20120312Motion for Temporary Stay.pdf

esIDA~POR~
An IDACORP Company
DONOVAN E. WALKER
Lead Counsel
dwalkercmidahopower.com
March 12,2012
VIA HAND DELIVERY
EXPEDITED REVIEW REQUESTED
Jean D. Jewell, Secretary
Idaho Public Utilties 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 INTEGRATED RESOURCE PLANNING (IRP)
METHODOLOGIES FOR CALCULA T1NG PUBLISHED AVOIDED COST
RATES
Dear Ms. Jewell:
Enclosed for filing are an original and seven (7) copies each of Idaho Power
Company's Motion for a Temporary Stay of Its Obligation to Enter into New Power
Purchase Agreements with Qualifying Facilities, Memorandum in Support of Idaho Power
Company's Motion for a Temporary Stay of Its Obligation to Enter into New Power
Purchase Agreements with Qualifying Facilities, Affidavit of Randy C. Allphin In Support of
Idaho Power Company's Motion for a Temporary Stay of Its Obligation to Enter into New
, Power Purchase Agreements with Qualifying Facilties in the above matter.
y yours,
Donovan E. ~f:f:~
DEW:csb
Enclosures
1221 W. Idaho St. (83702)
P.O. Box 70
Boise, ID 83707
DONOVAN E. WALKER (ISB No. 5921)
JASON B. WILLIAMS (ISB No. 8718)
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
dwalker(âidahopower.com
jwilliams(âidahopower.com
Attorneys for Idaho Power Company
RECEIVED
2UI2 MAR 12 PH 4: 49
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. )
)
)
)
)
i. MOTION
CASE NO. GNR-E-11-03
IDAHO POWER COMPANY'S
MOTION FOR A TEMPORARY
STAY OF ITS OBLIGATION TO
ENTER INTO NEW POWER
PURCHASE AGREEMENTS WITH
QUALIFYING FACILITIES
EXPEDITED REVIEW REQUESTED
Pursuant to Idaho Public Utilties Commission ("Commission") Rules of
Procedure ("RP") 56 and 256, Idaho Power Company ("Idaho Powet') hereby
respectfully moves the Commission for an order placing a temporary stay on Idaho
Powets obligation under Sections 201 and 210 of the Public Utilty Regulatory Policies
Act of 1978 ("PURPA") and various Commission Orders to enter into fixed-price PURPA
contracts with Qualifying Facilties ("QF"), other than pursuant to Schedule 86. Idaho
IDAHO POWER COMPANY'S MOTION FOR A TEMPORARY STAY OF ITS OBLIGATION
TO ENTER INTO NEW POWER PURCHASE AGREEMENTS WITH QUALIFYING FACILITIES - 1
Power moves the Commission to find that: (1) the evidence set forth in GNR-E-11-03
(in previous filngs and in those accompanying this Motion) establishes prima facie proof
that Idaho Powets current avoided cost rates are not accurate; (2) that without
adequate interim relief from its duty to purchase output from QFs at those inaccurate
avoided cost rates, Idaho Powets customers are likely to suffer substantial harm; (3)
that the balance of harms favors granting interim relief compared to not granting such
relief; and (4) that good cause exists to grant immediate relief on an interim basis.
Idaho Power further respectfully moves that the Commission act to prevent the
likelihood of substantial harm by ordering a temporary stay, effective March 15, 2012, of
the requirement that Idaho Power enter into any new power purchases (other than
pursuant to Schedule 86) with QFs during the Commission's remaining investigation of
avoided cost rates in this proceeding. Should the Commission deny this requested
relief, Idaho Power requests, in the alternative, that the Commission provide alternative
interim relief in the form of: (1) an order declaring that rates contained in QF purchase
agreements entered into by Idaho Power after the date of this Motion be subject to the
Commission's final rate determination in this matter; or (2) an order setting interim rates
for Idaho Power at the applicable modified rates set forth in Table 2 of Idaho Powets
Memorandum accompanying this Motion; or (3) an order limiting to one year the term of
any QF contract entered into after the date of this Motion and prior to completion of the
Commission's investigation; or (4) an Order establishing Tariff Schedule 86 as Idaho
Powets sole avoided cost for the remainder of the Commission's investigation, subject
to revision to conform with the Commission's ultimate determinations regarding avoided
costs in this matter; or (5) such other relief as the Commission deems 'appropriate.
