20120720Objection to Late Petition.pdf

IDAHO
RE C E IV E An IDACORP Company
2012 JUL 20 PM•lr 53
JASON B. WILLIAMS
Corporate Counsel ILAFtO PULi
jwiIIiamsidahopower.com UI LITl ES
July 20, 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
PURPA SAR and IRP Methodologies - Objection to Petition to Intervene of
Big Wood Canal Company and American Falls Reservoir District No. 2
Dear Ms. Jewell:
Enclosed for filing in the above matter are an original and seven (7) copies of Idaho
Power Company's Objection to Petition to Intervene by Big Wood Canal Company and
American Falls Reservoir District No. 2.
Very truly yours,
Jason B. Williams
JBW: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]
dwaIker(idahopower.com
iwilIiamsidahoDower.com
RECEIVED
212 JUL 20 PM (: 53
DAH,IrUELIC:
U1'LITIES COMMISSiON
Attorneys for Idaho Power Company
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-11-03
IDAHO POWER COMPANY'S
OBJECTION TO PETITION TO
INTERVENE BY BIG WOOD
CANAL COMPANY AND
AMERICAN FALLS RESERVOIR
DISTRICT NO. 2
COMES NOW, Idaho Power Company ("Idaho Power") pursuant to Idaho Public
Utilities Commission ("Commission") Rule of Procedure 73 and hereby objects to the
July 13, 2012, Petition to Intervene by Big Wood Canal Company and American Falls
Reservoir District No. 2 ("Petitioners") The basis for Idaho Power's objection is as
follows:
I. BACKGROUND
The issues being addressed in this case have been developing for nearly two
years. On November 5, 2010, Idaho Power, Avista Corporation ("Avista"), and
IDAHO POWER COMPANY'S OBJECTION TO PETITION TO INTERVENE BY BIG
WOOD CANAL COMPANY AND AMERICAN FALLS RESERVOIR DISTRICT NO. 2-I
PacifiCorp d/b/a Rocky Mountain Power ("PacifiCorp") (collectively the "Utilities") filed a
Joint Petition requesting that the Commission lower the published rate eligibility cap for
Qualifying Facilities ("QFs") and initiate an investigation to address avoided cost issues
related to the Commission's implementation of the Public Utility Regulatory Policies Act
of 1978 ("PURPA"). In response, a number of QFs submitted comments objecting to
the Utilities' request to lower the published rate eligibility cap, including the Petitioners
who, while not parties to that proceeding, submitted comments to the Commission via
letters dated December 17, 2010.1 On February 7, 2011, the Commission issued Order
No. 32176 in Case No. GNR-E-10-04, which granted in part and denied in part the
Utilities' request to temporarily reduce the published rate eligibility cap for QFs. In
addition, Order No. 32176 directed the parties to that proceeding to establish a
procedural schedule to explore the possibility of developing a published avoided rate
cap structure that allowed small wind and solar QFs to avail themselves of published
avoided cost rates for projects producing 10 average megawatts or less and that
prevents large QFs from disaggregating in order to obtain a published avoided cost rate
that exceeds a utility's avoided cost. Order No. 32176 at 11.
That proceeding became Case No. GNR-E-11-01, which the Commission
designated as "Phase II of GNR-E-1 0-04." In that case, Idaho Power submitted prefiled
direct testimony which, among other things, proposed the use of the Integrated
Resource Plan ("IRP") methodology to establish the published rate for eligible QFs.
Avista and PacifiCorp submitted prefiled direct testimony in GNR-E-1 1-03 as well.
1 Letter dated December 17, 2010, to the Commission submitted in Case No. GNR-E-10-04 from
Lynn Harmon, General Manager, American Calls Reservoir District No. 2
(http://www.puc.idaho.pov/internet/cases/elec/GNRJGNRE1 004/ubIic%20comments/201 01221 COMMENTS.PDF) and letter
dated December 17, 2010, to the Commission from Lynn Harmon, General Manager, Big Wood Canal
Company (http://www.Duc.idaho.pov/internet/cases/elec/GNR/GNRE1 004/public%20comments/201 01 22OCOMMENTS.PDF).
