20110422Reading Reb.pdf

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RËCEIVED
2Ul1 APR 22 PH~: 39
ATTORNEYS AT LAW
Tel: [phone] Fax: [phone]
P.O. Box 7218 Boise, ID 83707 - 515 N. 27th St. Boise, ID 83702
April 22, 2011
Ms. Jean Jewell
Commission Secretar
Idaho Public Utilities Commission
472 W. Washington
Boise, ID 83702
RE: Case No. GNR-E-ll-Ol
Dear Ms. Jewell:
We are enclosing for filing in the above-referenced case nine (9) copies of the REBUTTAL
TESTIMONY OF DON READING fied on behalf of THE NORTHWEST AND
INTERMOUNTAIN POWER PRODUCERS COALITION IN OPPOSITION TO ROCKY
MOUNTAIN POWER'S MOTION FOR CLARFICATION AND MOTION FOR
PROTECTIVE ORDER. An additional copy is enclosed for you to stap for our records. I
have also enclosed a CD-ROM containing the electronic copies of the testimony and exhibit for
the cour reporter.
i;~Richardson & O'Lear PLLC
encL.
RECEfVED
201 i APR 22 PM 4= 39
Peter J. Richardson (lSB No. 3195)
Gregory M. Adams (lSB No. 7454)
RICHARDSON & O'LEARY, PLLC
515 N. 27th Street
P.O. Box 7218
Boise, Idaho 83702
Tel: [phone]
Fax: [phone]
peter(frichardsonandoleary.com
greg(frichardsonando leary.com
Attorneys for Northwest and Intermountain
Power Producers Coalition
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE
COMMISSION'S INVESTIGATION
INTO DISAGGREGATION AND AN
APPROPRITE PUBLISHED
AVOIDED COST RATE ELIGIBILITY
CAP STRUCTUR
Case No. GNR-E-ll-Ol
REBUTTAL TESTIMONY AND EXHIBITS OF
DR. DON READING
ON BEHAF OF
NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION
APRIL 22, 2011
1 Q. Please state your name, address, and affliation.
2 A. My name is Don Reading. I am Vice President and Consulting Economist for
3 Ben Johnson Associates, 6070 Hil Road, Boise Idaho. My resume is attched as Exhibit 401.
4 Q. On whose behalf are you testifying?
5 A. I am testifying on behalf of the Northwest and Intermountain Power Producers
6 Coalition (NIPPC) which is a party to this proceeding. NIPPC is an association of independent
7 power producers established to actively pursue informal and formal (i.e., laws, policies, rules and
8 regulations) avenues and forums to promote competitive electric power supply markets in the
9 Pacific Northwest and Intermountain West. NIPPC supports a fully competitive electric power
10 supply marketplace. Among NIPPC's 15 members and 11 associate members are some of the
11 major independent energy producers in the county. The member companies' energy projects that
12 are currently on-line have a capacity of more than 4,000 MW in the Nortwest.
13 Q. What is the purpose of your rebuttal testimony?
14 A. I point out that some of the recommendations made by several parties go
15 beyond the scope of this proceeding. In addition, I address implementation and real world
16 problems associated with the recommendations of other parties.
17 Q. Why did NIPPC not fie direct testimony?
A. NIPPC did not fie direct testimony because NIPPC does not believe that the18
19 current methodology used by the Commission needs to be changed. Therefore, it would not have
2 0 been productive for NIPPC to fie testimony on how it should be changed.
21 Q. Why do you believe the current system for eligibilty for the published rates
22 does not need to be changed?
Reading, Reb
NIPPC
GNR-E-II-01
2
1 A. The "problems" identified by the three investor-owned utilities is that projects
2 are actually employing the methodology set up by the Commission for determining eligibilty for
3 published avoided cost rates. It is not a bad thing to comply with this Commission's orders and
4 standards. The result is that a large number of projects have been able to utilize the current
5 system to successfully build wind projects.
6 Q. Would you agree that the use of disaggregation is a problem?
7 A. Not necessarily. Utilities and their ratepayers should be indifferent to a project
8 that is disaggregated or one that is aggregated - as long as the avoided cost rates are accurately
9 set. So I believe this entire case is focused on the wrong "problem."