IDAHO POWER COMPANY'S MOTION FOR A TEMPORARY STAY OF ITS OBLIGATION
TO ENTER INTO NEW POWER PURCHASE AGREEMENTS WITH QUALIFYING FACILITIES - 2
Idaho Power is entitled to the requested relief under the Idaho Supreme Court's
reasoning, in Empire Lumber Co. v. Washington Water Power Co., 114 Idaho 191,233
(1988), that the Commission has implicit authority to grant immediate interim rate relief
when a utilty makes a prima facie showing that rates are inaccurate.1 Idaho Powets
Memorandum in Support of Idaho Power Company's Motion for a Temporary Stay of its
Obligation to Enter Into New Power Purchase Agreements with QFs ("Memorandum"),
inclusive of the Affidavit of Randy C. Allphin, and the direct testimony previously
submitted by Idaho Power in this Case No. GNR-E-11-03, inarguably makes a prima
facie showing. To the extent Idaho Code § 61-307 applies to relief granted by the
Commission, for "good cause shown," the Commission may waive the notice
requirement in that statute.2 Such good cause clearly exists. In addition, QFs that
would be affected by a suspension do not have a due process right to current avoided
cost rates.3 QFs wil not be irreparably harmed by an immediate stay. If, weeks from
now, the Commission's careful consideration of this Motion and opposing arguments
causes the Commission to lift the interim stay, QFs can be kept whole. The opposite is
not true. If the Commission delays for weeks granting a stay, in the interim Idaho Power
wil most likely be met by a flood QFs locking in 20-year contracts.
1 Empire Lumber Co. v. Washington Water Power Co., 114 Idaho 191, 233 (1988) (citing
Grindstone Butte Mut. Canal Co. v. Idaho Power Co., 98 Idaho 860,862 (1978) ("All Commission orders
as to rates are subject to change, given the mandate of I.C. § 61-502 that the Commission continue to
evaluate the rates charged and make changes as necessary. It is true that no statute gives explicit
authority to the Commission to enter "interim" or "temporary" orders; however, implied in the directive of
on-going investigation is the power to make orders effecting rates that are temporary in nature." Id.)
2 Supra, n. 76.
3 In the Matter of the Adjustment of Avoided Cost Rates for New PURPA Contracts, IPUC Case
No. GNR-E-10-01, Order No. 31092,12 (2010) (QFs without a legally enforceable obligation do not have
a property interest in prior rates) (citing Rosebud Enters. v. Idaho PUC, 131 Idaho 1,7 (1997)).
IDAHO POWER COMPANY'S MOTION FOR A TEMPORARY STAY OF ITS OBLIGATION
TO ENTER INTO NEW POWER PURCHASE AGREEMENTS WITH QUALIFYING FACILITIES - 3
II. PREREQUISITES FOR EXPEDITIOUS SUBSTANTIVE RELIEF
This Motion is brought pursuant to RP 56 and RP 256. In satisfaction of RP
256.02, Idaho Power hereby declares that:
1 . The facts supporting Idaho Powets request to act on fewer than 14
days notice are set forth in the direct testimony of Idaho Power's witnesses filed in
GNR-E-11-03 on January 31, 2012, and in the Affidavit of Randy C. Allphin filed
contemporaneously with this Motion. Those facts are summarized in Idaho Powets
accompanying Memorandum, which also provides legal argument and basis why Idaho
Power is entitled to the requested relief.
