20050701Gale Direct.pdf

""
r f 'r'
t..LCI\/t. l;'
ILE::O
10115 Jut - I Pt~1 4:4'
InllHO PUBLiC
UTILl,.-IES C OHHiSSION
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE PETITION OF
IDAHO POWER COMPANY FOR AN ORDER
TEMPORARILY SUSPENDING IDAHO
POWER'S PURPA OBLIGATION TO ENTER
INTO CONTRACTS TO PURCHASE ENERGY
GENERATED BY WIND-POWERED SMALL
POWER PRODUCTION FACILITIES.
) CAS E
IDAHO POWER COMPANY
DIRECT TESTIMONY
JOHN R. GALE
NO. IPC-E- 05 -
Please state your name and business address.
My name is John R. Gale and my business address
is 1221 West Idaho Street, Boise, Idaho.
By whom are you employed and in what capacity?
I am employed by Idaho Power Company as the
Vice President of Regulatory Affairs.
and a Masters
University.
Please describe your educational background.
I hold a Bachelors of Business Administration
of Business Administration from Boise State
I serve as an advisor to the University s College
of Business and Economics.Additionally, I have completed the
Edison Electric Insti tute ' s Advanced Ratemaking School and the
University of Idaho's Public Utility Executive Course.
Powe r Company.
Please describe your work experience with Idaho
In October 1983, I accepted a position as Rate
Analyst with Idaho Power Company.In March 1990, I was
assigned to the Company s Meridian District Office for one
year where I held the position of Meridian Manager.In March
1991, I was promoted to Manager of Rates.In July 1997, I was
named General Manager of Pricing and Regulatory Services.
March of 2001, I was promoted to Vice President of Regulatory
Affairs.As Vice President of Regulatory Affairs, I am
responsible for the overall coordination and direction of the
GALE, DI
Idaho Power Company
Pricing & Regulatory Department, including development of
jurisdictional revenue requirements and class cost-of~service
studies, preparation of rate design analyses, and
administration of tariffs and customer contracts.In my
current position am also responsible for policy matters
related to the economic regulation Idaho Power Company
( "
I daho Power"Company
Q .What topics will you discuss in your testimony
in this proceeding?
I will discuss the role of the Integrated
Resource Plan ("IRP") at Idaho Power Company, the Company
actions to implement the IRP recommendations, the
complications encountered in acquiring the wind resources
described in the 2004 IRP portfolio , the resulting request for
a temporary suspension in wind purchases under the Public
Utility Regulatory policies Act of 1978 ("PURPA", and a
recommendation on handling transitional PURPA agreements.
What is the Integrated Resource Plan?
The Integrated Resource Plan is a comprehensive
look at Idaho Power's present and future demands for
electricity, as well as a plan for meeting those demands.The
plan addresses how Idaho Power expects to meet its Idaho and
Oregon customers ' growing electrical demand over a 10-year
planning horizon.The IRP describes the Company's proj ected
GALE, Dr
Idaho Power Company
need for additional electrici ty and the resources necessary to
meet that need while maintaining reliability and efficiency.
Both the Idaho and Oregon public utility commissions require
state electric utilities to file an IRP every two years.The
current plan was filed with the commissions in August 2004.
What purpose does the IRP serve at Idaho Power?
The IRP is the Company's principal resource
planning document and the foundation for making resource
acquisition decisions.The near- term action items described
in the plan serve as a blueprint for Company action.
Obviously, circumstances change over time and these
circumstances are considered along wi th the IRP as part of
resource acquisition decisions.Nevertheless, the IRP is our
starting point.
Please generally describe the resul ts of the
most recent IRP.
The 2004 IRP is the Company s most recently
completed plan.The plan examined 12 different resource
portfolios and ultimately selected a diversified portfolio
wi th nearly equal amounts of renewable generation and
tradi tional thermal generation as the preferred resource
portfolio.The 2004 IRP has been accepted for filing by the
Idaho Public Utili ties Commisslon IPUC"Commission and
acknowledged by the Public Utility Commission of Oregon.
GALE, DI
Idaho Powe r Company
the 2004 IRP?
What were the near-team actions identified
For Fall 2004, the following actions were
identified:(1) issue an RFP for 200 MW wind resource,(2 )
issue an RFP for a peaking resource,(3) proceed with the
Borah-West transmission upgrade,(4) file a supplement to the
2004 IRP presenting the results of the ongoing demand-side
management studies, and (5) file for an energy efficiency
tariff rider with the Oregon Public Utilities Commission.For
2005 these additional actions were identified:(1) design
demand-side measures in coordination with the Energy
Efficiency Advisory Group and the Public Utility Commissions,
(2) issue an RFP for 12 MW CHP , and (3) issue an RFP for 100
MW geothermal resource.
