for consideration in ths proceedng." Motion at 3. Again, any asserton that testimony
regarding a central element of any published avoided cost rate eligibilty cap strcture-i.e., the
published avoided cost rate to be applied in such strcture-is without merit. Ths is especialy
tre here, where the profits developers derive from the curent published avoided cost rate
provides the economic incentive to disaggregate large projects into smaller QF projects.
In ths porton of testiony that RN and NIPPC seeks to stre, Mr. Kalich testifies that
changing the published rate paid for QF resources is essential to preventig disaggregation.
Kalich Direct at 10:20-11:23. Mr. Kalich furter provides testiony regarding the history of
wind development in Idaho to demonstrate that economics has been, and continues to be, the
principle drver of such wind development. Kalich Direct at 12: 122: 10. Mr. Kalich's testimony
1 A vista notes that the Motion sweeps into its request to stre ths section of the Kalch
Dirt page 8, lines 11-22. Ths section of the Kalich Dirct does not, as the Motion asserts
"argue( ) that the current published avoided cost rates are too high for varable energy resources,
from the utility perspective." Motion at 3. Rather, ths porton of the Kalich Direct is diected at
the fact that projects as large as 10 aM have a price tag of $60 millon or more and, therefore,
canot faily be characterized as "small" QFs for which published rates are necessar in order to
simplify the contracting process. See Kalich Direct at 8:11-22. RN does not provide any basis
for moving to stre this porton of the Kalich Direct. To the extent the Motion can be read to
suggest that ths porton is beyond the scope of ths proceeding (Motion at 3), such suggestion is
without merit. As discussed in the Kalich Direct, applying the eligibilty cap to projects as large
as 10 aM is both unnecessar and is a fundaental drver of the disaggregation problem that is
at issue in ths proceeding. See, e.g., Kalich Direct at 8: 11-22.
Page - 6 AVISTA CORPORATION'S ANSWER TO MOTION TO STR PORTIONS OF
TH DIRCT TETIONY OF CLIN KACH
demonstrates that, under the current published avoided cost rate, "(a) 10 aM wind project is
being overpaid by approximately $63 millon over 20 year." Kalich Direct at 21:19-20.
Ths testimony is diectly responsive to the Commssion's request for information on a
published avoided cost rate eligibilty cap strcture that both prevents disaggregation and ensures
that "large QFs (are not allowed) to obtan a rate that is not an accurate reflection of a utility's
avoided cost for such projects." See Notice at 3. Overpayment by utilities for varable resource
projects as large as 10 aM as a result of published avoided cost rates that do not accurately
reflect the utility's actual avoided costs provides a strong economic incentive, and is the primar
drver, for developers to disaggregate their projects in order to tae advantage of those published
rates. Accordingly, if the Commssion (1) adopts any published avoided cost rate eligibilty cap
strcture that allows QFs as large as 10 aM to tae advantage of published rates and (2) hopes
to both prevent disaggregation and ensure that QFs are not obtaning a rate that is not an accurate
reflection of the utility's avoided cost, the Commssion must as a theshold matter ensure the
published avoided cost rate that wil be applied in that strcture accurately reflect the utilities'
tre avoided costs. See Notice at 3; e.g., Kalich Direct at 8:6-10 (stating "if the Commssion
reestablishes a 10 aM eligibilty cap for published avoided cost rates, ths mismatch between
the published avoided cost rate and the utilities' actual avoided cost for a similar resources is the
theshold issue that must be addressed to solve Idaho's PURA issues-including
disaggregation."). RN's and NIPPC's motion to stre testimony on the centr theshold issue
in ths phase of the proceedng should be denied.
Page - 7 AVISTA CORPORATION'S ANSWER TO MOTION TO STR PORTIONS OF
TH DIRCT TESTIONY OF CLIN KACH
3. Page 22, Line 11 through Page 30, Line 2 of Mr. Kalich's Direct
Testimony Should Not be Stricken.