"
2. Idaho Power served all of the parties on the GNR-E-11-03 service
list with a copy of this Motion, the Affidavit of Randy C. Allphin, and the Memorandum
by U.S. Mail and electronic mail on March 12,2012. At least one representative of each
party (as indicated on the Certificate of Service) was also contacted and informed of this
Motion and the procedure set forth in RP 256.02 by telephone on March 12, 2012.
II. REQUESTED PROCEDURE
Idaho Power hereby respectfully requests that the Commission grant the
requested relief effective March 15,2012, after parties to this proceeding have had two
full days following notice of the Motion to inform the Commission Secretary whether
they support or oppose the Motion. Idaho Power submits that the facts supporting its
request justify the Commission's issuing its order for temporary relief by no later than
March 15, 2012, after being informed of the parties support or opposition, and whether
they wish to be heard, pursuant to RP 256.02 and without further briefing. If the
IDAHO POWER COMPANY'S MOTION FOR A TEMPORARY STAY OF ITS OBLIGATION
TO ENTER INTO NEW POWER PURCHASE AGREEMENTS WITH QUALIFYING FACILITIES - 4
Commission concludes that it wil consider further written responses of the parties, then
Idaho Power respectfully proposes the following schedule:
· The Commission grant Idaho Power interim relief effective no later
than March 15, 2012, subject to modification upon conclusion of briefing and oral
argument.
· Any party seeking similar substantive or procedural relief must join
in the Motion or file its own motion by March 19, 2012, (within 7 days after receiving the
original Motion). RP 256.04.
· All responses to the Motion(s) shall be filed by April 2, 2012, (the
party answering to or responding to the Motion(s) wil have 14 days from the time of
filing of the last motion or joinder in which to respond). Id.
· Idaho Power, and any party that has joined in the Motion or filed its
own motion, shall file its reply no later than April 9, 2012, (7 days after receipt of
responses to the Motion).
· Oral argument shall be scheduled for April 17, 2012, or such date
as soon as practicable thereafter as shall be acceptable to the Commission and its
docket.
IV. CONCLUSION
For the reasons above, Idaho Power respectfully requests that the Commission
grant Idaho Powets Motion and grant the relief requested herein.
DATED this 12th day of March 2012.
~.,
IDAHO POWER COMPANY'S MOTION FOR A TEMPORARY STAY OF ITS OBLIGATION
TO ENTER INTO NEW POWER PURCHASE AGREEMENTS WITH QUALIFYING FACILITIES - 5
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 12th day of March 2012, pursuant to RP 256.02,
that Idaho Power Company contacted one representative from each party listed below
by telephone, as indicated below, and informed said party of the filng of IDAHO
POWER COMPANY'S MOTION FOR, MEMORANDUM IN SUPPORT OF, AND
AFFIDAVIT OF RANDY C. ALLPHIN IN SUPPORT OF IDAHO POWER COMPANY'S
MOTION FOR A TEMPORARY STAY OF ITS OBLIGATION TO ENTER INTO NEW
POWER PURCHASE AGREEMENTS WITH QUALIFYING FACILITIES.
Each part's representative, as indicated below, was informed by telephone of
the filng requesting expedited, immediate relief, and of the procedure set forth in RP
256.02 to inform the Commission Secretary, either in writing personally delivered to the
Secretary or by telephone, within the next two business days, whether they support or
oppose the Motion and whether they desire to be heard on the Motion in person, in
writing, or by telephone.
Additionally, I HEREBY CERTIFY that on the 1ih day of March 2012 I served a
true and correct copy of:
1. Idaho Power Company's Motion for a Temporary Stay of its
Obligation to Enter Into New Power Purchase Agreements with Qualifying Facilties;
2. Memorandum in Support of Idaho Power Company's Motion for a
Temporary Stay of its Obligation to Enter Into New Power Purchase Agreements with
Qualifying Facilities; and
3. Affidavit of Randy C. Allphin in Support of Idaho Power Company's
Motion for a Temporary Stay of its Obligation to Enter Into New Power Purchase
Agreements with Qualifying Facilities.
upon the following named parties by the method indicated below, and addressed to the
following:
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
-2 Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
-2 Email don.howell(Qpuc.idaho.gov
kris.sasser(Qpuc. idaho.gov
-2 Telephonic Notice to Kristine A. Sasser at
[phone], at 11 :25 a.m.