10 Q. What is your understanding of the proper scope of this proceeding?
A. Staff witness Sterling has done a good job in his description the proper scope of11
12 this proceeding. On page 5 of his direct testimony he quotes from Order No. 32195 and
13 concludes that his testimony would be narrowly focused on the two questions raised by the
14 Commission. He also properly concluded on page 6 that "Issues related to the appropriateness or
15 accuracy of either the Surrogate Avoided Cost Resource methodology (SAR methodology) or the
16 Integrated Resources Plan Methodology (lRP methodology) wil be addressed in subsequent
17 proceedings." I do not necessarily agree with the premise that the question of disaggregation and
18 the validity of the avoided cost methodology are distinct such that they can be addressed
19 separately. Nevertheless, the Commission has, for purposes of this phase of its ongoing
20 investigation, strictly limited the paries to just the two questions of how to devise a methodology
21 that "(1) allows small wind and solar QFs to avail themselves of published rates for projects 10
Reading, Reb
NIPPC
GNR-E-II-0l
3
1 aMW or less; and (2) prevents large QFs from disaggregating in order to obtain a published
2 avoided cost rate that exceeds a utilty's avoided cost."
3.Q. Have you reviewed the testimonies fied by the three investor-owned
4 utilties, Rocky Mountain Power, Idaho Power and Avista?
5 A. Yes. All three recommend that the Commission adopt a permanent 100 kW size
6 threshold for wind and solar projects for entitlement to the published avoided cost rates. See Mr.
7 Griswold's testimony at page 2, Mr. Kalich's testimony at page 4 and Mr. Stokes' testimony at
8 page 3.
9 Q. What is your opinion with respect to the recommendation by the three
10 investor-owned utilties that the Commission restrict the availabilty of published avoided
11 cost rates to projects no larger than 100 kW.
12 A. Those recommendations simply ignore the Commission's directive in Order No.
13 32195 which clearly states that the paries are to provide testimony and propose a methodology
14 that "allows small wind and solar QFs to avail themselves of published rates for projects
15 producing 10 aMW or less." Ignoring the Commission's clear instructions, the investor-owned
16 utilties all recommend that small solar and wind QFs be restricted to only access published
17 avoided cost rates for projects 100 kW or less. They have disregarded the Commission's
18 instrctions with respect to recommending a methodology that "allows" small wind and solar to
19 have access to published rates up to 10 aMW.
20 Q. What is your response to the assertions by the investor-owned utilities that
21 it is not possible to devise a system that both allows access to avoided cost rates of up to 10
22 aMW and prevents disaggregation?
Reading, Reb
NIPPC
GNR-E-II-0l
4
1 I do not believe the investor-owned utilities are motivated to offer such a system for
2 the Commission's review. Certainly the other parties to this case were able to offer ideas on how
3 the Commission could accomplish its goals. I see no justification for why the investor-owned
4 utilties failed to do so by simply recommending a 100 kw eligibilty cap.
5 Q. Have you reviewed Staff Witness Sterling's direct testimony in this docket?
6 A. Yes, and I have some concerns about his recommendations.
7 Q. What are your concerns?
8 A. His Single Project Criteria in Staff Exhibit 301 are overly broad and vague.
9 Q. In what way are Stafls Single Project Criteria vague?
A. Staffs Exhibit lists fifteen separate indicia of what makes for a Single Project.10
11 That list is prefaced with the statement that the Commission wil consider "all relevant factors,
12 including but not limited to" the fifteen listed on Exhibit 301. Therefore, a developer cannot
13 know, going forward what other "relevant factors" may be used to determine whether or not his
14 or her project wil be aggregated for purposes of entitlement to published avoided cost rates.
15 That uncertinty is surely not going to engender a positive climate for developers investing
16 capital in QF projects. In addition, some of the specific items on the list are too vague to provide
17 clarity.
18 Q. Why did Mr. Sterling include as one of his criteria the phrase,"all relevant
19 factors, including but not limited to" and leave it to the Commission to settle disputes over
2 0 non-listed factors?
21 A. On page 9 of his direct testimony he states that "If a rigid set of criteria were to
22 be adopted, I believe that some project developers might devise ways to meet the criteria, yet
Reading, Reb
NIPPC
GNR-E-II-0l
5
1 violate their clear intent." I understand his concern. He also advocates the utilties make the
2 initial determination and go before the Commission only when there may be uncertainty or
3 disagreement between the project developer and the utilty. My concern is that it can also be the
4 utilty that can take advantage of the overly broad and vague criteria in order to stall or
5 discourage projects.
