20120131Grow Direct.pdf

DONOVAN E. WALKER
Lead Counsel
dwalker((idahopower.com
e:IDA~POR~
An IDACORP Company
January 31,2012
VIA HAND DELIVERY
Jean D. Jewell, Secretary
Idaho Public Utilities Commission
472 West Washington Street
Boise, Idaho 83702
Re: Case No. GNR-E-11-03
IN THE MATTER OF THE COMMISSION'S REVIEW OF PURPA QF
CONTRACT PROVISIONS INCLUDING THE SURROGATE AVOIDED
RESOURCE (SAR) AND INTEGRA TED RESOURCE PLANNING (IRP)
METHODOLOGIES FOR CALCULA T1NG PUBLISHED AVOIDED COST
RATES
Dear Ms. Jewell:
Enclosed for filng are nine (9) copies of the testimonies and exhibits of Lisa A.
Grow, M. Mark Stokes, Tessia Park, William H. Hieronymus, and Karl Bokenkamp. One
copy of each of the aforementioned testimonies has been designated as the "Reporter's
Copy." A disk containing Word versions of the testimonies is enclosed for the Reporter.
In addition, nine (9) copies of the confidential portions of Exhibit NO.7 have been
included in a separate envelope. Please handle the confidential information in accordance
with the Protective Agreement in this matter.
yours,G?rJ~
ovan E. Walker
DEW:csb
Enclosures
1221 W. Idaho St. (83702)
P.O. Box 70
Boise, ID 83707
R~Ctl"¡:D..\ :j.. ,,, 9' .iL
2ßl2 JAN 31 PH 3: 20
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE COMMISSION'S
REVIEW OF PURPA QF CONTRACT
PROVISIONS INCLUDING THE SURROGATE
AVOIDED RESOURCE (SAR) AND
INTEGRATED RESOURCE PLANNING (IRP)
METHODOLOGIES FOR CALCULATING
PUBLISHED AVOIDED COST RATES.
CASE NO. GNR-E-ll-03
IDAHO POWER COMPANY
DIRECT TESTIMONY
OF
LISA A. GROW
1 Q.Please state your name and business address.
2 A.My name is Lisa A. Grow and my business
3 address is 1221 West Idaho Street, Boise, Idaho 83702.
4 Q.By whom are you employed and in what capacity?
5 A.I am employed by Idaho Power Company (" Idaho
6 Power" or "Company") as the Senior Vice President of Power
7 Supply.
8 Q.Please describe your educational background
9 and work experience with Idaho Power.
10 A.I graduated from the Uni versi ty of Idaho in
11 1987 with a Bachelor of Science degree in electrical
12 engineering. I received an Executive Masters of Business
13 Administration from Boise State University in 2008. I
14 began my career at Idaho Power after graduating from the
15. University of Idaho in 1987, and have held several
16 engineering positions before moving into management in
17 2005. In 2005, I was named Vice President of Delivery
18 Engineering and Operations. In 2009, I was appointed to my
19 current position as Senior Vice President of Power Supply.
20 My current responsibilities include overseeing the
21 operation and maintenance of Idaho Power's generation
22 fleet, power plant engineering and construction,
23 environmental affairs, water management, power supply
24 planning, and wholesale electricity and gas operations.
25
GROW, DI 1
Idaho Power Company
1 Q.What is the purpose of your testimony in this
2 matter?
3 A.The purpose of my testimony is to present the
4 Company's requests to modify the Idaho Public Utili ties
5 Commission's ("Commission") implementation of the Public
6 Utility Regulatory Policies Act of 1978 ("PURPA") as it is
7 applied in the state of Idaho and more particularly to
8 Idaho Power. I will provide an overview of the Company's
9 case and summarize the maj or points contained in the
10 testimony of the Company' s witnesses.
11 I . INTRODUCTION
12 Q.What has the Commission stated with regard to
13 the purpose and/or scope of the present proceeding?