RN and NIPPC also seek to strke the Kalich Direct that appears at (i) page 22, line 11
though page 24, line 19; (ii) page 24, line 20 though page 25, line 19; and (iii) page 25, line 20
though page 30, line 2 on the grounds that, these sections argue (1) "that an IR methodology is
more appropriate", (2) "that PURA rates have negatively impacted Avista's Customers", and
(3) "that the utility's need for resources should be reflected in avoided costs." Motion at 3-4. In
RN and NIPPC's view, these sections of testimony are "beyond the scope of issues identifed
for consideration in ths proceeng." Motion at 3-4. Such testimony is squarely withn the
scope of the issues set for ths phase of ths proceeding. The Motion to stre ths testimony
should be denied.
Again, the Commssion has expressly requested information regarding a published
avoided cost rate eligibilty cap strcture that prevents disaggregation and does not provide large
QFs a published avoided cost rate that is not an accurate reflection of a utility's avoided cost.
Notice at 3. As discussed above, any published avoided cost rate eligibilty cap strcture that
provides published avoided cost rates to QFs as large as 10 aM, and both attempts to prevent
larger QFs from disaggregating to tae advantage of those rates and ensures that such strctue
does not provide QFs a published avoided cost rate that does not accurately reflect the utility's
actual avoided cost, must, as a theshold matter, include a published avoided cost rate that
reflects the actual avoided costs of the utilities.
In these sections of the Kalich Dirt, Mr. Kalich testifies about the nee to modfy the
current SAR methodology that is used to set published avoided cost rates to ensure that the
published avoided cost rates reflect actual avoided costs. Kalich Testiony at 22: 11- 25: 19.
Based in large par on ths testimony, Mr. Kalich concludes that "the best means to determne
Page - 8 AVISTA CORPORATION'S ANSWER TO MOTION TO STR PORTIONS OF
TH DIRCT TESTIONY OF CLIN KAICH
actual avoided costs in the current environment is to calculate the value of the PURP A
development using the IR Methodology."i Kalch Direct at 24: 17-19. Finally, Mr. Kalich
testifies that avoided cost rates should consider utility need. Kalich Dirct at 25:20-30:2. Mr.
Kalich's testimony is squarely withn the scope of the Commssion's request for information
regarding a published avoided cost rate eligibilty cap strcture that attempts to prevent
disaggregation and also does not provide QFs a published avoided cost rate that does not reflect
the utility's actual avoided cost. See Notice at 3. The Motion is without merit and, therefore,
should be denied.
B. Testimony on An A voided Cost Rate Eligibilty Cap Structure That Provides
Published Avoided Cost Rate to Small QFs and Satisfies the Commission's
State Goals of Preventing Disaggegation and Ensuring the A voided Cost
Rate Provided to Large QFs Accurately Reflects the Utilty's A voided Cost is
Within the Scope of this Preeding.
RN and NIPPC seek to stre the Kalich Direct at page 34, line 10 though page 41, line
17 on the ground that, the Commssion is seeking only "information on possible ways single
PUR A projects of up to 10 aM could receive published rates while preventing disaggregation
of larger projects" and that the Commssion "did not invite pares to reargue the theory that 100
KW is a better cap for rate eligibilty purposes." Motion at 4. Accordingly, in RN and
i To the extent that RN and NIPPC rely on the Commssion's bench order issued on
March 23, 2011 ("Bench Order"), to support the Motion, such reliance is misplaced. The Bench
Order granted a protective order prohibiting discovery on issues regarding the validity of the IR
Methodology. See Minutes of Decision Meeting, March 21, 2011 (Commssion Smith stating
that she did not believe the validit~ of the IR methodology is an issue the Commssion
designated for hearng on May 10 ). A vista acknowledges that the IR Methodology is an
accepted and approved methodology. In that light, the Kalich Direct does not in any way
question the validity of the IR methodology. Rather, in the context of testimony regarding how
to ensure that QFs are not able to obtan a published avoided cost rate that does not accurately
reflect the utility's actual avoided cost (an issue expressly set for ths phase of ths proceedng),
the Kalich Direct asserts that the IR Methodology is a fai way to ensure comparabilty between
the published avoided cost rate and the costs associated with resources the utilities would build
and own or otherwise acquire. See Kalch Direct at 22:13-24:19. Such testimony is withn the
scope of ths phase of ths proceeng.
Page - 9 AVISTA CORPORATION'S ANSWER TO MOTION TO STR PORTIONS OF
TH DIRCT TETIONY OF CLIN KAICH
NIPPC's view, ths section of testiony is "beyond the scope of issues identified for
consideration in ths proceeng." Motion at 3-4. RN and NIPPC read the Notice initiating ths
proceedng too narowly.