What specifically did the 2004 IRP call for in
the way of wind resources?
The 2004 IRP called for 200 MW of wind
resources to be implemented via Requests for Proposals
RFPs") issued in 2005 and an additional 150 MW of wind
resources to be implemented via RFPs issued in 2008.The
total amount of wind resources called for during the planning
period was 350 MW.
Wha t has the Company done to procure the wind
resources identified in the 2004 IRP?
GALE, DI
Idaho Power Company
Idaho Power initiated an RFP process to procure
200 MW of wind resource on January 13, 2005.The Company
received offers in response to the RFP on March 10, 2005.
Has the Company encountered any circumstances
that impact the implementation of the 2004 IRP near-term
actions, including the procurement of wind resources?
Yes.As Idaho Power attempted to execute its
RFP for wind resources , it became evident that the prices and
contracts available to wind resources under PURPA were
influencing the RFP process.Significant amounts of wind
generation began to materialize under PURPA at prices above
the levels contemplated in the IRP.Bids in the RFP process
were much closer to the PURPA price than the IRP price.
Additionally, it was evident that unsuccessful RFP bidders
could repackage their proj ects to fit PURPA.Once these
influences became apparent, Idaho Power realized that it had
to act to address the potential of much more wind coming on-
line sooner and more expensively than contemplated in the IRP.
The concern with wind resources was the possibility of
receiving quantities that were too much , too soon, and too
expens i ve .
Under what authority is Idaho Power obligated
to purchase electric energy produced by cogeneration and small
production facilities?
GALE , DI
Idaho Powe r Company
Sections 201 and 210 of PURPA require electric
utilities to offer to purchase electric energy generated by
qualifying cogeneration and small power production facilities.
PURPA requires that state commissions set the rates for
purchases of power from Qualifying Facilities ("QFs ) at
levels that are just and reasonable to the utility
customers, in the public interest and that do not discriminate
against QFs.PURPA specifies that the purchase rates set by
state commissions for electric utility purchases of energy
generated by QFs may not exceed the incremental cost to the
electric utility of the electric energy which , but for the
purchase from such QFs, the utility would generate or purchase
from another source.
Has the Commission established avoided cost
purchase rates or "published rates" which Idaho Power
legally obligated to offer QFs?
Yes.In Order No. 29646, issued by the IPUC on
December 1 , 2004 in Case No. IPC-04-25, the Commission
established the published rates that Idaho Power is obligated
to offer to QFs that generate less than 10 average MW per
mon th
What is the current average levelized published
rate for 20-year contracts as established by the IPUC?
GALE, DI
Idaho Powe r Company
The current average levelized published rate
for a 20-year contract that is scheduled to be online in 2006
is $60.99 per MWh.
Before the issuance of Order No. 29646, how
many megawatts of QF wind-powered generation did Idaho Power
have on contract?
Prior to the issuance of Order no. 29646, Idaho
Power had less than 1 MW of QF wind-powered generation under
PURPA contracts.
What was the published rate for 2003 QF
contracts?
The published rate for 2003 QF contracts set in
IPUC Order No. 29124 was approximately $48.61 per MWh for a
project scheduled to come online in 2003 which is 25% less
than today s levelized published purchase rates.
How many megawatts of PURPA resources have been
approved by the Commission within the Idaho Power service
territory since the issuance of Commission Order No. 29646?
Since the issuance of Order No. 29646, 71.5 MW
of nameplate capaci ty have been approved by the Commission.
Are there any pending applications before the
IPUC for approval of additional wind-powered QF contracts?
GALE, DI
Idaho Power Company
Idaho Power presently has applicationsYes.
before the Commission for 21 MW of additional wind-powered QF
contracts.
Has the Company received inquiries from other
wind-powered QF developers?
Yes.Idaho Power has received numerous
inquiries from potential developers of new wind proj ects
Based on information presented by the developers to Idaho
Power on issues including, but not limited to , site control,
equipment supply and wind studies, Idaho Power estimates these
inquiries represent an additional 193 MW of wind-powered
generation that has the potential of developing into actual QF
proj ects
In the Company s opinion , are there other
factors besides the 2004 published avoided cost rate that has
stimulated this sudden increase in wind-powered QF development
in Idaho?
