20061030Answer and Comments.pdf

IDAHO
POWE R CID
RECEIVED
200& OCT 21 PM 4: ~6
BARTON L. KLINE
Senior Attorney
An IDACORP Company
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Jean D. Jewell, Secretary
Idaho Public Utilities Commission
472 West Washington Street
P. O. Box 83720
Boise, Idaho 83720-0074
Re:Case No. IPC-06-
Cassia Gulch Wind Park LLC and Cassia Wind Farm LLC v. Idaho
Power Company
Dear Ms. Jewell:
Please find enclosed an original and seven (7) copies of the following
documents for filing in the above -referenced matter.
Answer and Comments of Idaho Power; and
Affidavit of David Sikes.
I would appreciate it if you would return a stamped copy of this transmittal
letter in the enclosed self-addressed , stamped envelope.
Barton L. Kline
BLK:sh
Enclosures
Telephone [phone], Fax [phone] E-mail BKlinerffJidahopower.com
BARTON KLINE, ISB # 1526
LISA D. NORDSTROM, ISB # 5733
Idaho Power Company
1221 West Idaho Street
O. Box 70
Boise , Idaho 83707
Telephone: [phone]
FAX Telephone: [phone]
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2006 OCT 21 PH 4: 1+ 7
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Attorney for Idaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASSIA GULCH WIND PARK LLC AND
CASSIA WIND FARM LLC
Respondent
Case No.: IPC-06-
Complainants
ANSWER AND COMMENTS OF
IDAHO POWER
IDAHO POWER COMPANY
COMES NOW , Idaho Power Company ("Idaho Power" or "the Company ) and
submits the following Answer and Comments ("Comments in response to the
Complaint of Cassia Gulch Wind Park LLC and Cassia Wind Farm LLC ("Cassia" or
Projects ) dated September 13, 2006.
SUMMARY OF ISSUES TO BE ADDRESSED
In this Complaint, Cassia is requesting that the Commission exempt PURPA
Qualifying Facilities ("QFs ) from paying their share of the cost of transmission system
upgrades that Idaho Power must construct to interconnect and integrate new generating
facilities, including QFs. A number of significant regulatory policy issues are raised by
Cassia s Complaint. A description of those issues and a summary of Idaho Power
ANSWER AND COMMENTS OF IDAHO POWER -
position on each of the issues is as follows:
Issue 1
Does this Commission or the FERC have jurisdiction over the allocation of
transmission system upgrade costs to QFs?
Idaho Power s Position:
Both Idaho Power and Cassia agree that this Commission has exclusive
jurisdiction to resolve the issues raised by Cassia. However, the FERC has considered
many of the same policy issues presented to this Commission by Cassia s Complaint
and Idaho Power believes that FERC's analysis and resolution provide persuasive
precedent.
Issue 2:
Is requiring QFs to fund their share of the cost of required transmission system
improvements consistent with the policies and orders of this Commission and the
FERC?
Idaho Power s Position:
Both Idaho Power s Schedule 72 Interconnectinq to Non-Utility Generation , and
FERC's PURPA rules require QFs to fund system improvements needed to integrate
their generation. Idaho Power has proposed a cost-sharing agreement to allow QF
developers to fund the upgrade costs subject to refund. Idaho Power s proposal is
consistent with both the FERC's rules and Schedule 72.
Issue 3:
Will adoption of Cassia s proposal to exempt QFs from paying their share of the
cost of required transmission system upgrades violate PURPA avoided cost principles?
ANSWER AND COMMENTS OF IDAHO POWER - 2
Idaho Power s Position:
Cassia s proposal to have QFs bear only a portion of the costs of integrating their
generation resources will cause Idaho Power s customers incur costs for QF resources
that exceed Idaho Power s approved avoided costs.
Issue 4:
Will adoption of Cassia s proposal to exempt QFs from paying their share of the
cost of required transmission system upgrades accelerate the need for rate increases?