IDAHO POWER COMPANY'S MOTION FOR A TEMPORARY STAY OF ITS OBLIGATION
TO ENTER INTO NEW POWER PURCHASE AGREEMENTS WITH QUALIFYING FACILITIES - 6
Avista Corporation
Michael G. Andrea
Avista Corporation
1411 East Mission Avenue, MSC-23
P.O. Box 3727
Spokane, Washington 99220-3727
PacifiCorp d/b/a Rocky Mountain Power
Daniel E. Solander
PacifiCorp d/b/a Rocky Mountain Power
201 South Main Street, Suite 2300
Salt Lake City, Utah 84111
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
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
Hand Delivered
-2 U.S. Mail
_ Overnight Mail
FAX
-2 Email michael.andrea(Qavistacorp.com
-2 Telephonic Notice to Michael G. Andrea at
[phone], at 12:24 p.m.
Hand Delivered
-2 U.S. Mail
_ Overnight Mail
FAX
-2 Email daniel.solander(Qpacificorp.com
-2 Telephonic Notice to Daniel E. Solander at
[phone], at 11: 15 p.m.
Hand Delivered
-2 U.S. Mail
_ Overnight Mail
FAX
-2 Email peter(Qrichardsonandoleary.com
greg(Qrichardsonandoleary.com
-2 Telephonic Notice to Peter J. Richardson at
[phone], at 2:58 p.m.
Hand Delivered
-2 U.S. Mail
_ Overnight Mail
FAX
-2 Email jcarkulis(Qexergydevelopment.com
-2 Telephonic Notice to Peter J. Richardson at
[phone], at 2:58 p.m.
Hand Delivered
-2 U.S. Mail
_ Overnight Mail
FAX
-2 Email robertapaul08(Qgmail.com
-2 Telephonic Notice to Peter J. Richardson at
[phone], at 2:58 p.m.
IDAHO POWER COMPANY'S MOTION FOR A TEMPORARY STAY OF ITS OBLIGATION
TO ENTER INTO NEW POWER PURCHASE AGREEMENTS WITH QUALIFYING FACILITIES - 7
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
Hand Delivered
-2 U.S. Mail
_ Overnight Mail
FAX
-2 Email don. stu rteva nt(Qsi mplot. com
-2 Telephonic Notice to Peter J. Richardson at
[phone], at 2:58 p.m.
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
Hand Delivered
-2 U.S. Mail
_ Overnight Mail
FAX
-2 Email rkahn(Qnippc.org
-2 Telephonic Notice to Peter J. Richardson at
[phone], at 2:58 p.m.
Board of Commissioners of Adams
County, Idaho
Bil Brown, Chair
Board of Commissioners of
Adams County, Idaho
P.O. Box 48
Council, Idaho 83612
Hand Delivered
-2 U.S. Mail
_ Overnight Mail
FAX
-2 Email bdbrown(Qfrontiernet.net
-2 Telephonic Notice to Peter J. Richardson at
[phone], at 2:58 p.m.
Clearwater Paper Corporation
Marv Lewallen
Clearwater Paper Corporation
601 West Riverside Avenue, Suite 1100
Spokane, Washington 99201
Hand Delivered
-2 U.S. Mail
_ Overnight Mail
FAX
-2 Email marv.lewallen(Qclearwaterpaper.com
-2 Telephonic Notice to Peter J. Richardson at
[phone], at 2:58 p.m.
Renewable Energy Coalition and Dynamis
Energy, LLC
Ronald L. Wiliams
WILLIAMS BRADBURY, P.C.