Certain tax incentives adopted at theYes.
state and federal levels have stimulated wind-powered QF
development.Just prior to the issuance of IPUC Order No.
29646, the federal government reinstated the production Tax
Credit ("PTC") for wind generation.The reinstated PTC
provides proj ect owners a tax credit of approximately $19 per
MWh for the first 10 years of the project's operation.That
GALE, DI
Idaho Power Company
production tax credit, together with accelerated depreciation
rules and other tax incentives at the federal level, 'has
stimulated the development of wind generation.At the state
level, the Idaho legislature recently enacted sales tax
exemptions (Idaho Code, ~ 63-3622QQ) to encourage the
development of alternative generating resources, including
wind.In addition, recent IPUC Orders that have increased the
term of QF contracts to 20 years (IPUC Order No. 29124) and
have made proj ects producing less than 10 average MW per month
eligible to receive the published rates (IPUC Order No. 29632)
have created a fertile environment for wind development.
The combination of federal and state tax incentives,
the increase in energy purchase rates established in Order No.
29646, and the favorable contract terms and conditions
described above, plus the fact that QF developers retain the
right to any green tags associated wi th QF development, have
all played a role in the rapid increase in the number of QFs,
including wind-powered QFs, seeking contracts to sell their
generation to Idaho Power.
Has the increased QF activity impacted the
responses to a Request for Proposals issued by the Company?
I believe so.As previously stated, the 2004
IRP called for 350 MW of wind-powered resources to be acquired
in the near term, 200 MW in 2005, and an additional 150 MW in
GALE, DI
Idaho Power Company
2008.In deciding to move forward with an RFP program to
competitively acquire wind resources, Idaho Power was hopeful
that a bidding process would allow the Company to take
advantage of competition and the economies of scale associated
with large-sized wind generation projects.Idaho Power
anticipated that this strategy would moderate the total cost
of wind energy acquired by averaging the higher cost of
smaller QF wind proj ects acquired at the avoided cost rate
wi th the presumably lower cost of wind acquired by competi ti ve
RFPs .
Have these expectations been met?
No, these expectations have not been met.The
bids received in response to the 2005 RFP are, on average
higher than the levelized prices contemplated in the 2004 IRP.
Is it possible that the published rates for QFs
influenced the bidding?
Yes, I believe so.
On what basis is Idaho Power establishing this
belief?
To begin with , Idaho Power s 2004 IRP modeled
costs to acquire wind resources was $42.94 per MWh based upon
information obtained from public sources and wind developers.
The Company also was aware of recent announcements made by
other regional utili ties concerning power purchase agreements
GALE, DI
Idaho Powe r Company
they had entered into wi th wind resource developers with
substantially lower pricing structures.In the state of
Montana, for example, NorthWestern Energy recently received
approval from the Public Service Commission of Montana (Final
Order No. 6633b, issued on March 31, 2005) for an agreement
with Judith Gap LLC under which NorthWestern will purchase
135-150 MW of wind resource at a price of $31.71 per MWh.
What impact has the accelerated level of QF
wind development had on Idaho Power's recently issued Request
for Proposals for 200 MW of wind-powered resources?
In light of the large number of MWs of QF wind
resources already acquired, approved and proposed, and the
high bid prices received in the 2005 RFP , it is almost certain
that Idaho Power will reduce the amount of wind generation
will obtain through the 2005 RFP.At the same time, it
likely that the 2008 RFP will need to be either reduced or
eliminated altogether.
If Idaho Power reduces or eliminates the amount
of wind required in the 2005 and 2008 RFPs, does the
possibility exist that wind developers who either responded to
or intend to respond to future RFPs will submit applications
for QF developments?
Yes.That is a real concern to the Company.
With only minor modifications, it would not be difficult for a
GALE, DI
Idaho Power Company
larger wind proj ect to be reconf igured into several smaller
proj ects each of which would qualify for the published rates.
What would be the consequences to Idaho Power
and its customers if previous RFP bidders reconfigured their
facilities to comport with PURPA requirements and Idaho Power
were required to acquire a disproportionate quantity of wind
powered generation through PURPA?
That scenario would lock the Company and its
customers into long- term contracts at prices that the Company
asserts are not appropriate for an intermittent energy
resource such as wind-powered generation.These circumstances
could potentially create an unmanageable influx of
intermittent generation on the Company s system.
Could the addition of large amounts of QF wind
generation adversely affect the reliability of Idaho Power'
system?