The Commssion expressly reuested "information and investigation of a published
avoided cost rate eligibilty cap strcture that: (1) allows small wind and solar QFs to avail
themselves of published rates for projects producing 10 aM or less; (2) prevents large QFs
from disaggregating in order to obtan a published avoided cost rate that excees a utility's
avoided cost", and (3) that does not allow "large QFs to obtan a rate that is not an accurate
reflection of a utility's avoided cost for such projects." Notice at 3. Mr. Kalich testifies that "(i)t
is very unlikely that the Commssion wil be able to adopt a PUR A eligibilty cap strcture that
both allows wind and solar QFs as large as 10 aMW to avail themselves to published rates and
also prevent disaggregation." Kalich Direct at 10. In support of that position, Mr. Kach cites,
as an example, the fact that a 65 MW wind project was able to successfully disaggregate to tae
advantage of Oregon's published avoided cost rates even though Oregon had both a signficantly
lower eligibilty cap (10 MW in Oregon as compared to 10 aM in Idaho) and a five-mile
separation requirement. Kalich Direct at 32: 10-33: 12. Mr. Kalich furter testifies:
As the example discussed above ilustrtes, developers can come up with very
imaginative ways to disaggregate and still comply with even very strct requirements to
prevent such disaggregation. It is impossible to foresee the varous ways that developers
may come up with to circumvent the intent of the eligibilty cap by disaggregating their
projects. Additional requirements regarding ownership, sharng of equipment and
interconnection facilties, and project separation rules might help, but they wil be very
diffcult for utilities, and ultimately ths Commssion, to monitor and enforce. A vista is
concerned that such additional requirements wil lead to additional litigation that wil
require substantial time and resources in order to enforce the intent of the published
avoided cost rate eligibilty cap. More importtly, to the extent that developers are able
to require utilities to pay rates above the utilities' actual avoided costs for large QF
projects, the utilities' actual avoided costs for large QF projects, the utilities' customers
wil shoulder the burden of those costs though higher retal rates.
Page - 10 AVISTA CORPORATION'S ANSWE TO MOTION TO STR PORTIONS OF
TH DIRCT TESTIONY OF CLIN KAICH
Kalich Direct at 33: 15-34:5.
In sum, in diect response to the Commssion request for information and investigation,
Mr. Kalich testifies that it is virually impossible, or at best extremely diffcult and burdensome,
to adopt a published avoided cost rate eligibility cap strcture that provides published rates for
projects as large as 10 aM and also both prevent large QFs from disaggregating and prevent
large QFs from obtaining a published avoided cost rate that does not reflect the utility's actual
avoided cost. See, e.g., Kalich Direct at 10:1-19, 33:15-34:5; Notice at 3. A fundamenta reason
why such a strctue is unlikely to be successful is the incorrect premise that wind and solar
projects as large as 10 aM are "smalL." Mr. Kalich's testimony demonstrates that such projects
canot faily be characterized as "small" such that it is necessar to provide such projects
published avoided cost rates. Kaich Direct at 35:5-37:2 (discussing the costs of developing
varous resources and testifying that "10 aM wind or solar projects are not small QFs."
(Emphasis in original.)). With that understading, Mr. Kalich offers an alternative approach-
i.e., retaning the 100 kW eligibilty cap-that can satisfy the Commssion's stated goals of (1)
providing published avoided cost rates to small QFs, (2) preventing disaggregation, and (3)
ensuring that large QFs are not allowed to obtan a rate that is not an accurate reflection of a
utility's avoided cost for such projects. See Notice at 3. Ths testiony is withn the scope of
ths proceedng and, therefore, the Motion should be denied.
c. Exhibit 101 to the Kalich Direct Should Not Be Strcken
Finally, RNP and NIPPC seek to stre Exhbit 101 to the Kalch Direct. In RN and
NIPPC's view, "(t)he generation patterns of (a photovoltac solar facility) are irelevant to the
issues identified in the Notice, and accordingly ths exhibit is beyond the scope of issues
Page - 11 AVISTA CORPORATION'S ANSWER TO MOTION TO STR PORTIONS OF
TH DIRCT TETIONY OF CLIN KAICH
identified for consideration in ths proceeding. Motion at 4. RN and NIPPC's request to stre
Exhbit 10 1 is without merit and should be denied.