IDAHO POWER COMPANY'S OBJECTION TO PETITION TO INTERVENE BY BIG
WOOD CANAL COMPANY AND AMERICAN FALLS RESERVOIR DISTRICT NO. 2 - 2
The Commission issued Order No. 32262 in Case No. GNR-E-1 1-01 on June 8,
2011, which, among other things, maintained the 100 kilowatt ("kW") eligibility cap for
published avoided cost rates for wind and solar Us and initiated "additional
proceedings to allow the parties to investigate and analyze both the SAR Methodology
and the IRP Methodology (GNR-E-11-03)." Order No. 32262 at 8. Notably, the
Commission said, "We encourage a full examination of the application of the IRP
Methodology and are open to considering alternatives to the current methodologies."
Order No. 32262 at 9.
Per a requirement in Order No. 32262, the parties convened and established a
procedural schedule for Case No. GNR-E-11-03. On November 2, 2011, the
Commission issued Order No. 32388, which reiterated the scope of the issues that
could be addressed in Case No. GNR-E-1 1-03: "To review the terms of PURPA power
purchase agreements including, but not limited to, the surrogate avoided resource
(SAR) and Integrated Resource Planning (IRP) methodologies for calculated avoided
cost rates." Order No. 32388 at I citing Order No. 32352. Order No. 32388 also
established a procedural schedule for the case, specifically providing deadlines for the
submittal of testimony, discovery cut-offs, the filing of legal briefs, and the date of the
hearing.
On January 31, 2012, pursuant to the procedural schedule set by Order No.
32388, Idaho Power, Avista, and PacifiCorp submitted prefiled direct testimony. Idaho
Power submitted testimony from five witnesses covering a broad array of PURPA-
related issues. Shortly thereafter, and continuing until just very recently, Idaho Power
responded to numerous, detailed discovery questions consisting of hundreds of pages
of responsive materials. Commission Staff and numerous intervenors submitted
IDAHO POWER COMPANY'S OBJECTION TO PETITION TO INTERVENE BY BIG
WOOD CANAL COMPANY AND AMERICAN FALLS RESERVOIR DISTRICT NO. 2 - 3
prefiled testimony on May 4, 2012. Discovery among all parties ensued; discovery
served on the utilities continued. On June 29, 2012, parties submitted rebuttal
testimony. The discovery cut-off on rebuttal testimony occurred on July 6, 2012. Legal
briefs in this case are due July 20, 2012. A three-day technical hearing is scheduled for
August 7-9.
Petitioners submitted its petition for late-filed intervention on July 13, 2012.
II. ARGUMENT
Idaho Public Utilities Commission Rule of Procedure 73 sets forth timeliness
requirements for petitions to intervene in a Commission proceeding. The rule states:
Petitions not timely filed must state a substantial reason for
delay. The Commission may deny or conditionally grant
petitions to intervene that are not timely filed for failure to
state good cause for untimely filing, to prevent disruption,
prejudice to existing parties or undue broadening of the
issues, or for other reasons. Intervenors who do not file
timely petitions are bound by orders and notices earlier
entered as a condition of granting the untimely petition.
Idaho Power objects to the Petition to Intervene for failure to state good cause,
disruption of the proceedings, prejudice to existing parties, and unduly broadening of
the issues in the case. In the alternative, should the Commission allow Petitioners to
intervene in the case, they should be strictly limited to accept the record as it exists up
to this point and in scope of issues identical to that of the parties they are joining in
order to prevent undue expansion of the issues.
A. The Petition to Intervene Should be Denied for Failure to State Good Cause
for the Delay.