14 A.In its order maintaining the 100 kilowatt
15 ("kW") published rate eligibility cap for wind and solar
16 Qualified Facilities ("QF"), Case No. GNR-E-11-01, the
17 Commission stated that it was initiating "additional
18 proceedings to allow the parties to investigate and analyze
19 both the SAR Methodology and the IRP Methodology" and that
20 "we (the Commission) encourage a full examination of the
21 application of the IRP Methodology and are open to
22 considering al ternati ves to the current methodologies."
23 Order No. 32262, pp. 8-9.
2 4 Additionally, in its Notice of Review for this
25 matter, Case No. GNR-E-11-03, the Commission further
GROW, DI 2
Idaho Power Company
1 directed that this proceeding investigate and review the
2 methodologies for calculating avoided cost rates for QFs
3 pursuant to PURPA. Order No. 32352. With regard to the
4 investigation and scope of this particular proceeding, the
5 Commission further stated that it, "seeks information
6 regarding the appropriateness of both the SAR and IRP-based
7 avoided cost methodologies. Specifically, the calculation
8 of avoided cost rates, for both published and negotiated
9 contracts, is being re-examined." Id., p. 4.
10 Additionally, "the Commission anticipates that the scope of
11 this inquiry will also include (but is not limited to)
12 considerations regarding the dispatchabili ty of varying
13 resources, curtailment options, integration costs,
14 renewable energy credits, delay security and liquidated
15 damages, timing and schedule of negotiations, and contract
16 milestones." Id.
17 Q. Is this matter also referred to as "Phase III"
18 of the PURPA avoided cost rate proceedings that were
19 initiated in November 2010?
20 A.Yes. This is considered Phase III of those
21 proceedings.
22 Q.Could you summarize Phase I and Phase II of
23 these proceedings?
24 A.Yes. Phase I began when Idaho Power, Avista,
25 and Rocky Mountain Power filed a Joint Petition on November
GROW, DI 3
Idaho Power Company
1 5, 2010, in Case No. GNR-E-10-04, requesting the Commission
2 ini tiate an investigation to address various avoided cost
3 issues related to the implementation of PURPA in Idaho.
4 The utili ties were experiencing numerous requests for PURPA
5 contracts from large, utility-scale proj ects that were
6 being disaggregated in order to take advantage of the
7 published rates only available to smaller proj~cts. The
8 utilities requested that the Commission immediately lower
9 the eligibility cap from 10 average megawatts to 100 kW
10 during the investigation.
11 On December 3, 2010, the Commission declined to
12 lower the eligibility cap immediately and set a schedule to
13 process the Joint Petition through Modified Procedure and
14 oral arguments. Order No. 32131. The Commission also
15 directed that if a decision to lower the cap was made, it
16 would be effective as of December 14, 2010.
17 In Order No. 32176, issued on February 7, 2011, the
18 Commission granted part of the request by lowering the
19 eligibility cap for wind and solar projects to 100 kW, but
20 the cap for other resource types remained unchanged. The
21 order also directed the parties to meet within 10 days to
22 establish a schedule for Phase II which would address the
23 disaggregation issue.
24 Commission Order No. 32195 established a schedule
25 for Phase II, in Case No. GNR-E-11-01, which culminated
GROW, DI 4
Idaho Power Company
1 with a Technical Hearing the week of May 9, 2011. The
2 Commission also directed the parties to provide information
3 regarding how small wind and solar QFs could continue to
4 have access to published avoided cost rates without
5 allowing large QFs to obtain a rate that does not
6 accurately reflect a utility's avoided cost. In Order No.
7 32262, issued on June 8, 2011, the Commission determined
8 that the published rate eligibility cap for wind and solar
9 QFs would remain at 100 kW, and the Commission would
10 undertake a more detailed examination of the methodologies
11 used to set avoided cost rates. Order No. 32262 also
12 directed the parties to meet to establish an issues list
13 and a schedule for Phase III, which is this present case,
14 GNR-E-11-03.
15 II. CAE STRUCTUR AN WITNSS SUMY
16 Q. Could you please provide an overview of Idaho
17 Power's case and summarize the testimony of the Company's
18 witnesses?