6 Q. Do you have any examples of items on the list that are vague?
7 A. Yes. Let's start with a real world example of how Staffs proposal wil play out.
8 Assume there are two landowners with adjacent properties and they each build a wind project on
9 their land. Assume further that each project is owned, conceived, built, financed and managed
10 completely independently of the other. Under Staffs proposal these two independent projects
11 would be subject to aggregation because they use the same motive force and they are in close
12 proximity to each other.
13 Q. Do you have other examples of the vagueness of Staffs list?
14 A. Yes. An indicia of a Single Project for Staff is if two wind projects use the
15 same general contractor. That fact alone would be sufficient to classify them as a single project
16 regardless of how distant and how unrelated the two projects really are. Given the relative small
1 7 universe of contractors in the specialized business of designing and constructing wind and solar
18 projects, the chances that a single contractor would work on more than one project in the state
19 are quite high.
20 Q. Do you have specific concerns with Stafls Criteria?
21 A. Yes. Only the terms "person" and "affliated person" are defined, leaving us to
22 speculate as to the meaning and applicabilty of the other terms in the list of Criteria. In Criteria
Reading, Reb
NIPPC
GNR-E-II-0l
6
1 "a" it is an indicia of common ownership if two projects use the "same motive force." That
2 could be interpreted to be as broad as just "wind." It would make no sense to define it that
3 broadly as there could be two wind projects hundreds of miles apart that are aggregated because
4 they both use wind to generate power. The same arguent could be made for use of the "same
5 fuel source." Two hydro projects on different streams both use hydro power as the fuel source.
6 Surely Staff doesn't mean to be so broad in the application of its criteria, but without specifically
7 defining each term as to how it is to be used there is simply too much room for mischief in
8 Staff s proposaL. The same criticism is applicable to the criteria on sharing common control,
9 communications and operations facilities - how granular one gets or how broad a view one takes
10 of sharing common communications and operations facilities can be subject to great variability.
11 Criteria "g" provides that two facilities are a single project if they have a contract executed
12 within twelve months of each other and are located "in the same general vicinity." It is
13 impossible to know what that means with any degree of certinty. The same criteria calls out a
14 "similar facility" that is in the same general vicinity. Exactly what a similar facility would be is
15 surely in the eye of the beholder. Are wind turbines of different sizes similar enough to be
16 ensnared in this definition / or are wind turbines manufactured by different companies similar
1 7 enough to be ensnared? Criteria "0" is particularly troubling. It provides for different projects to
18 be considered a Single Project if they are merely in close proximity to other similar facilties.
19 Staffs proposal, as written is simply unworkable.
20 Q. Do you have any comments on the Criteria on interconnections and
21 transmission?
Reading, Reb
NIPPC
GNR-E-II-0l
7
1 A. Yes. I believe that the Commission should be careful with recommendations
2 that allow investor;.owned utilties to inquire as to the status of interconnection facilty
3 agreements and transmission interconnection agreements as suggested by Staffs Criteria "d" and
4 "f." It is my understanding that utilities may be precluded from making such inquiries by
5 FERC's Standards of Conduct. But someone with a better understanding of that issue than I
6 have should probably be consulted on that topic.
7 Q. Do you have any comments on the Criteria relative to financing and
8 revenue arrangements of QF developers?
9 A. Again, the Commission should be careful with recommendations that allow
10 investor-owned utilities to inquire into the financial arrangements of QFs as I understand they are
11 exempt from those types of inquiries under PUR A. But, again someone with a better
12 understanding of that issue than I have probably should be consulted on this topic as well.
13 Q. Do you have any comments on the applicabilty of Staffs Criteria to non-
14 wind and non-solar project?
15 A. Yes. I was surrised to see that Staff recommends that its Criteria apply to all
16 projects not just wind and solar.
17 Q. Why were you surprised?
18 A. Because the Commission's order opening this docket was explicit in stating that
19 it only wanted testimony and comments on wind and solar. I was also surprise to read that Staff
20 wanted to extend the reach of its Criteria beyond wind and solar because in the opening pages of
21 his testimony Staff Witness Sterling cited to the Commission's order, stating that his "testimony
22 wil be very narrowly focused." (Sterling Direct at p. 5.)One, I believe, unintended
Reading, Reb
NIPPC
GNR-E-II-0l
8
1 consequence of expanding the coverage to all QFs and using Staff's Criteria would be that a
2 strong argument could be made that all dairy digesters in the Twin Falls area should be
3 aggregated as a Single Project. In addition, I think that non-wind and non-solar developers
4 would be surprised to see an order come out of this phase of the Commission's investigation that
5 subjects their projects to aggregation - given that the order opening this docket was limited to
6 just wind and solar.