Idaho Power s Position:
Adoption of Cassia s proposal would immediately add the full cost of the required
transmission system upgrades to Idaho Power s rate base. A return on Idaho Power
full investment in those upgrades increases Idaho Power s revenue requirement more
rapidly than Idaho Power s proposal which would increase Idaho Power s revenue
requirement in much smaller increments over a longer period of time.
Issue 5:
Will adoption of Cassia s proposal to exempt QFs from paying their share of the
cost of transmission system improvements violate FERC's comparability requirements?
Idaho Power s Position:
Adoption of Cassia proposal will result in QF resources receiving more
favorable treatment than either Idaho Power generating resources or merchant
generation resources in the use of the Company s transmission system. This result is
inconsistent with FERC's comparability requirements and could adversely affect Idaho
Power s ability to require market generation developers to fund system improvements.
ANSWER AND COMMENTS OF IDAHO POWER - 3
Issue 6:
Will adoption of Cassia s proposal to exempt QFs from paying their share of the
cost of transmission system improvements adversely impact the Integrated Resource
Planning process?
Idaho Power s Position:
Idaho Power s other major transmission investments are made in a manner that
is consistent with the Company s Integrated Resource Plan. Adoption of Cassia
proposal will result in economically inefficient siting decisions by QFs because
transmission costs are ignored. For the same reason it will result in scarce transmission
investment dollars being allocated based on QF developers' plans rather than the
Integrated Resource Plan.
Issue 7:
Will requiring QFs to fund their share of transmission system upgrades caused
by their siting decisions discriminate against QFs?
Idaho Power s Position:
No. PURPA rules require QFs to fund all interconnection costs including
system improvements. Idaho Power is proposing a cost-recovery program that is very
similar to the Company s current Rule H that requires developers to initially fund the
cost of line extensions they require to develop their projects.
II.BACKGROUND
Events LeadinQ to the Complaint.
In June 2006, Idaho Power completed a Generator Interconnection System
Impact Study ("System Impact Study" or "Study ) addressing the impacts on the
ANSWER AND COMMENTS OF IDAHO POWER - 4
Company s system arising out of interconnection requests adding up to more than 200
MW of new generation on the 138 kV transmission system in the Twin Falls area. The
System Impact Study was prepared in accordance with the requirements of the
Company s Federal Energy Regulatory Commission ("FERC") approved Open Access
Transmission Tariff ("OA TT") and FERC Order Nos. 2003, 2003-, 2003-B and 2006
Order 2003 et seq.1 As Cassia notes on page 1 of its Memorandum in support of its
Complaint, the Projects are PURPA Qualifying Facilities and were included in the
cumulative group of new generating resources that were included in the System Impact
Study.
Resources that are included in the 200 MW cumulative total include several
windfarms in addition to the Cassia Projects, Idaho Power s Shoshone Falls
hydroelectric generation capacity increase project and several other generation
resources, a number of which are QF resources currently holding contracts through
which they would sell all of their output to Idaho Power.
As noted in the Affidavit of David Sikes which accompanies these Comments , the
System Impact Study concluded that four (4) phases of transmission system
improvements need to be constructed to provide network resource interconnection
service to the 200 MW of new generation.
Each of the four phases incrementally increase in cost.Idaho Power has
proposed to fund the first phase which is estimated to cost approximately $300 000.
The remaining three phases would provide sufficient capability to interconnect all of the
1 FERC Order No. 2003 , et seq. specifically deal with both large and small generating projects
interconnecting with utility systems. These orders describe FERC policy governing cost responsibility for
such interconnections.
ANSWER AND COMMENTS OF IDAHO POWER - 5
generation projects that had requested interconnection in the Twin Falls area at the time
of the study and will cost a total of approximately $58 million.
Idaho Power s Efforts to Address the Problem.