In this case, the time for which petitions to intervene must be filed was set by
Order No. 32352 as September 8, 2011—more than 10 months ago. Pursuant to RP
73, petitions filed after that date must state a substantial reason for delay. Petitioners
IDAHO POWER COMPANY'S OBJECTION TO PETITION TO INTERVENE BY BIG
WOOD CANAL COMPANY AND AMERICAN FALLS RESERVOIR DISTRICT NO. 2 - 4
state that they were "only recently able to confirm" that the proposals made by the
Utilities in this proceeding could have a substantial impact on their rights and
obligations. Pet. to Intervene at 2. Specifically, Petitioners state that the issues which
could directly or indirectly affect their rights and obligations include Schedule 74
"curtailment," the absence of carbon related costs in the proposal, proposed contract
terms, and standard offer cap limits.
In its expansive prefiled testimony filed on January 31, 2012, Idaho Power
submitted testimony sponsoring its proposed Schedule 74, the removal of carbon costs
from the Company's proposed IRP-based, hourly incremental pricing methodology, as
well as testimony proposing a variety of changes to terms and conditions of standard
PURPA contracts. Thus, these proposals have been publicly available for nearly six
months. Petitioners offer no explanation as to why they could "only recently" confirm
that these proposals may have an impact on them even though several hundred pages
of testimony and supporting documents describing these proposals were filed in
January 2012.
More glaring, the issue of "standard offer cap limits" was the issue teed-up by the
Utilities' Joint Petition in November 2010 and was the primary issue in Case No. GNR-
E-10-4. As noted above, Petitioners submitted comments in that proceeding opposing
the Utilities' proposal to reduce the standard rate eligibility cap to 100 kW on December
17, 2010—more than 18 months ago. Thus, Petitioners had actual notice more than
I /2 years ago that standard offer cap limits for QFs is an issue before the Commission.
For Petitioners to now assert that they are "only recently able to confirm" that the
proposals related to standard offer cap limits could impact them is disingenuous at best.
IDAHO POWER COMPANY'S OBJECTION TO PETITION TO INTERVENE BY BIG
WOOD CANAL COMPANY AND AMERICAN FALLS RESERVOIR DISTRICT NO. 2 - 5
Thus, Petitioners have had notice of the issues in this case from anywhere
between six and 18 months. The Petition to Intervene fails to describe why they had to
wait until one week before legal briefs are to be filed in this case and only a little more
than three weeks before the hearing in this case is to be held to "confirm" the potential
impacts of this case. Instead, the Petition contains a statement that "Petitioners were
only able to confirm through review of direct testimony and discovery and after joint
meeting of both boards that the proposals by Idaho Power Company could have
substantial impact on the Petitioners' right and obligations." Pet. to Intervene at 2.
Idaho Power finds this assertion untenable. As noted above, Petitioners had actual
notice of at least one issue they identify more than 18 months ago, and should have had
notice of the other issue since January 31, 2012, when Idaho Power filed its direct
testimony in this case.
Petitioners have had ample time to review the testimony and make a
determination on whether the case will impact them. Instead, they put off filing for
intervention until one week prior to the date on which briefs are due by the parties.
Petitioners' failure to adequately assess the issues and make a timely determination
even though all information needed to make such an assessment was publicly available
for nearly six months previous does not constitute good cause for delay. The
Commission should deny the Petition to Intervene because a potential party's prolonged
decision making is not a substantial reason for untimely filing.
B. The Commission Should Deny the Petition to Intervene Because It Will
Disrupt the Case. Prejudice the Parties, and Unduly Broaden the Issues.
Petitioners' significant delay in filing for intervention will disrupt the proceedings,
prejudice existing parties, and unduly broaden the issues in the case.
IDAHO POWER COMPANY'S OBJECTION TO PETITION TO INTERVENE BY BIG
WOOD CANAL COMPANY AND AMERICAN FALLS RESERVOIR DISTRICT NO. 2 - 6
Petitioners have chosen to intervene so late in the proceedings that they cannot
be accommodated without considerable disruption in the case. Notably, this very
objection to their late-filed Petition is due on the same day as legal briefs in the case.
Idaho Power has devoted significant time and energy toward preparing its legal brief (as
well as all other aspects of this case) and this filing diverts its attention from that
important pleading in order to object to their untimely Petition. This alone is a
substantial disruption and hardship to Idaho Power.