Yes, the addition of large amounts of QF wind
generation could adversely affect system reliability.Wind
generation is an intermi t tent resource subj ect to the natural
variabili ty in the wind.Thus, the energy output from this
resource may fluctuate tremendously from hour-to-hour or even
minute-to-minute independent of Idaho Power s system needs.
For example, a 10 MW wind facility may be at full output at
one moment and minutes later be at a very low to no output.
GALE , DI
Idaho powe r Company
As a result of these wind generation fluctuations and to
assure system reliability, wind-powered generation must be
firmed" by ancillary services.
By what means can intermittent wind resources
be firmed?
Firming of a wind resource can be provided by
the purchase of load- following services and reserves from a
third party if the ancillary services and transmission are
available on a firm, long-term basis.Alternatively, firming
can be self-provided by the utility primarily through other
resources in the utility s power supply portfolio, such as
excess hydro capacity or gas-fired combustion turbines, that
the utility can dispatch as necessary.
Does the combined cycle combustion turbine,
adopted by the Commission as the surrogate avoided cost
resource for setting avoided costs, adequately establish the
costs of integrating intermi t tent wind resources into Idaho
Power's system?
No, it does not.That surrogate avoided cost
methodology does not consider the costs associated with the
ancillary services, described in my earlier testimony, that
are required to reliably integrate intermittent wind resources
onto the Company s system.Neither the Company nor the
GALE , DI
Idaho Powe r Company
Commission foresaw these consequences when the current process
for setting QF rates was established.
Is it fair to say that there are costs
associated with integrating intermittent wind resources onto
Idaho Power s system that are not reflected in the published
rates approved by the Commission?
Yes, that is a fair statement.
Wha t does the Company propose in response to
these circumstances?
In order to assess if wind resources are
impacting Idaho Power's system in a manner that is too much,
too soon , and too expens i ve , Idaho Power proposes to seek a
temporary suspension on new PURPA wind proj ects until the
impacts of integrating these resources onto the Company
system can be more thoroughly evaluated from a cost and
reliability standpoint.The Company anticipates that there
are a number of activities that will facilitate this
evaluation.
What activities does Idaho Power anticipate
will need to be taken during a suspension period if the
Commission would approve such request?
Idaho Power proposes to undertake the following
acti vi ties during a Commission-approved suspension period:
(1) the Company would retain an independent third party
GALE, DI
Idaho Power Company
consultant to assist Idaho Power in preparing an analysis
which would assess the total amount of addi tional wind
resources the Company s system can absorb without adversely
affecting the Company s overall power supply costs and system
reliability;(2) Idaho Power would prepare and file with the
Commission a proposal for computing avoided costs specifically
tailored to the attributes of intermittent wind-powered
resources, including the addi tional costs attributable to
peaking resources required to integrate significant amounts of
wind generation into Idaho Power s resource portfolio; and (3)
Idaho Power would prepare and present to the Commission a
report describing possible steps that could be taken to
increase the likelihood that future RFPs for wind resources
reflect actual resource costs and market prices for wind
resources rather than published avoided cost rates for all
types of smaller QF proj ects This analysis would also
include a review of the benefits and detriments to Idaho Power
of an ownership option for wind resources as a way to provide
pricing discipline wi th the RFP process.
Historically, avoided cost rates specifically
targeted to individual QF generating technologies have not
been developed.Why should the Commission consider this
practice now?
GALE, DI
Idaho Power Company
Only recently has the Company become aware
the unique set of challenges that intermittent wind resources
present to Idaho Power's system.As I've already testified,
nei ther the Commission nor the Company foresaw the impact
intermittent wind resources on a utility s system when the
present surrogate avoided cost methodology was established.
The Commission should consider a specific wind technology
avoided cost rate because of the unique intermittent nature of
wind resources and the large number of actual and potential QF
wind resources that are seeking PURPA contracts wi th Idaho
Power.A reassessment of how the avoided costs should be
computed for wind generating resources should be undertaken.
That analysis, for the first time, would consider the costs of
firming and reliably integrating QF wind resources into the
Company s system.
In the Company s estimation, should the
Commission conduct a review of system reliability issues and
wind-specific avoided costs without instituting a temporary
suspension of mandatory PURPA purchases for new wind QF
proj ects?