After the Study was presented to Cassia and others, several developers
expressed dissatisfaction with the prospect of paying any portion of these transmission
system improvement costs. In response , Idaho Power invited the Commission Staff
Cassia and all of the other generating projects located in the group of projects that have
made requests for interconnection and would be a part of the group of resources
impacting the Company s 138 kV transmission system in the Twin Falls area, to meet in
Boise on August 15 , 2006. The purpose of the meeting was to discuss the possibility of
the parties agreeing on an arrangement that would equitably share the cost of
upgrading Idaho Power s transmission network to accommodate the various generating
projects. This type of sharing arrangement is referred to by the FERC as a "cluster
approach. (FERC Order No. 2003 'il155 , pp 37-38). Others refer to it as a "cumulative
approach.
Representatives from the vast majority of affected generating projects attended
the August 15 , 2006 meeting. Others who did not attend but signed the Confidentiality
Agreement were subsequently briefed by the Company regarding its proposal
presented at the meeting.
Idaho Power s Proposed Cumulative Approach
At the August 15 , 2006 meeting, Idaho Power presented a "straw man" proposal
to address funding of the required system upgrades.Idaho Power s proposal
summarized as follows:
ANSWER AND COMMENTS OF IDAHO POWER - 6
All projects, both QF and non-, including Idaho Power s Shoshone Falls
hydro generation project capacity increase would contribute their pro-rata share of the
required transmission upgrade costs based on project capacity. Their contributions
would be based on the costs assigned to each of the four phases and the projects
respective places in the transmission application "Queue.In other words, those
projects that made application for interconnection early in the process and paid for
studies of interconnection costs and impacts were allocated costs based on the time of
their application. This approach spreads the total upgrade costs over a large amount
generating capacity thereby lowering total costs per project. This approach also
consistent with the FERC's requirements for allocating transmission capacity and
upgrade costs as described in FERC Order No. 2003, et seq.
Idaho Power would treat these payments by the various resource
developers as advances in aid of construction with the advances to be repaid in full with
interest over a period of time not to exceed the term of the contract between the
resource developer and Idaho Power. The duration of the repayment period could be
shorter, depending on how well a project performed its power sales contract. Idaho
Power would pay interest on the unamortized balance of the advance at the rate of
interest the FERC periodically establishes for refunds. This is the same interest rate the
Company would pay to wholesale transmission customers when these customers fund
network upgrades under the FERC's rules established in Order No. 2003, et seq.
At the August 15 meeting Idaho Power emphasized that its proposal had
not been previously discussed with the Commission Staff nor has it been approved by
the Commission; and there is no guarantee that the Commission would approve any
ANSWER AND COMMENTS OF IDAHO POWER - 7
arrangement developed by the parties. However, Idaho Power indicated its preference
to present a mutually-agreeable voluntary proposal to the Commission with the intent of
avoiding the delays that would accompany litigation of this issue. Idaho Power also
expressed its willingness to consider modifications to its proposal so long as those
modifications did not violate FERC comparability standards.These comparability
standards are discussed in greater detail later in these comments.
At the August 15, 2006 meeting, several parties expressed interest in
pursuing the cumulative approach and indicated it was their intention to provide written
comments to the Company regarding its proposal.One party has provided such
comments and others have informally expressed interest in further discussions to
implement Idaho Power s proposal.
Cassia filed its Complaint on September 13, 2006.
III.ARGUMENT AND LEGAL ANALYSIS
Jurisdiction of the Commission.
With one exception , wholesale rates and rules governing interconnection and
transmission by generation developers making wholesale sales is within the exclusive
jurisdiction of the FERC. However, in the case of QFs intending to sell all of their output
to the interconnection utility, Idaho Power agrees with Cassia that FERC has delegated
its wholesale ratemaking authority to this Commission and this Commission possesses
exclusive jurisdiction over the recovery of costs incurred to integrate QF resources.
FERC Orders 2003, et seq. clearly hold that this Commission has jurisdiction to allocate
costs incurred to integrate QF resources when the QFs intend to sell all of their output
ANSWER AND COMMENTS OF IDAHO POWER - 8
to the interconnecting utility.2 (FERC Order No. 2003 ~ 813 , pp. 172-173; see also
Western Massachusetts Electric Co.61 FERC ~ 61 182 at 61 661-62 (1992) (Western
Massachusetts), af'd sub nom. Western Massachusetts Electric Co. v. FERC 165 F.