19 A.Yes. The next witness for the Company is M.
20 Mark Stokes, Manager of Power Supply Planning. Mr. Stokes
21 describes the current status of PURPA QF proj ects on Idaho
22 Power's system, as well as the current implementation of
23 both the Surrogate Avoided Resource- ("SAR") and Integrated
24 Resource Plan- ("IRP") based avoided cost methodologies in
25 Idaho. He also addresses issues related to risk and harm
GROW, DI 5
Idaho Power Company
1 to Idaho Power customers, contract term, contracting
2 process, and presents the Company's proposal to utilize the
3 IRP-based methodology for establishing the avoided cost for
4 all PURPA QF proj ects, and for both published and
5 negotiated rates.
6 Q.Does the Company present any testimony
7 regarding utility operations?
8 A.Yes.Tessia Park, Load Serving Operations
9 Director, presents testimony regarding utility operations
10 with regard to PURPA QFs and the Company's requirements to
11 reliably serve load. Ms. Park provides testimony regarding
12 the economic dispatch of Idaho Power's resources, and how
13 economic dispatch decisions come in to play when
14 incorporating PURPA QF generation into Idaho Power's
15 system. Ms. Park discusses the requirements of federal
16 regulations, particularly 18 C.F.R. § 292.304, and how they
17 interact with certain light load operational situations on
18 the Company's system. Ms. Park explains and presents the
19 Company's proposed new Tariff Schedule 74 which sets forth
20 an authorized curtailment policy and procedure for PURPA QF
21 generation pursuant to 18 C.F.R. § 292.304(f).
22 Q.Does the Company have any other witnesses?
23 A.Yes. The Company engaged an outside
24 consulting firm, Charles Rivers & Associates, to evaluate
25 Idaho Power's system, the current implementation of PURPA
GROW, DI 6
Idaho Power Company
1 QF requirements in the state of Idaho, the current avoided
2 cost methodologies employed by the Commission, and other
3 PURPA related issues relevant to this proceeding. Mr.
4 William Hieronymus from Charles Rivers & Associates
5 discusses the history and origins of PURPA requirements and
6 the implementation of those requirements in various
7 jurisdictions. Mr. Hieronymus also presents various
8 methods that have been utilized across the country to
9 calculate and establish avoided cost rates and prices
10 pursuant to PURPA. He also discusses issues related to the
11 allocation of risk in PURPA QF transactions such as pricing
12 and contract term. Finally, Mr. Hieronymus discusses the
13 avoided cost methodology employed in the state of Idaho and
14 discusses Idaho Power's proposed revisions to the
15 methodology presented in this case.
16 Q.Does Idaho Power propose any changes to the
17 avoided cost methodologies?
18 A.The Company's final witness to provide direct
19 testimony is Karl Bokenkamp, Power Supply's Director of
20 Operations Strategy. He provides testimony setting forth
21 the Company's proposed changes, or modifications, that
22 Idaho Power requests for the implementation of the IRP
23 methodology.
24
25
GROW, DI 7
Idaho Power Company
1 III. CAE SUMY
2 Q.What are Idaho Power's maj or concerns in this
3 case?
4 A.Idaho Power is deeply concerned about the
5 negative economic impact caused by the implementation of
6 PURPA and its requirements, as well as the detrimental
7 effect that the accumulated and continuing addition of
8 PURPA QF generation is having on Idaho Power's system and
9 operations. The economic ramifications are extremely
10 harmful to customers. Idaho Power is very concerned that
11 the avoided cost methodologies approved by the Commission
12 have become disconnected from federal requirements and the
13 definition of avoided cost. This has resulted in an
14 environment that has fostered rapid and uncontrolled
15 development of QF generation proj ects that are causing
16 substantial harm to Idaho Power customers by greatly
17 inflating power supply costs while at the same time
18 degrading the reliability of the system.