7 Q. Do you have any comments on ownership restrictions?
8 A. I believe that such restrictions, if deemed appropriate by the Commission at the
9 time the power purchase agreement is in place, should be lifted at some point well before the end
10 of the contract term. This is important because such restrictions are nothing more than a restraint
11 on the owner's ability to sell his project should the need arÎse. Investors may want to consolidate
12 a number of smaller projects for the benefit of the landowners, financers or even for ease of
13 administration for the power purchase agreements.
14 Q. Does this conclude your testimony?
15 A. Yes it does.
16
Reading, Reb
NIPPC
GNR-E-II-0l
9
BEFORETBE
IDABOPUøLICUTILITItS COMMSSION
CASE NO. GNR-ii..Ol
NOaTBWEST. AND..INTERMOUNTAIN .POWERPRODUCERS
COALITION
READING, REB
TESTIM.ONY
EXHIBIT NO. 401
Dr. Doii Reading's. Curriculum. Vitae
P,.,ifl pui/i."
BiiU ali, 11
Hil n r Stu I
lIl1ltiris
Prøj. uii ."ai
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lJiJlo 'Y
DOl~~
Don C. Readi,
Vice Puitnt and Consulti Et onomist
B.S., Economics - Uta State Uniersty
M.S., Economic - Universit of Oregon
Ph.D., Bconomics- Uta State Univmity
Otic Del Epsiln. NSF Felowship
Be Johnson Associates, Inc.:
1989 u_ Vice Pæsident
1986 .... Consulti Economit
Idaho Public Utilåes Comision:
19fU ~86Economist/Dirc:tor of Poky and Administration
Teahirt
1980-81 Assoia Profesor, Univsity ofHàwa.Hilo
i 970.80 Asso and Assistat Ptofessor, Id aho State University
1968.70 As$Ítat PrfelSot, Middle Tennessee State U!Ucrty
/S:lt tl."alÀ. ReMiÚlpros expe tetionyconc~economîc..nd~toryissues.
Hl:hest'tiieoninoreth 3$ ocçaon sbc reutityrç~ty ci;Î$~onsin
~Sk~ Cålfo~ Colo~,.tleDistrçt.of Co lumpia Ha,., I~o. N evila,
North DaKoti Te~as, Utah. Wyomiiig,ed WasÏtigt()Q.
Dr. ae~hnmo1'tl$Ó3Q yeø ~en eeintheftetd of ~ijòmics.Heh.1l
parciptted .inthe deielopment of indices reflecting economic irens, GNP .grØW
ra.teìl fôrtisexchåige màikcts,the monty supply ,stodìnlltket lev_ls,md
infltion. He has anyzed such public policyissues as the mimum w&g, federal
s~ndiiigedtl.~iion,a.m.l import/export batces. Dr.Readn~is one .of four
econt)lXi~tsproviØigyea.rly fOrecasts of sta.tcWie. peuoiuincornetothe State of
.~òf¡)rp~s of uc.b1ishill$tate pers01alincom.e.tU. rates.
In th fid of telecornunicatins, Dr. Reaing has provided expen: tcsumony on
the i$Sue.s of rnaigal cost, price eltity, and meuured service. Dr. Reang
prepared a sraUl-specifc siuyof the pri:e elastcity of demand for loal telephone
serve in Idaho and recen~ conducted research for. and directed the preparatin
of. a repo tò ile Idaho legslate resuding ile Stall.l of te1com.municatinl
competion in that sute.
Eû.ibit No. 401
GNR.E-U-oi
RadÙlg,UB
'''..1
DoD C. J.cidiii&
Dr. Readings areas of expettsein the fild of electric power indidedemand
forecasting, long-range planníng, price elasucity, margina and averaconpiicin,
prpduction.simuluion modeling, and econometricmpdelitig. Among h.s t(:cnt
cases Wll. an c:leCttÎC tate design ..naysis for the Indusp:ial C~llpmets ofldahp
P0W't; Dr. Readitt8 is ~entlY' a eonsul~ttothe ItWo Legslature's Cpitinittte
ò!Ì JEle(ittitResttçtrin.
Since 1999 Dr. Readng hu been affiated with the Cliate Impact Group (CIG) at
the UniversityofWashiiigtn. His wom with me CIG has inwlved an analysis of
the impac t of Glob ai Wam g on the hy do facities on the Snake Ri er. It also
includes an investion into water markets in me Northwest and Florida. In
addimn he has malyzed me economics of snowmaking fOr ski area's impacted by
Global Warmng.