3d. 922 , 926 (D.C. Cir. 1999)). However, as will be discussed in more detail later in
these comments, the FERC's policy considerations and determinations regarding cost
responsibilities for initial funding of network upgrades provide persuasive precedent.
Idaho Power Schedule 72 ReQuires QFs to Fund Interconnection
Costs IncludinQ System UpQrades
Idaho Power s Schedule 72 is the tariff governing interconnection with QFs.
Cassia concedes that, under Schedule 72 it is obligated to fund the cost
interconnecting its projects to Idaho Power s system. Cassia argues , however, that in
approving Schedule 72 , the Commission intended to draw a distinction between
upgrades and equipment needed on the distribution side of the interconnection point
and upgrades and equipment needed on the transmission side of the interconnection
point.Neither the FERC PURPA definition of Interconnection Facilities nor Idaho
Power s Commission-approved Schedule 72 definitions that implement FERC's rules
draw such a distinction. In fact, both FERC and this Commission s rules addressing
interconnection of QFs identify the need for the Company to construct facilities and
install equipment required to provide safe and reliable service to customers. Where
such equipment is physically located on the system has never been an issue. Both
FERC's PURPA rules and Schedule 72 definitions explicitly include transmission
2 Not all of the generating resources in the "cluster" are OFs, and the non-OF resources have not
committed to sell their output to Idaho Power. As such , they would be covered by FERC's cost allocation
rules. However, because Idaho Power s cost sharing proposal is consistent with the FERC's "cluster
approach, Idaho Power believes FERC would accept inclusion of the non-OFs in the "cluster.
3 This is Cassia s "driveway" and "highway" distinction. Cassia Memorandum p. 5.
ANSWER AND COMMENTS OF IDAHO POWER - 9
investment as potential costs to be allocated to QFs as part of the interconnection
process.(18 CFR 101 (b)(7) , 18 CFR 292.306 , Idaho Power Schedule 72
Interconnections to Non-Utility Generation).Interconnection costs for QFs under
PURPA are defined by the FERC in 18 CFR 9292.101 (b)(7):
Interconnection costs means the reasonable costs
connection, switching, metering, transmission, distribution
safety provisions and administrative costs incurred by the
electric utility directly related to the installation and
maintenance of the physical facilities necessary to permit
interconnected operations with a qualifyinq facility, to the
extent such costs are in excess of the corresponding costs
which the electric utility would have incurred if it had not
engaged in interconnected operations, but instead generatedan equivalent amount of electric energy or capacity from
other sources. Interconnection costs do not include any costs
included in the calculation of avoided costs. (emphasis
added).
The above-quoted FERC regulation shows that interconnection costs include
transmission costs incurred to permit interconnected operations with a QF. As Mr.
Sikes states in his affidavit in support of these Comments , the interconnection of
Cassia s projects and the other projects in the Twin Falls area requires the addition of
transmission upgrades to maintain safe, reliable electric service to customers. (Sikes
Aff. at p. 4).
The FERC's delegation of wholesale ratemaking authority to this Commission
under PURPA requires that the Commission implement the FERC's regulations. (18
CFR 9 292.401). Schedule 72 is consistent with the requirement embodied in the
above-referenced FERC PURPA regulations. Schedule 72 requires QFs to fund the
costs of additions, alterations and upgrades to transmission lines and other facilities that
ANSWER AND COMMENTS OF IDAHO POWER - 10
are required to safely interconnect the QF's generation facility to the Company
system. The definition of interconnection facilities in Schedule 72 provides:
Interconnection Facilities are the facilities which are
reasonably required by prudent electrical practices and the
National Electric Safety Code to interconnect and to allow
the delivery of energy from the Seller's Generation Facility to
the Company s system , including, but not limited to, Special
Facilities Disconnection Equipment and Metering
Equipment.