19 Idaho Power's main concern is that the Company is
20 obligated to take a very large amount of generation that it
21 does not need and is not valuable to its operations, while
22 at the same time paying more for it than other generation
23 or market purchases that are available to serve load. The
24 Company is also very concerned about the very large and
25 dramatic increase in power supply costs that must be borne
GROW, DI 8
Idaho Power Company
1 by customers because of the mandatory QF purchases that
2 cost more than the Company's own generation or al ternati ve
3 purchases. Idaho Power desires that the requirements of
4 PURPA continue to be met, but also wants to ensure that
5 Idaho Power's requirements of providing safe, reliable, and
6 low cost power to its customers is not undermined in doing
7 so.
8 Q.What does Idaho Power see as problems with the
9 current implementation of PURPA?
10 A.Several things: (1) The continuing and
11 unchecked requirement for the Company to acquire QF
12 generation, pursuant to avoided cost rates, with no regard
13 for the Company's need for additional generation on its
14 system, nor the availability of other lower cost resources,
15 and in a manner inconsistent with the federal definition of
16 avoided cost; (2) Circumvention of the Company's required
17 IRP planning process and a continuing requirement to
18 acquire generation outside of that established process that
19 inflates customers' power supply costs; (3) System
20 reliabili ty and other operational issues caused by a rapid
21 and large scale increase in intermittent and unreliable
22 generation sources; and (4) Most importantly, a dramatic
23 increase in the price that Idaho Power's customers must pay
24 for their energy needs as a direct result of the large
25 quanti ties of additional QF generation at prices in excess
GROW, DI 9
Idaho Power Company
1 of the Company's avoided cost, and beyond that which would
2 otherwise be considered prudent.
3 These items are discussed in more detail in the
4 direct testimony of Mr. Stokes.
5 Q.How does the large increase in PURPA
6 generation affect Idaho Power's customers?
7 A.Customers pay 100 percent of PURPA power
8 supply costs in the annual Power Cost Adjustment ("PCA").
9 These costs, while never insignificant, were relatively
10 small and stable from 1982, when the first QF projects were
11 connected to the Company's system, until about 2003. Since
12 2004, PURPA expense has grown dramatically, and customers
13 will see very significant annual rate increases out to 2026
14 based upon the current QF proj ects that are currently
15 generating, and those that have approved power sales
16 agreements to date. As shown in more detail in the
17 testimony of Mr. Stokes, annual PURPA power supply expenses
18 in 2004 were approximately $40 million. It took more than
19 20 years of accumulation of annual PURPA expense to amount
20 to the 2004 one-year magnitude of cost. Just five years
21 later, by 2009, that amount grew by 50 percent to
22 approximately $ 60 million. Just another three years after
23 that, in 2012, that $60 million will double to $120 million
24 of annual PURPA power supply costs. That number increases
25 to $167 million by 2014, and by 2026, will be $186 million
GROW, DI 10
Idaho Power Company
1 annually, an approximate 465 percent increase in costs from
2 2004. This will result in dramatic annual rate increases
3 for all of Idaho Power's customers.
4 Q.Please summarize the Company's requested
5 relief in this case.
6 A.The Company has conducted a comprehensive
7 examination of the process by which the Commission
8 implements the requirements of PURPA and PURPA's
9 corresponding Federal Energy Regulatory Commission
10 regulations. Idaho Power's testimony summarizes the
11 current procedures and methodologies that are in place, and
12 requests changes in several areas. The Company
13 demonstrates through testimony how its proposed changes
14 both comply with the federal requirements o~ PURPA, and
15 address severe problems with the current implementation of
16 PURPA. If left unaddressed, the current problems
17 associated with the implementation of PURPA will continue
18 to unnecessarily inflate the power supply costs of its
19 customers and to degrade the reliability of Idaho Power's
20 system.