Among Dr. Reading's recent projec are a PERC hydropower reliec:nsing st!dy (ior
the Skokomsh Indian Tribe) ..nd an anaysis ofNorem Sta Poweù Nort
Dakota rate desig proposals affècting lage induStia cullometS (fOr l.R. SiinplOt
Company). Dr. Reading has alo perfonied anlysis for the Idao Govemor's
Office 0 f the impact on the N omwest Po wet Grid of varous plans to increae
salmon runs in the Columbia Rier Basin.
Dr. Reading has prepared econometì:£orecasror me $outheall ldaho Counci of
Govemiiu:nt$ and the R.evenue Pr:oje~on COmittee oEthe Id~p Staie~.latue.
He hasalo been a me mber of severo N orre$tP~r;Pl~~C()çUS~t.ql
AdYisory Cointtees and was vj(iecharmíì OftleGoveror'sEcanomic RCfs.eat'èli
Councilir Idaho
Whe at Idaho State U nívei:ity. Dr. Reading performed demogiaphic studies usin a
cohort! survval model and several economic impact studies using input/ output
analysis. He has alÐ pr:ovided expert testimony in cues CDncerning loss of income
reultigftom wrongf dea~injur. otèmployment discination. He is
currently a adjunct professr of economics at Boise State University (Idaho
economic histoty, urban/reona economics an labor economic.)
Dr. Reag ha recently complete a public inteest water: rigts trsfer cae. He is
currently a member of the Boise City Public WoritCommission.
Exhbit No. 401
GNR-E..ii-oi
Reng, REB
Page 2
l)olic.i.iiii
PM ltD til. 11 s "Bn~ping Idaho", Idaho Issues Onlne, Boise Sllte Uiiversky, Fal2006.
ww.boisstaedu/history/Ílon1e/fa00.Jsli/index.hunl
The Economic Impact of the 2001 Samon Season In Idtho, Idaho Fish and
Wildlife'ounda1Ìon, Apri 2003.
The Economic Impact of aR.estored Salon Fishei in Idtho. Idaho Fiih and
Wildlfe Foundation, Aprit 19~9.
The Economic lmpa ofS~dhead Fishinat th:Ret of Salmon Fihi in
Iclho, Idao Fis and Wildlfe Foundation, September, 1997.
"Cost Savings fmm Nuclear Resources Reform: An Economettic: Model" (with E.
Ray Ca tery an Ben Johnson) S ,(lb". Emli01 l'NmJ, Spri 1996.
A VistO An.ts fo a Birs of Pre Pubc Attaction, Perepe Fund. Inc.,
November, 1988~
Invesriùon of . Caitaaton Rate for Idao Hydtelectre Projec Idaho State
Tax Commssion. Jun, 1988;
"Po.t-PlJRPA ViêWL," In Proedingof theNAIUJC Bieial~atorY
Confè.renee....t9Iß.
An Input-Output Anals of the Impact from Proposed Ming in the Challis Ata
(with ll Davies). Public Policy R.esearch Center, Idaho Sta~ Uniersity, Februar
1980.
Pbø_1d S",till AS _ EøIl AIf (with J. Eyre, et al). Government
Research Institate of Idaho State Un~rsit and the Southeast Idaho Council of
GovtmmentS, Augst 1975.
E.1Î1C..-iFìllI."A1lIlfl'ltInStat, 6IUflbø(with.S. Gbazanlù aid O.floU.y).ceterf()l'.lhl.$ioen and Efon()V1ca.sear.ch. Bo:i$e St. Universa.JutJe 1915.
itA Not~ on the DÎ$tt.hution ofFeciel'al Expendkres: An Interstate Compaison,
1933.1939 and 1961.1965." In Tin Aøl1 Em/l,1It,
VoL. XVII, No.2 (Fal 1914), pp. 125.128.
"New Deal AdiVity and the Sfalls. 193). 1939."iii l(JlimJ'¡ E.mii()"m Hist.'!, Vol.
icXxilI,fiecember I973,pp.792.81().