1015 West Hays Street
Boise, Idaho 83702
Hand Delivered
-2 U.S. Mail
_ Overnight Mail
FAX
-2 Email ron(Qwillamsbradbury.com
-2 Telephonic Notice to Ronald L. Wiliams at
[phone], at 1 :46 p.m.
IDAHO POWER COMPANY'S MOTION FOR A TEMPORARY STAY OF ITS OBLIGATION
TO ENTER INTO NEW POWER PURCHASE AGREEMENTS WITH QUALIFYING FACILITIES - 8
Renewable Energy Coalition
Thomas H. Nelson, Attorney
P.O. Box 1211
Welches, Oregon 97067-1211
Hand Delivered
-2 U.S. Mail
_ Overnight Mail
FAX
-2 Email nelson(Qthneslon.com
-2 Telephonic Notice to Ronald L. Wiliams at
[phone], at 1 :46 p.m.
John R. Lowe, Consultant
Renewable Energy Coalition
12050 SW Tremont Street
Portland, Oregon 97225
Hand Delivered
-2 U.S. Mail
_ Overnight Mail
FAX
-2 Email jravenesanmarcos(Qyahoo.com
-2 Telephonic Notice to Ronald L. Willams at
[phone], at 1 :46 p.m.
Dynamis Energy, LLC
Wade Thomas, General Counsel
Dynamis Energy, LLC
776 East Riverside Drive, Suite 150
Eagle, Idaho 83616
Hand Delivered
-2 U.S. Mail
_ Overnight Mail
FAX
-2 Email wthomas(Qdynamisenergy.com
-2 Telephonic Notice to Ronald L. Wiliams at
[phone], at 1 :46 p.m.
Interconnect Solar Development, LLC
R. Greg Ferney
MIMURA LAW OFFICES, PLLC
2176 East Franklin Road, Suite 120
Meridian, Idaho 83642
Hand Delivered
-2 U.S. Mail
_ Overnight Mail
FAX
-2 Email greg(Qmimuralaw.com
-2 Telephonic Voice Mail to R. Greg Ferney at
[phone], at 2:52 p.m.
Bil Piske, Manager
Interconnect Solar Development, LLC
1303 East Carter
Boise, Idaho 83706
Hand Delivered
-2 U.S. Mail
_ Overnight Mail
FAX
-2 Email bilpiske(Qcableone.net
-2 Telephonic Voice Mail to R. Greg Ferney at
[phone], at 2:52 p.m.
IDAHO POWER COMPANY'S MOTION FOR A TEMPORARY STAY OF ITS OBLIGATION
TO ENTER INTO NEW POWER PURCHASE AGREEMENTS WITH QUALIFYING FACILITIES - 9
Renewable Northwest Project and Idaho
Windfarms, LLC
Dean J. Miler
Chas. F. McDevitt
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
Idaho Windfarms, LLC
Glenn Ikemoto
Margaret Rueger
Idaho Windfarms, LLC
672 Blair Avenue
Piedmont, California 94611
Twin Falls Canal Company and North Side
Canal Company
C. Thomas Arkoosh
CAPITOL LAW GROUP, PLLC
205 North 10th Street, 4th Floor
P.O. Box 2598
Boise, Idaho 83701-2598
Twin Falls Canal Company
Brian Olmstead, General Manager
Twin Falls Canal Company
P.O. Box 326
Twin Falls, Idaho 83303
Hand Delivered
-2 U.S. Mail
_ Overnight Mail
FAX
-2 Email joe(Qmcdevitt-miler.com
chas(Qmcdevitt-miller.com
-2 Telephonic Notice to Dean J. Miler at
[phone], at 1 :03 p.m.
Hand Delivered
-2 U.S. Mail
_ Overnight Mail
FAX
-Å Email megan(Qrnp.org
-2 Telephonic Notice to Dean J. Miler at
[phone], at 1 :03 p.m.