21 To address the current and potential economic harm
22 to Idaho Power customers as a result of continuing to add
23 large amounts of unneeded generation to its system at a
24 high cost, Idaho Power requests first, that all PURPA QF
25 avoided costs be calculated using an IRP-based avoided cost
GROW, DI 11
Idaho Power Company
1 methodology. This is a large step in the right direction
2 to more closely estimate Idaho Power's avoided cost - the
3 incremental cost that the utility would incur, either by
4 generating the power itself or purchasing it from another
5 source, but for the purchase from the QF. This is also a
6 step in the right direction to better ensure that Idaho
7 Power customers remain neutral as to whether the power was
8 purchased from a QF or otherwise acquired by the utility,
9 as is required by federal law. It also starts to bring
10 some aspects of utility need into the determination of
11 avoided cost prices.
12 Second, the Company requests approval and
13 implementation of a standard contracting and negotiation
14 process by which PURPA QFs can obtain a Power Purchase
15 Agreement ("PPA") with Idaho Power in a completely
16 transparent process that provides certainty to both
1 7 parties, better defines the parties' obligations, and
18 addresses issues frequently brought before the Commission
19 in the form of "grandfathering" requests.
20 Third, to mitigate and reduce the risk born entirely
21 by Idaho Power customers associated with long-term power
22 purchase commitments at a fixed price or rate, Idaho Power
23 requests a reduction in the maximum authorized PPA contract
24 term from its present term of 20 years to a maximum of five
25 years.
GROW, DI 12
Idaho Power Company
1 To ensure that customers are not harmed by the
2 purchase of power from the QF, and that the Company's lower
3 cost base load resources are being optimized and used to
4 cost-effectively serve customers when available, the
5 Company requests approval of a new Tariff Schedule 74.
6 This Tariff Schedule sets forth the authorized curtailment
7 policy and procedure for PURPA QF generation pursuant to 18
8 C.F.R. §292.304(f).
9 Lastly, the Company seeks certain modifications to
10 the currently approved IRP-based avoided cost pricing
11 methodology in order to better estimate Idaho Power's
12 avoided cost, and to align the methodology with the
13 definition of avoided cost from federal law. This request
14 is essentially a modification to the present implementation
15 of the IRP-based methodology that better aligns the
16 methodology with the definition of avoided cost from
17 federal regulations.
18 Q.You stated earlier that the Commission
19 mentioned renewable energy credits ("RECs") in a list of
20 possible issues in Order No. 32352. Does the Company have
21 a proposal as part of this case regarding RECs?
22 A.Issues related to PURPA QFs and RECs are
23 currently being litigated by the Company before the
24 Commission in Case No. IPC-E-11-15. The Commission has had
25 proceedings in the past regarding issues related to the
GROW, DI 13
Idaho Power Company
1 . ownership of RECs between PURPA QFs and the purchasing
2 utility, but the issue of ownership of RECs in the state of
3 Idaho remains an unsettled issue.Idaho Power understands
4 that the Idaho Legislature, which is currently in session,
5 may be considering proposed legislation that would address
6 the ownership of RECs from PURPA QF projects, and thus the
7 Company has no specific request of the Commission in this
8 regard at this time.
9 Q.Please detail the specific approval the
10 Company is requesting from the Commission.
11 A.The Company requests specific Commission
12 approval of the following:
13 1.The use of an IRP-based methodology for
14 establishing avoided cost rates for all PURPA QF proj ects;
15 2.Establishment of a Commission-
16 authorized negotiation process and procedure by which a
17 PURPA QF can obtain a PPA with Idaho Power;
18 3.A reduction in the maximum term for
19 PURPA QF PPAs from 20 years to five years;
20 4.The Company's proposed Tariff Schedule
21 74 setting forth the Company's authorized curtailment
22 policy and procedure for PURPA QF generation pursuant to 18
23 C.F.R. § 292.304(f); and
24 5.The Company's proposed modifications to
25 the previously approved IRP-based avoided cost methodology.