Furthermore, due to the proximity of the filing to the deadline for filing of briefs in
the case, the Commission Staff Attorney directed that even potential parties should file
legal briefs by the current schedule's July 20 deadline and that the Commission would
make subsequent determination as to the admissibility of such legal briefs at its July 30
decision meeting .2 The fact that non-parties to the case have an opportunity to submit
legal briefs for subsequent evidentiary determination by the Commission is a disruption
to this proceeding. Specifically, the Commission has to engage in special procedure to
allow this to occur. The Commission should not disrupt these proceedings simply to
accommodate the Petitioners' untimely request. The better approach is for the
Commission to deny their request for intervention.
Similarly, this extremely late filing prevents the opportunity for discovery and
timely assessment of issues as they may relate to Petitioners and the impact their
intervention could have on Idaho Power's case. At this point in the case, when
discovery is complete and the parties are wrapping up their issues for Commission
decision, it is highly prejudicial to allow new potential parties to join. The hearing in this
case set for August 7-9 is effectively the culmination of close to two years of research,
2 E-mail from Kristine Sasser, Deputy Attorney General, to parties of record in Case No. GNR-E-1 1-03.
IDAHO POWER COMPANY'S OBJECTION TO PETITION TO INTERVENE BY BIG
WOOD CANAL COMPANY AND AMERICAN FALLS RESERVOIR DISTRICT NO. 2 - 7
analysis, and efforts. It is the tail end of a very involved case and is detrimental to
current parties in the case to allow extremely late filed intervenors to enter the fray.
Furthermore, the inclusion of the Petitioners is likely to unduly broaden the issues
in the case. Petitioners state that they do not seek to present additional arguments.
However, one of the Petition's stated issues is "the absence of carbon costs in the
proposal." Petition at 2. Based on the dearth of information in the Petition, it is unclear
what "proposal" this issue is related to. Idaho Power submitted testimony proposing an
IRP-based, hourly incremental avoided cost pricing method that removed assumed
carbon costs to establish the rate. Idaho Power assumes this is the issue referred to by
the Petitioners. However, Petitioners may be referring to the absence of carbon costs in
the Schedule 74 proposal. If this is indeed the case, it is potentially a new issue which
would unduly broaden the issues already presented in this case. Importantly, because
the discovery cut-off in this proceeding has already occurred, Idaho Power has no
opportunity to submit discovery requests to determine the scope of the issues which
Petitioners seek to address.
Idaho Power believes that the Petitioners' interests may already be represented
by other parties to the case. It is possible Petitioners are members of the Northwest
Intermountain Power Producers Coalition, the Renewable Energy Coalition, and/or
another industry organization that is already a party to this case and that those
organizations will adequately represent their interests. Again, because the time for
discovery has passed, it is impossible for Idaho Power or this Commission to know
whether this is the case.
In light of the burdensome nature of the request, its disruption of proceedings,
prejudice to other parties, and expansion of issues, the Petitioners' lingering decision-
IDAHO POWER COMPANY'S OBJECTION TO PETITION TO INTERVENE BY BIG
WOOD CANAL COMPANY AND AMERICAN FALLS RESERVOIR DISTRICT NO. 2 - 8
making process is not an adequate, much less a substantial, reason for delay that
justifies granting the Petition to Intervene. Accordingly, the Commission should deny
Petitioners' request for intervention.
C. If the Commission Grants the Petition to Intervene, Petitioners'
Participation in the Case Should Be Limited.
In the alternative, if the Commission grants the Petition to Intervene, in order to
mitigate the adverse effects on existing parties to the case, the Commission should
make such inclusion conditional. Notably, the Petitioners have offered that their
"participation will be limited to joining the position taken by Twin Falls Canal Company
and North Side Canal Company, and the presentation of the same evidence, cross-
examination briefing and argument." Pet. to Intervene at 3. Accordingly, if the
Commission grants Petitioners' intervention, the Commission should strictly limit
Petitioners participation and they should be required to accept the record as it currently
exists as objections to the record at this stage in the proceeding would create undue
hardship and expansion of the issues. In addition, Petitioners should also be strictly
limited to joining the scope of inclusion and positions taken by the Twin Falls Canal
Company and North Side Canal Company in order to avoid unduly expanding the
issues to be addressed.