Hand Delivered
-2 U.S. Mail
_ Overnight Mail
FAX
-2 Email glenni(Qenvisionwind.com
margaret(Qenvisionwind .com
-2 Telephonic Notice to Dean J. Miler at
[phone], at 1 :03 p.m.
Hand Delivered
-2 U.S. Mail
_ Overnight Mail
FAX
-2 Email glenni(Qenvisionwind.com
margaret(Qenvisionwind .com
-2 Telephonic Voice Mail to C. Thomas
Arkoosh at [phone], at 2:55 p.m.
Hand Delivered
-2 U.S. Mail
_ Overnight Mail
FAX
-2 Email olmstead(Qtfcanal.com
-2 Telephonic Voice Mail to C. Thomas
Arkoosh at [phone], at 2:55 p.m.
IDAHO POWER COMPANY'S MOTION FOR A TEMPORARY STAY OF ITS OBLIGATION
TO ENTER INTO NEW POWER PURCHASE AGREEMENTS WITH QUALIFYING FACILITIES -10
North Side Canal Company
Ted Diehl, General Manager
North Side Canal Company
921 North Lincoln Street
Jerome, Idaho 83338
Hand Delivered
-2 U.S. Mail
_ Overnight Mail
FAX
-2 Email nscanal(Qcableone.net
-2 Telephonic Voice Mail to C. Thomas
Arkoosh at [phone], at 2:55 p.m.
Birch Power Company
Ted S. Sorenson, P.E.
Birch Power Company
5203 South 11 th East
Idaho Falls, Idaho 83404
Hand Delivered
-2 U.S. Mail
_ Overnight Mail
FAX
-2 Email ted(Qtsorenson.net
-2 Telephonic Notice to Ted S. Sorenson at
[phone], at 3:04 p.m.
Blue Ribbon Energy LLC
M.J. Humphries
Blue Ribbon Energy LLC
4515 South Ammon Road
Ammon, Idaho 83406
Hand Delivered
-2 U.S. Mail
_ Overnight Mail
FAX
-2 Email blueribbonenergy(Qgmail.com
-2 Telephonic Notice to M.J. Humphries at
[phone], at 1 :34 p.m.
Arron F. Jepson
Blue Ribbon Energy LLC
10660 South 540 East
Sandy, Utah 84070
Hand Delivered
-2 U.S. Mail
_ Overnight Mail
FAX
-2 Email arronesq(Qaol.com
-2 Telephonic Notice to M.J. Humphries at
[phone], at 1 :34 p.m.
Idaho Conservation League
Benjamin J. Otto
Idaho Conservation League
710 North Sixth Street (83702)
P.O. Box 844
Boise, Idaho 83701
Hand Delivered
-2 U.S. Mail
_ Overnight Mail
FAX
-Å Email botto(Qidahoconservation.org
-2 Telephonic Notice to Benjamin J. Oto at
[phone] ext. 12, at 1:12 p.m.
IDAHO POWER COMPANY'S MOTION FOR A TEMPORARY STAY OF ITS OBLIGATION
TO ENTER INTO NEW POWER PURCHASE AGREEMENTS WITH QUALIFYING FACILITIES - 11
Snake River Allance
Ken Miller, Clean Energy Program Director
Liz Woodruff, Executive Director
Lisa Young, Clean Energy Organizer
Snake River Allance
350 North 9th Street #B610
P.O. Box 1731
Boise, Idaho 83701
Hand Delivered
-2 U.S. Mail
_ Overnight Mail
FAX
-Å Email kmiller(Qsnakeriverallance.org
Iwoodruff(Qsnakeriveralliance.org
lyoung(Qsnakeriveralliance.org
-2 Telephonic Notice to Lisa Young at
[phone], at 2:03 p.m.
onovan E. Walker
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S MOTION FOR A TEMPORARY STAY OF ITS OBLIGATION
TO ENTER INTO NEW POWER PURCHASE AGREEMENTS WITH QUALIFYING FACILITIES -12