In my Vlew , that approach is neither possible
nor prudent.Prior history has shown that when a utility asks
the Commission to consider changing avoided cost rates,
potential developers inundate the utility with contract and
GALE , DI
Idaho Power Company
interconnection requests in an effort to obtain the rates in
effect prior to the potential rescission of those rates and
adoption of newer, likely lower rates.A temporary suspens ion
of mandatory purchases of wind QF resources is imperative to
effectively address this unique issue and to avoid the adverse
impacts anticipated should the Company s system become deluged
wi th wind resources.
Has the Commission authorized temporary
suspensions of the PURPA contract obligation in the past?
Yes, my legal counsel has advised me that such
a suspension is not without precedent.In IPUC Order No.
19348 issued in Case No. U-1500-156, the Commission , on its
own motion , imposed a one-year moratorium on purchases from
QFs located within the service area of non-investor-owned
utilities that purchase energy supplies from Bonneville Power
Administration.That moratorium was eventually lifted and
Idaho Power is the purchaser of energy from QF proj ects
located in the service area of Idaho municipalities and
electric co-operatives.
Does the Company recommend that the suspension
apply to all wind agreements being negotiated between wind
developers and Idaho Power prior to the filing of Idaho
Power s peti tion in this proceeding?
GALE, Dr
Idaho Powe r Company
Idaho Power is aware that, should the
Commission grant the requested temporary suspension , one of
the decisions that must be made is how to apply the suspension
to those entities interested in the process of having QF
contracts negotiated and reviewed.To that end, the Company
does not intend to sign any addi tional agreements until the
IPUC provides some guidance on the Company s request.The
Company calls to the Commission s attention that a very
limited number of QF wind projects were in the final stages of
negotiations with Idaho Power immediately prior to the filing
of the Idaho Power peti tion.One proj ect in particular, Arrow
Rock Wind, Inc.Arrow Rock") executed an agreement with the
Company prior to the date that Idaho Power filed its petition
with the Commission.On June 24, 2005 , the Company received
copy of correspondence from Arrow Rock to the IPUC that
details the series of events leading to the execution of the
agreement.A copy of the agreement is provided as Exhibit No.
1 .
Idaho Power concurs wi th the statements made by Arrow
Rock contained in Exhibi t No.As noted in that letter,
energy deliveries from the Arrow Rock would not be the typical
type of intermittent energy generally associated with a wind
proj ect Instead, Arrow Rock has secured a firming agreement
with another utility.Accordingly, the energy delivered from
GALE, DI
Idaho Power Company
the proj ect to Idaho power will be a flat, firm, monthly
schedule of energy.
Due to the fact that negotiation of this agreement was
completed prior to the filing of the Petition in this
proceeding and the fact that the actual energy delivered to
Idaho Power will not be of the intermittent nature at issue in
this proceeding, the Company respectfully recommends that the
Commission consider Idaho Power's agreement with the Arrow
Rock Wind, Inc. proj ect as appropriate for exempting from the
temporary suspension request sought in this proceeding.
How long a suspension does Idaho Power
anticipate is needed to complete the above-referenced
activities and analyses?
It is my understanding that it will take
approximately six to nine months to conduct the necessary
acti vi ties and analyses.
How do you recommend that the Commission
proceed In this matter?
The Company respectfully requests that the
Commission issue its Order temporarily suspending for a period
of nine months Idaho Power's obligation under ~~ 201 and 210
of PURPA to enter into new contracts to purchase energy
generated by wind-powered QFs in order to permit the Company
and the Commission the opportunity to undertake the activities
GALE , DI
Idaho Power Company
and analyses described in this testimony.Should the studies
be completed sooner, Idaho Power would be supportive of an
earlier end to the suspension period.
Does that conclude your testimony?
Yes, it does.
GALE, DI
Idaho Power Company
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
IDAHO POWER COMPANY
Case No IPC-E-OS-22
Exhibit No
John R. Gale
'ViT B. 0 C ""WV" in. d, I.....
5203 South 11th East
Idaho Falls, Idaho 83404
Tel [phone]
fax [phone]
June 24, 2005
Idaho Pubic UtHitics COtl1mission
P. O. Box 83720
Boise, ID 83270-0074
Delivered via Facsimile: 208-334-3762
Subject: Arrow Rock Wind -.- QF Contract with Idaho Power
Dear Commissioners:
This letter is written pursuant to a firm energy sales agreement, which we have negotiated with Idaho
.Power. This contract was negotiated over the past several months with Idaho Power. In the normal
course of business ldaho Power forwarded a contract for our signature on June 16, 2005. 1 signed
this contract on June 18, 2005 and returned it to Idaho Power via overnight nulH, pursuant to Idaho
Contract Power Administrator Randy Allphin s letter of June 16 2005, a copy of which is attached.