Ill. CONCLUSION
Because the Petitioners have not shown good cause or a substantial reason for
untimely filing of the Petition to Intervene and because granting the Petition would
create disruption, prejudice, and unduly expand the issues, Idaho Power respectfully
requests that the Commission deny the Petition to Intervene. In the alternative, if the
Commission grants the Petition, Idaho Power respectfully requests that the Commission
IDAHO POWER COMPANY'S OBJECTION TO PETITION TO INTERVENE BY BIG
WOOD CANAL COMPANY AND AMERICAN FALLS RESERVOIR DISTRICT NO. 2 - 9
substantially limit the Petitioners' ability to alter the record and limit them to joining in the
arguments of the Twin Falls and North Side Canal Companies.
DATED at Boise, Idaho, this 20th day of July 2012.
LA
B. WILLIAMS
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S OBJECTION TO PETITION TO INTERVENE BY BIG
WOOD CANAL COMPANY AND AMERICAN FALLS RESERVOIR DISTRICT NO. 2-10
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 20l day of July 2012 I served a true and correct
copy of IDAHO POWER COMPANY'S OBJECTION TO PETITION TO INTERVENE BY
BIG WOOD CANAL COMPANY AND AMERICAN FALLS RESERVOIR DISTRICT NO.
2 upon the following named parties by the method indicated below, and addressed to
the following:
Commission Staff
Kristine A. Sasser
Deputy Attorney General
Idaho Public Utilities Commission
472 West Washington (83702)
P.O. Box 83720
Boise, Idaho 83720-0074
Avista Corporation
Michael G. Andrea
Avista Corporation
1411 East Mission Avenue, MSC-23
Spokane, Washington 99202
PacifiCorp d/bla 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
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Exergy Development Group of Idaho, LLC Hand Delivered
James Carkulis, Managing Member X U.S. Mail
Exergy Development Group of Idaho, LLC Overnight Mail
802 West Bannock Street, Suite 1200 FAX
Boise, Idaho 83702 X Email jcarkuIisexerc1ydeveloDment.com
IDAHO POWER COMPANY'S OBJECTION TO PETITION TO INTERVENE BY BIG
WOOD CANAL COMPANY AND AMERICAN FALLS RESERVOIR DISTRICT NO. 2-li
Dr. Don Reading _Hand Delivered
6070 Hill Road X U.S. Mail
Boise, Idaho 83703
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drbenjohnsonassociates.com
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
Mary Lewallen
Clearwater Paper Corporation
601 West Riverside Avenue, Suite 1100
Spokane, Washington 99201
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IDAHO POWER COMPANY'S OBJECTION TO PETITION TO INTERVENE BY BIG
WOOD CANAL COMPANY AND AMERICAN FALLS RESERVOIR DISTRICT NO. 2-12
Renewable Energy Coalition and Dynamis
Energy, LLC
Ronald L. Williams
WILLIAMS BRADBURY, P.C.
1015 West Hays Street
Boise, Idaho 83702
Renewable Energy Coalition
John R. Lowe, Consultant
Renewable Energy Coalition
12050 SW Tremont Street
Portland, Oregon 97225
Dynamis Energy, LLC
Wade Thomas, General Counsel
Dynamis Energy, LLC
776 East Riverside Drive, Suite 150
Eagle, Idaho 83616
Interconnect Solar Development, LLC
R. Greg Ferney
MIMURA LAW OFFICES, PLLC
2176 East Franklin Road, Suite 120
Meridian, Idaho 83642
Bill Piske, Manager
Interconnect Solar Development, LLC
1303 East Carter
Boise, Idaho 83706
Renewable Northwest Project, Idaho
Windfarms, LLC, and Ridgeline Energy LLC
Dean J. Miller
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
421 SW 6th Avenue, Suite 1125
Portland, Oregon 97204
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IDAHO POWER COMPANY'S OBJECTION TO PETITION TO INTERVENE BY BIG
WOOD CANAL COMPANY AND AMERICAN FALLS RESERVOIR DISTRICT NO. 2-13
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
ELECTRONIC SERVICE ONLY
Lori Thomas
CAPITOL LAW GROUP, PLLC
205 North 1 0th Street, 4th Floor
P.O. Box 2598
Boise, Idaho 83701-2598
ELECTRONIC SERVICE ONLY
Donald W. Schoenbeck
RCS, Inc.