GROW, DI 14
Idaho Power Company
1 The Company believes that these determinations can
2 reasonably be made based upon the full and detailed
3 testimony provided by the Company in this case.
4 Q.Is it your opinion that the granting of the
5 requested relief proposed by the Company is in the public
6 interest?
7 A.Yes. The great advantages that Idaho Power
8 customers, its service terri tory, and its region enj oy from
9 consistently having among the very lowest electricity
10 prices in the nation are being eroded by a flood of QF
11 generation that we all are paying too much for. Idaho
12 Power is forced to purchase this power with no regard to
13 whether it is needed on its system, with no regard to
14 whether it is called for in the Company's IRP process, and
15 with no regard to whether there are other lower cost
16 al ternati ves for its customers . Additionally, the Company
17 is forced to deal with the difficult tasks and problems
18 associated with integrating large amounts of intermittent
19 and variable renewable generation into its system, once
20 again with customers paying the resulting price. In most
21 instances, customers do not even get the "benefits" derived
22 from the renewable attributes of that generation in the
23 form of RECs, nor is the Company even able to "claim" or
24 get credit for the existence of that renewable energy on
25 its system.
GROW, DI 15
Idaho Power Company
1 In this proceeding we have the unique opportunity to
2 re-examine the appropriateness of the methodologies used to
3 set avoided cost, and to re-examine the way that the state
4 of Idaho implements the federal requirements of PURPA.
5 Idaho Power is deeply affected by these determinations, as
6 are its customers, and has proposed reasoned and rational
7 solutions to both ensure that the requirements of PURPA
8 continue to be met, but also that Idaho Power's
9 requirements of providing safe, reliable, and low cost
10 power to its customers is not undermined in doing so. The
11 Company's proposals are in the public interest, comply with
12 federal requirements, and the Company respectfully asks the
13 Commission to implement the same.
14 Q.Does that conclude your testimony?
15 A.Yes, it does.
16
17
18
19
20
21
22
23
24
25
GROW, DI 16
Idaho Power Company
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 31st day of January 2012 I served a true and
correct copy of the DIRECT TESTIMONY OF LISA A. GROW upon the following named
parties by the method indicated below:
Commission Staff
Donald L. Howell, II
Kristine A. Sasser
Deputy Attorneys General
Idaho Public Utilities Commission
472 West Washington (83702)
P.O. Box 83720
Boise, Idaho 83720-0074
.. Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
.. Email don.howeiicæpuc.idaho.gov
kris.sassercæpuc. idaho.gov
Avista Corporation
Michael G. Andrea
Avista Corporation
1411 East Mission Avenue, MSC-23
P.O. Box 3727
Spokane, Washington 99220-3727
Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
.. Email michael.andrea(aavistacorp.com
PacifiCorp d/b/a Rocky Mountain Power
Daniel E. Solander
PacifiCorp d/b/a Rocky Mountain Power
201 South Main Street, Suite 2300
Salt Lake City, Utah 84111
Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
.. Email daniel.solander(apacificorp.com
Kenneth Kaufmann
LOVINGER KAUFMANN, LLP
825 NE Multnomah, Suite 925
Portland, Oregon 97232
Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
.. Email kaufmann(alklaw.com
Exergy Development, Grand View Solar II,
J.R. Simplot, Northwest and Intermountain
Power Producers Coalition, Board of
Commissioners of Adams County, Idaho,
and Clearwater Paper Corporation
Peter J. Richardson
Gregory M. Adams
RICHARDSON & O'LEARY, PLLC
515 North 27th Street (83702)
P.O. Box 7218
Boise, Idaho 83707
Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
.. Email peter(arichardsonandolearv.com
greg(arichardsonandolearv.com
CERTIFICATE OF SERVICE - 1
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
15690 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
Board of Commissioners of Adams
County, Idaho
Bill Brown, Chair
Board of Commissioners of
Adams County, Idaho
P.O. Box 48
Council, Idaho 83612
Clearwater Paper Corporation
Marv Lewallen
Clearwater Paper Corporation
601 West Riverside Avenue, Suite 1100
Spokane, Washington 99201
CERTIFICATE OF SERVICE - 2
Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
.. Email jcarkulis(aexergydevelopment.com
Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
.. Email robertapaul08(agmail.com
Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
.. Email don.sturtevant(asimplot.com
Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
.. Email rkahn(anippc.org
Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
.. Email bdbrown(afrontiernet.net
Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
.. Email marv.lewallen(aclearwaterpaper.com
Renewable Energy Coalition
Thomas H. Nelson, Attorney
P.O. Box 1211
Welches, Oregon 97067-1211
Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
.. Email nelson(athneslon.com
John R. Lowe, Consultant
Renewable Energy Coalition
12050 SW Tremont Street
Portland, Oregon 97225
Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
.. Email jravenesanmarcos(ayahoo.com
Dynamis Energy, LLC
Ronald L. Wiliams
WILLIAMS BRADBURY, P.C.