As discussed more fully above, and in the Kalich Direct, the published avoided cost rate
to be applied in any published avoided cost rate eligibilty cap strcture is very much at issue in
this proceeng. See Notice at 3 (expressly seeking information and investigation on criteria to
ensure that QFs do not receive a rate that does not reflect the utility's actual avoided cost). Mr.
Kalich explains that the issue with the current SAR methodology for setting those rates is that
varable energy generating resources, including solar resources, do not have the same
characteristics and attbutes as the current combined cycle combustion turbine surrogate avoided
cost resource that is currently used to establish the published avoided cost rate. E.g., Kalich
Direct at 5: 1-6:8, 10:22-11 :6, 22: 13-23:5. Accordingly, the characteristics of solar resources is
relevant to, and therefore withn the scope of, ths proceeng. The Motion to strke Exhbit 101
should be denied.
Page - 12 AVISTA CORPRATION'S ANSWER TO MOTION TO STR PORTIONS OF
TH DIRCT TESTIONY OF CLIN KAICH
ILL. Conclusion
As discussed herein, the portions of the Kalich Direct that RN and NIPPC seek to stre
are well withn the scope of the Commssion's request for information and investigation of a
published avoided cost rate eligibilty cap strcture that prevents disaggregation and includes
"criteria withn which small wind and solar QFs can obtan a published avoided cost rate without
allowing large QFs to obtan a rate that is not an accurate reflection of a utility's avoided cost for
such projects." Notice at 3. Accordingly, Avista respectfully requests that the Commssion issue
an order denying the Motion in its entiety.
Respetflly submitted by,
AVISTA CORPORATION
n
Michael G. Andrea
Attorney for A vista Corporation
Dated: April~, 2011
Page - 13 AVISTA CORPRATION'S ANSWER TO MOTION TO STR PORTIONS OF
TH DIRCT TETIONY OF CLIN KAICH
CERTIFCATE OF SERVICE
I hereby certfy that on ths 26th day of April 2011, tre and correct copies of
AVISTA CORPORATION'S ANSWER TO MOTION TO STR PORTIONS OF TH
DIRCT TETIONY OF CLIN KAICH were delivered to the following persons via
Emal (unless otherwise indicated).
Jea Jewell
Idaho Public Utilities Commssion
472 W. Washington St.
Boise, ID 83702
Email: jean.jewell CWpuc.idaho.gov
(via Email and Overnght Mail)
Dean J. Miler, Esq.
McDevitt & Mier, LLP
POBox 2564
Boise, ID 83701-2564
joeCW mcdevitt -miller. com
Danel E. Solander
Senior Counsel
Rocky Mountan Power
201 ~. Main Street, Suite 2300
Salt ¡Lae City, UT 84111
Email: DaneLsolanderCWpacificorp.com
Donovan E. Waler
Lisa' Nordstrom
Idaho Power Company
POBox 70
Boi~e, ID 83707-0070
Ema: dwalerCWidahopower.com
lnordstrom CWidaopower.com
Pag~ 1--ERTIFCATE OF SERVICE
Donald L. Howell, II
Krs Sassar
Deputy Attorneys General
Idaho Public Utilities Commssion
472 W. Washington St.
Boise, ID 83702
Emal: don.howell CWpuc.idao.gov
krs.sassarCWpuc.idao.gov
Peter Richardson
Gregory M. Adams
Richardson & O'Lear
515 N. 27th St.
PO Box 7218Boise, ID 83702
Email: peterCWrichardsonandolea.com
greg CW richardsonandolear .com
Magan Walseth Decker
Senior Sta Counsel
Renewable Nortwest Project
917 SW Oak St., Suite 303
Portand, ()R 97205
Email: meganCWrnp.org
R. Greg Ferney
Mimur Law Offices, PLLC
2176 E. Franin Rd., Suite 120
Meridian, ID 83642
Email: gregCWmiuraaw.com
Ted S. Sorenson, P.E.
Sorenson Engieering, Inc.