900 Washington Street, Suite 780
Vancouver, Washington 98660
ELECTRONIC SERVICE ONLY
Twin Falls Canal Company
Brian Olmstead, General Manager
Twin Falls Canal Company
P.O. Box 326
Twin Falls, Idaho 83303
ELECTRONIC SERWCE ONLY
North Side Canal Company
Ted Diehl, General Manager
North Side Canal Company
921 North Lincoln Street
Jerome, Idaho 83338
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IDAHO POWER COMPANY'S OBJECTION TO PETITION TO INTERVENE BY BIG
WOOD CANAL COMPANY AND AMERICAN FALLS RESERVOIR DISTRICT NO. 2-14
Birch Power Company
Ted S. Sorenson, P.E.
Birch Power Company
5203 South 1 1 th East
Idaho Falls, Idaho 83404
Blue Ribbon Energy LLC
M.J. Humphries
Blue Ribbon Energy LLC
3470 Rich Lane
Ammon, Idaho 83406-7728
Arron F. Jepson
Blue Ribbon Energy LLC
10660 South 540 East
Sandy, Utah 84070
Idaho Conservation League
Benjamin J. Otto
Idaho Conservation League
710 North Sixth Street (83702)
P.O. Box 844
Boise, Idaho 83701
Snake River Alliance
Liz Woodruff, Executive Director
Ken Miller, Clean Energy Program Director
Snake River Alliance
P.O. Box 1731
Boise, Idaho 83701
Energy Integrity Project
Tauna Christensen
Energy Integrity Project
769 North 1100 East
Shelley, Idaho 83274
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IDAHO POWER COMPANY'S OBJECTION TO PETITION TO INTERVENE BY BIG
WOOD CANAL COMPANY AND AMERICAN FALLS RESERVOIR DISTRICT NO. 2-15
Idaho Wind Partners I, LLC Hand Delivered
Deborah E. Nelson X U.S. Mail
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GIVENS PURSLEY LLP FAX
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P.O. Box 2720 kincc1ivensDursley.com
Boise, Idaho 83701-2720
(McA
Christa Bearry, Legal Assistant
IDAHO POWER COMPANY'S OBJECTION TO PETITION TO INTERVENE BY BIG
WOOD CANAL COMPANY AND AMERICAN FALLS RESERVOIR DISTRICT NO. 2-16
Christa Bearry,
NON-PARTY CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 20th day of July 2012 I served a true and correct
copy of the IDAHO POWER COMPANY'S OBJECTION TO PETITION TO INTERVENE
BY BIG WOOD CANAL COMPANY AND AMERICAN FALLS RESERVOIR DISTRICT
NO. 2 upon the following individuals who are not named parties in this proceeding by
the method indicated below, and addressed to the following:
Big Wood Canal Company and American
Falls Reservoir District No. 2
C. Thomas Arkoosh
CAPITOL LAW GROUP, PLLC
205 North 1 0th Street, 4th Floor
P.O. Box 2598
Boise, Idaho 83701-2598
Mountain Air Projects, LLC
J. Kahle Becker
The Alaska Center
1020 West Main Street, Suite 400
Boise, Idaho 83702
Michael J. Uda
UDA LAW FIRM, P.C.
7 West 6th Avenue, Suite 4E
Helena, Montana 59601
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IDAHO POWER COMPANY'S OBJECTION TO PETITION TO INTERVENE BY BIG
WOOD CANAL COMPANY AND AMERICAN FALLS RESERVOIR DISTRICT NO. 2-17