1015 West Hays Street
Boise, Idaho 83702
Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
.. Email ron(awilliamsbradbury.com
Wade Thomas, General Counsel
Dynamis Energy, LLC
776 East Riverside Drive, Suite 150
Eagle, Idaho 83616
Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
.. Email wthomas(adynamisenergy.com
Idaho Windfarms, LLC
Glenn Ikemoto
Margaret Rueger
Idaho Windfarms, LLC
672 Blair Avenue
Piedmont, California 94611
Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
.. Email glenni(aenvisionwind.com
margaret(aenvisionwind .com
Interconnect Solar Development, LLC
R. Greg Ferney
MIMURA LAW OFFICES, PLLC
2176 East Franklin Road, Suite 120
Meridian, Idaho 83642
Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
.. Email greg(amimuralaw.com
Bil Piske, Manager
Interconnect Solar Development, LLC
1303 East Carter
Boise, Idaho 83706
Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
.. Email billpiske(acableone.net
CERTIFICATE OF SERVICE - 3
Renewable Northwest Project
Dean J. Miller
McDEVITT & MILLER LLP
420 West Bannock Street (83702)
P.O. Box 2564
Boise, Idaho 83701
Megan Walseth Decker
Senior Staff Counsel
Renewable Northwest Project
917 SW Oak Street, Suite 303
Portland, Oregon 97205
North Side Canal Company and Twin Falls
Canal Company
Shelley M. Davis
BARKER ROSHOLT & SIMPSON, LLP
1010 West Jefferson Street, Suite 102 (83702)
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
Birch Power Company
Ted S. Sorenson, P.E.
Birch Power Company
5203 South 11 th East
Idaho Falls, Idaho 83404
Blue Ribbon Energy LLC
M. J. Humphries
Blue Ribbon Energy LLC
4515 South Ammon Road
Ammon, Idaho 83406
CERTIFICATE OF SERVICE - 4
Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
.. Email joe(amcdevitt-miler.com
Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
-. Email megan(arnp.org
Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
.. Email smd(aidahowaters.com
Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
.. Email olmstead(atfcanal.com
Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
.. Email nscanal(acableone.net
Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
.. Email ted(atsorenson.net
Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
.. Email blueribbonenergy(agmail.com
Arron F. Jepson
Blue Ribbon Energy LLC
10660 South 540 East
Sandy, Utah 84070
Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
.. Email arronesg(aaol.com
Idaho Conservation League
Benjamin J. Otto
Idaho Conservation League
710 North Sixth Street (83702)
P.O. Box 844
Boise, Idaho 83701
Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
-. Email botto(aidahoconservation.org
Snake River Allance
Ken Miler
Clean Energy Program Director
Snake River Alliance
350 North 9th Street #B610
P.O. Box 1731
Boise, Idaho 83701
Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
-. Email kmiler(asnakeriverallance.org
ri~Donovan E. Walker
CERTIFICATE OF SERVICE - 5