5203 South 11th East
Idaho Falls, ID 83404
Emai: tedCWtsorenson.net
Glenn Ikemoto
Margaret Ruger
Idaho Windfars, LLC
672 Blai Ave.
Piedmont, CA 94611
E-mail: glennCWenvisionwind.com
MargaretCWenvisionwind.com
Shelley M. Davis
Barker Rosholt & Simpson, LLP
1010 W. Jefferson St., Ste. 102
P.O. Box 2139
Boise, ID 83701-2139
Emai: smdCWidaowaters.com
Paul Marn
Intermountan Wind, LLC
POBox 353
Boulder, CO
Email:
paulmarn CWintermountainwind.com
Ronald L. Willams
Willams Bradbury, P.C.
1015 W. Hays St.
Boise ID, 83702
Email: ronCWwillamsbradbur.com
Dana Zentz
VP, Summt Power Group, Inc.
2006 E. Westmster
Spokae, W A 99223
Email: dzentzCWsummtpwer.com
Page 2-CERTIFICATE OF SERVICE
Robert D. Kah
Executive Director
Nortwest and Intermountain Power
Producers Coaltion
1117 Minor Ave., Suite 300
Seattle, W A 9810
Email: rkahnCWnippc.org
Thomas H. Nelson
Attorney for Renewable Energy Coaltion
PO Box 1211
Welches, OR 97067-1211
Email: nelsonCWthelson.com
Bil Piske, Manager
Interconnect Solar Development, LLC
1303 E. Carer
Boise, ID 83706
Email: bilpiskeCWcableone.net
Bil Brown, Chai
Board of Commssioners of Ada County,
Idaho
PO Box 48
Council, ID 83612
Email: bdbrownCWfrontiernet.net
Scott Montgomery
President, Cedar Creek Wind, LLC
668 Rockwoo Drve
Nort Salt Lae, Uta 84054
Email: scottCWwesternenergy.us
Wade Thomas
General Counsel, Dynams Energy
776 E. Riverside Drive, Suite 15
Eagle, ID 83616
Email: wtomasCWdynamsenerg.com
James Carkulis
Managing Member
EXERGY DEVELOPMENT GROUP OF
IDAHO,LLC
802 West Banock Street, Ste. 1200
Boise, Idaho 83702
Emal:jcarkulisCWexergydevelopment.com
JohnR. Lowe
Consultat to Renewable Energy
Coaltion
12050 SW Tremont Street
Portand, OR 97225
Email: jravenesancosCWyahoo.com
Twin Falls Canal Company
c/o Brian Olmstead, Genera Manager
P.O. Box 326
Twin Falls, Idao 83303-0326
Email: olmsteadCWtfcanal.com
Ken Kaufman
Lovinger Kaufmann, LLP
825 NE Multnomah, Suite 925
Portand, OR 97232
Email: KaufmannCWlkaw.com
Aron F. Jepson
Blue ribbon Energy LLC
10660 South 540 Eat
Sandy, UT 84070
Email: aronesq CW aoLcom
Page 3-CERTIFCATE OF SERVICE
Robert A. Paul
Grand View Solar IT
15960 Vista Circle
Desert Hot Sprigs, CA
Email: robertpaul CW gmaiLcom
Don Sturtevant
Energy Director
J. R. Simplot Company
ONE CAPITAL CENTR
999 Main Street, P.O. Box 27
Boise, Idaho 83707-0027
Emai: don.stuevantCWsimplot.com
Nort Side Canal Company
c/o Ted Diehl, General Manager
921 N. Lincoln St.
Jerome, Idaho 83338
Email: nscanalCWcableone.net
MJ Humphres
Blue Ribbon Energy LLC
4515 S. Amon Road
Amon, ID 83406
Email: blueribbonenergy CW gmaiLcom
Greg Seifert
Kurt Meyers
Idaho National Laboratory
Conventional Renewable Energy Group
2525 Fremont Ave.
Idaho Falls, ID 83415-3810
Email: gar.seifertCWinLgov
Kur.myersCWinLgov
Benjam J. Otto
Idaho Conservation League
710 N. 6th St.
P.O. Box 844
Boise, Idaho 83702
Ph: [phone] x 12
Fax: [phone]
Email: bottoCWidaoconservation.org
Page 4-ERTICATE OF SERVICE
Ken Miler
Clean Energy Program Director
Snake River Alance
Box 1731
Boise, 10 83701
Email: kmllerCW staeriveralance.org
~
Michael G. Andrea