Euibit No. 401
GNR.E-U..I
R., REPag)
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 22nd day of April, 2011, a tre and correct copy of the
within and foregoing Reb1\al Testimony of Don Reading was served as shown to the
following paries:
Jean Jewell
Idaho Public Utilties Commission
472 W . Washington
Boise, ID 83702
jean. j ewell (ßpuc.idaho . gov
Donald L. Howell II
Kristine Sasser
Idaho Public Utilties Commission
472 W. Washington
Boise, ID 83702
don.howell(ßpuc.idaho. gov
krs.sasser(ßpuc.idaho. gov
Donovan E. Walker
Lisa D. Nordstrom
Idaho Power Company
POBox 70
Boise, ID 83707-0070
dwalker(ßidahopower .com
Inordstrom(ßidahopower .com
Michael G. Andrea
A vista Corporation
1411 E. Mission Street
Spokane, W A 99202
michael.andrea(ßavistacom.com
Daniel Solander
PacifiCorp/dba Rocky Mountain Power
201 S. Main St., Suite 2300
Salt Lake City, UT 84111
daniel.solander(ßpacificorp.com
Ronald L. Wiliams
Wiliams Bradbur PC
1015 W. Hays Street
Boise,ID 83702
ron(ßwiliamsbradbury.com
CERTIFICATE OF SERVICE
GNR-E-ll-Ol
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Scott Montgomery
President, Cedar Creek Wind, LLC
668 Rockwood Dr.
North Salt Lake, UT 84054
scott($westemenergy. us
DanaZenta
Sumit Power Group, Inc.
2006 E. Westminster
Spokane, W A 99223
dzentz($summitpower.com
Thomas H. Nelson
PO Box 1211
Welches, OR 97067
nelson($thnelson.com
JohnR. Lowe
Renewable Energy Coalition
12050 SW Tremont St
Portland, OR 97225
j ravensanarcos($yahoo. com
Don Sturevant
J.R. Simplot Company
PO Box 27
Boise, ID 83707-0027
don. sturevant($simplot. com
Robert A. Paul
Grand View Solar II
15690 Vista Circle
Desert Hot Springs, CA 92241
robertpauI08~gmail.com
James Carkulis
Exergy Development Group of Idaho,
LLC
802 W. Bannock, Ste 1200
Boise, ID 83702
j carkulis($exergydevelopment.com
CERTIFICATE OF SERVICE
GNR-E-ll-Ol
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R. Greg Ferney
Mimura Law Offices, PLLC
2176 E. Franlin Rd., Ste 120
Meridian, ID 83642
gregcgmimuralaw.com
Bil Piske
Interconnect Solar Development, LLC
1303 E. Carer
Boise, iD 83706
bilpiskecgcableone.net
Dean J Milere
McDevitt & Miler, LLP
PO Box 2564
Boise, ID 83701
j oecgmcdevitt -miler .com
Paul Marin
Intermountain Wind, LLC
PO Box 353
Boulder, CO 80306
paulmarincgintermountainwind.com
Ronald L. Wiliams
Wiliams Bradbur, PC
1015 W. Hays Street
Boise, iD 83702
roncgwiliamsbradbury.com
Wade Thomas
Dynamis Energy, LLC
776 W. Riverside Dr., Ste. 15
Eagle, ID 83616
wtomascgdynamisenergy.com
Shelley M. Davis
Barker Rosholt & Simpson, LLC
PO Box 2139
Boise, iD 83701
smdcgidahowaters.com
CERTIFICATE OF SERVICE
GNR-E-ll-Ol
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Brian Olmstead
Twin Falls Canal Company
PO Box 326
Twin Falls, ID 83303
olmstead(ftfcanal.com
Ted Diehl
North Side Canal Company
921 N. Lincoln St.
Jerome, ID 83338
nscanal(fcableone.net
Bil Brown
Board of Commissioners of Adams
County, ID
PO Box 48
Council, ID 83612
bdbrown(ffrontiemet.net
Glen Ikemoto
Margaret Flueger
Idaho Windfars, LLC
672 Blair Avenue
Piedmont, CA 94611
glenni(fenvisionwind.com
margaret(fenvisionwind.com
Jeffrey S. Lovinger
Lovinger Kaufman LLP
825 NE Multnomah, Suite 925
Portland, OR 97232
lovinger(fLKLaw.com
Kenneth E. Kaufman
Lovinger Kaufman LLP
825 NE Multnomah, Suite 925
Portland, OR 97232
Kaufman(fLKLaw.com
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Benjamin J Otto
Idaho Conservation League
710 N 6th Street
Boise ID 83702
botto(ßidahoconservation.org
Gar Seifert
Kur Myers
Idaho National Laboratory
Conventional Renewable Energy Group
2525 Fremont Ave
Idaho Falls, ID 83415
CERTIFICATE OF SERVICE
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Signed ~