Schedule 72 further defines Special Facilities as:
Special Facilities are additions to or alterations of
transmission and/or distribution lines and transformers
including, but not limited to Upqrades and Relocation , to
safely interconnect the Seller s Generation Facility to the
Company s system. (emphasis added).
As was the case with the FERC definition of interconnection equipment, the definition of
interconnection equipment in Schedule 72 covers "all additions to or alterations of
transmission and/or distribution lines and transformers
, . .
. to safely interconnect the
Seller s Generation Facility to the Company s system.If system safety and reliability
require that the Company make "additions to or alterations to transmission" and
transformers" in order to accommodate the QFs delivery of energy to Idaho Power
system , Schedule 72 includes those transmission investments and allocates cost
responsibility to the QFs. Mr. Sikes s affidavit confirms that safety and system reliability
require the additional facilities.
This Commission reiterated the requirement for QF interconnection cost
responsibility under Schedule 72 in Order No. 29092 issued on August 27, 2002 in
Case No. IPC-01-38. On page 8 of the Order, in response to requests from some
intervenors that some QF interconnection costs be transferred from QFs to Idaho
ANSWER AND COMMENTS OF IDAHO POWER - 11
Power, the Commission stated: "regarding interconnection cost responsibility, we find
that it is important for the tariff to explicitly state that all interconnection costs will be
borne by the customer/generator. If interconnection requires more than the customer-
furnished standard equipment it is the customer/qenerator s responsibility to bear those
additional interconnection expenses." (Order No. 29092). (emphasis added).
In its Complaint on page 5 Cassia argues that because Idaho Power has
proposed a cumulative approach to funding the transmission system upgrades identified
by the System Impact Study, the Company has admitted that Schedule 72 does not
apply to transmission system upgrades. Cassia is incorrect. Idaho Power s proposal to
develop a voluntary contractual arrangement to share the funding of system upgrade
costs is permitted under Schedule 72. Schedule 72 provides that Idaho Power and QFs
may enter into written agreements to develop alternative arrangements to address costs
of interconnecting generating facilities. Specifically the section of Schedule 72 entitled
PAYMENT FOR INTERCONNECTIONS COSTS" states:
PAYMENT FOR INTERCONNECTION FACILITIES
Unless specifically agreed otherwise by written agreement
between the Seller and the Company, the Seller will pay all
costs of interconnecting a Generation Facility to the
Company s system.
Unless specifically agreed otherwise in written agreement
between the Seller and the Company, an initial cost estimate
of Company-owned Interconnection Facilities will be
provided to the Seller. Payment of the estimated cost will be
required prior to the Company ordering, installing,
modifying, upgrading, or performing in any other way work
associated with the Interconnection Facilities. Upon
completion of the Company-owned Interconnection
Facilities , the actual costs will be reconciled against the
estimated cost previously paid by the Seller and the
appropriate billing or refund will be processed. The
ANSWER AND COMMENTS OF IDAHO POWER -
Company reserves the right to collect additional costs fromthe Seller for any additional Company equipment
modifications , or upgrades the Company deems necessary
to operate and maintain a safe, reliable electrical system as
result of the Interconnection of the Seller s Generation
Facility to the Company s system. (emphasis added).
The language of Schedule 72 contemplates that Idaho Power and QFs may negotiate
and enter into written contracts to allocate costs of interconnection in a way that is
mutually agreeable to Idaho Power and the QF. Any such contract would include a
provision requiring that the contract be filed with and approved by this Commission
before it would become effective. This is precisely the procedure Idaho Power followed
in its negotiations with the various Twin Falls area resource developers prior to the filing
of Cassia s Complaint.
Cassia Distinction Between "Interconnection and "Network
UpQrades" is a Distinction Without a Difference
Cassia urges the Commission to adopt a policy that distinguishes between the
costs associated with interconnecting its Projects to Idaho Power s system and the
costs associated with transmission improvements needed to allow the energy flowing
over the interconnection to be safely and reliably integrated by Idaho Power. As Mr.
Sikes explains on page 7 of his affidavit in support of these Comments , interconnection
and the need for network upgrades are , for system planning and reliability purposes
inseparable. The FERC recognized this inseparability in Order 2003 , et seq.