The Idaho Power letter states that Idaho Power would s,ign the contract and forward to pue for
approval.
On Thursday, June 23, 2005, Arrow Rock was informed by Randy Allphin that Idaho Power had
filed a petition to suspend Idaho Power s requirement to sign PURPA wind contracts on June!?
2005 and until such time as Idaho Power received direction from the pue on this petition, Idaho
Power would not be signing any wind PU RP A contracts,
Generation projects require substantial planning periods and the resulting good faith negotiation for
the contract supporting the project was fully concluded and agreed upon on June :14, 2005. Idaho
Power negotiated the QF Agreement with Arrow Rock Wind in the nonnal course of business, \\ihiCh
included a unique arrangement in which Arrow Rock, rather than Idaho Power would 'be responsible
for flfming and shaping the intenllittent nature of the wind resource. The documentation clearly
demonstrates that the Arrow Rock project was fully negotiated prior to the June 17th Petition from
Idaho Po~er. The "mandatory contracting for purchases of wind QF resources" was completed
prior to IdahoPowcr~ s Petition.
The Arrow Rock Wind structure demonstrates that firming of 'intermittent resource does not
necessarily need to be the sole responsibility of host u6Jity. Therefore the Arrow Rock resource
does not maintain the reliability, ancillary service and integration character,istics that are the bas'is of
Idaho Power s Petition. The finn~ flat energy delivery to Idaho Power can easily be integTated into
thdr system and provides substantial value. In fact, Idaho Power recognized that the June
Petition would be limited to ;;'new contracts for purchases of energy from (intennittent) wind-
powered QFs. The suspension (request) would not. affect new contract with QFs utilizing other
generating technologies.
~~
The firm~ 11at energy structure places the cost of integration upon Arrow
Rock and as such mitigates the basis of concerns identified by Idaho Power. Inour opinion the firm
flat Arrow Rock project is actuaJly a superior resource to other generation technologies.
Exhibit No.
Case No. IPC-O5-
J. Gale, IPCo
Page 1 of 2
-","" ,.. '" ,..
... n..
Specifically, the Anow Rock Wind project has a very unique arrangement that elevates its energy
deliveries to Idaho Power to a signit1cantly more favorable energy product than the typical
intermittent energy from a wind facility. As a value-added and innovative solution to the complex
nature of intermittent rcsources~ Arrow Rock Wind has! at its sole cost1 secured firming and shaping
services to provide a finn, flat delivery, as negotiated, to Idaho Power of9 MW September through
February and 7 MW June through August. 'rhercfore Idaho Power ,IS not required to provide
ancillary services, integration and reliabj1jty measures.
By this same letter, I request that Idaho Power sign this contract within the next seven to ten days
and submit to the pue for approval. Your assistance and insight at the rue is sincerely appreciated.
:2Y
Ted S. Sorenson. President
pc. Randy Allphin, Idaho Power
Exhibit No.
Case No. IPC-O5-
J. Gale, IPCo
Page 2 of 2
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 1st day of July, 2005, r
served a true and correct copy of the Direct Testimony of John
R. Gale upon the following named parties by the method indicated
below, and addressed to the following:
Scott Woodbury
Deputy Attorney General
Idaho Public Utilities Commission
472 West Washington Street
P . O. Box 83 72 0
Boise, ID 83720-0074
Peter J. Richardson
Richardson & 0' Leary
515 N. 27th Street
P . O. Box 7218Boise, ID 83707
PLLC
Mr. James T. Carkulis
Exergy Development Group
1424 Dodge Avenue
P . O. Box 52 Helena, MT 59604
0 f Idaho LLC
Richard L. Storro
Director, Power Supply
Avista Corporation
1411 E. Mission Avenue
P . O. Box 3 72 7, MS C - 7
Spokane, WA 99220 - 3727
R. Blair Strong
Paine , Hamblen, Coffin , Brooke & Miller
71 7 West Sprague Avenue, Suite 1200
Spokane, WA 99201-3505
Hand Delivered
U . S. Mai 1
Overnight Mail
FAX
Hand Delivered
S. Mail
Overnight Mail
FAX
Hand Delivered
S. Mail
Overnight Mail
FAX
Hand Delivered
U . S. Mai 1
Overnight Mail
FAX
Hand Delivered
U. S. Mail
Overnight Mail
FAX
(J3.
MONI CA B. MOEN
CERTIFICATE OF SERVICE