In those Orders the FERC ruled that if improvements to the transmission system
are required to integrate generation , those transmission improvements will be funded by
the interconnecting customer subject to refund. (Order No. 2003-B ~ 32). In Order No.
2003-A issued in Docket RM02-001 , the FERC determined it was appropriate for
ANSWER AND COMMENTS OF IDAHO POWER -
interconnection customers to initially fund the costs of network upgrades occasioned by
their interconnection request.Under the rules FERC adopted , the cost of network
upgrades advanced by the interconnection customer is subsequently refunded to the
interconnection customer in the form of credits applied to transmission charges levied
by the transmission provider as the interconnection customer delivers energy from its
generation facility. (Order 2003, p. 139 , ~ 694).
On rehearing following the issuance of Order No. 2003-, a number of potential
interconnection customers objected to FERC'decision to require interconnection
customers to provide upfront funding of network upgrades. In FERC Order No. 2003-
the Commission responded:
32. In Order No. 2003-, the Commission revised therules governing transmission credits to place the
Interconnection Customer at a greater risk for the cost of
Network Upgrades occasioned by the Interconnection
Request. The Commission was concerned that to do
otherwise would not lead to efficient siting decisions and
would not adequately protect native load and other
Transmission Customers from having to bear Network
Upgrade costs if the Generating Facility were to retire early.
In their arguments opposing the modifications , Intergen and
others state that the cost of Network Upgrades is typically
small compared to the cost of the Generating Facility and
that the Interconnection Customer will often embark on a
project even though Network Upgrade costs are unknown.
This suggests that placing the risk for the cost of Network
Upgrades on the Interconnection Customer does not place a
significant burden on the Interconnection Customer and thus
is completely appropriate. Also, Intergen states that the
Interconnection Customer has a strong incentive to
maximize its use of the Transmission Sytem because it only
makes money if it is selling output from its Generating
Facility. The crediting policy, however, reinforces that
incentive by linking transmission credits directly to the output
of the Generating Facility.
ANSWER AND COMMENTS OF IDAHO POWER - 14
33. We strongly encourage policies that promote efficient
investment decisions and protect native load and other
Transmission Customers from having to bear the burden ofthe Interconnection Customer s Network-Upgrade costs.
Given these concerns , we continue to find that the Order No.
2003-crediting policy provides a reasonable balance
between the objectives of promoting competition and
infrastructure development protecting the interests of
Interconnection Customers , and protecting native load and
other Transmission Customers. (Order 2000-, p. 12-13).
In its Memorandum on page 10 , Cassia claims incorrectly that the FERC agrees
with Cassia s position that QFs should only pay interconnection costs and the additional
costs of network upgrades should be socialized and paid by all customers. In support of
that position , Cassia cites a FERC decision entitled Western Massachusetts EIec. Co.
77 FERC. ~. 61 , 268 (1996), affirmed Western Massachusetts EIec. Co. v. FERC 165
F.3d 922 (D.C. App. 1999). While Cassia s Memorandum accurately describes the
FERC's decision in the 1996 Western Massachusetts Company case , Cassia fails to
disclose that , in the FERC's more recent decisions in Order Nos. 2003 et seq., the
FERC has reversed its position taken in Western Massachusetts.
Cassia also notes that the FERC cited the Western Massachusetts decisions in
Order Nos. 2003 and 2006. Cassia s reference to Order Nos. 2003 and 2006 implies
the Western Massachusetts decisions remain good precedent for cost responsibility
when in fact they do not. The FERC's citations to the Western Massachusetts decisions
in Order Nos. 2003 , et seq. were in support of those portions of the FERC's 2003, et
seq. Orders in which the FERC confirmed that state commissions, not the FERC , had
jurisdiction over QF interconnections. In Order No. 2003, et seq. the FERC did not cite
the Western Massachusetts decisions as precedent for a rolled-in allocation of
transmission costs. In fact, in FERC Order No. 2003 , et seq. the FERC concluded that
ANSWER AND COMMENTS OF IDAHO POWER - 15
to adequately protect native load and other transmission customers from having to bear
network upgrades costs, FERC will require that interconnection customers like Cassia
initially fund the cost of network upgrades subject to refund. Idaho Power s cumulative
cost sharing proposal , including refunds, is entirely consistent with the FERC approach
and procedure. (See FERC Order No. 2003-A p. 4. ~ 9 and 2003-B p. 4-, ~~ 10 , 32
and 56). Cassia s proposal is not.
Cassia s proposal that this Commission exempt QFs' resources from paying the
costs of transmission system improvements required by their interconnections presents
the same policy consideration for this Commission as it did for the FERC.FERC
received dozens of comments on exactly this same policy question.Non-utility
merchant generators urged the Commission to roll in the cost of transmission upgrades
to promote the development of merchant generation and to stimulate the construction of
new transmission resources. FERC considered the policy arguments on both sides of
this issues and ultimately concluded in Orders Nos. 2003-A and B that if resource
developers have no upfront cost responsibility for Network Upgrades, then their
resource siting decisions may be made inefficiently as compared to siting decisions
where the total cost of the resource , including transmission cost is considered. Allowing
resource developers to make inefficient siting decisions will shift costs and risks to
customers that should rightfully be assumed by resource developers.
In its Memorandum on page 11 , Cassia makes the same argument that the
merchant generators made to FERC; QFs should be excused from paying their share of
transmission system improvements required by their decision to site generating
resources in a particular location because this policy will encourage the development of
ANSWER AND COMMENTS OF IDAHO POWER - 16
new QF generation. Undoubtedly that is true. Subsidies almost always encourage
investment. Unfortunately, holding QF developers harmless from the full costs of their
decisions to site resources at particular locations on the utility system will also
encourage inefficient siting decisions. Some of Idaho s best QF resource sites are in
very remote locations far from load centers. Cassia s recommendation that only a
portion of the costs Idaho Power incurs to interconnect and integrate a QF resource be
funded by the QF developer, with the balance socialized to all of Idaho Power
customers, will almost certainly ensure that Idaho Power s customers will pay more than
the Commission-approved avoided cost rate for QF power.
Idaho Power recognizes the fact that the FERC has chosen to require resource
developers to assume their share of expenses of interconnection and transmission
system improvements is not binding on this Commission.However, Idaho Power
believes that the policy considerations that convinced the FERC to require generation
developers to fund system improvements subject to refund should be equally
compelling for this Commission.
Cassia Proposal to Exempt QFs From PavinQ Their Share of
ReQuired Svstem Improvements Violates PURPA Principles
Under PURPA, the avoided cost rates an electric utility pays for electric energy
from a QF must "be just and reasonable to the electric consumers of the electric utility
and in the public interest." 16 USC~824a-3(b). To comply with PURPA requirements
avoided cost rates set by this Commission cannot exceed the incremental cost to the
electric utility of alternative electric energy. 16 USC~824a-3(b). The term "incremental
cost of alternative electric energy" means the cost to the electric utility of electric energy
which , but for the purchase from such co-generator or small power producer, such utility
ANSWER AND COMMENTS OF IDAHO POWER - 17
would generate or purchase from another source. 16 USC 9824a-3(d). Stated another
way, after the Commission has set avoided costs, customers should be economically
indifferent to whether the utility purchases an amount of energy from QFs , generates
the same amount of energy itself, or purchases the energy on the whole market. This is
often referred to as the ratepayer neutrality test.
In setting avoided costs in Idaho, this Commission has consistently utilized a
surrogate avoided resource ("SAR") as the benchmark for determining avoided costs for
the three Idaho electric utilities.Each time the Commission has established new
avoided costs rates it has also considered how much if any, transmission cost
associated with the SAR should be included in setting the avoided cost rates. Adding
avoided transmission investment and expenses to the avoided cost payment fully
compensates QFs for any transmission savings their resource development may bring
to the utilities resource portfolio and establishes avoided costs at a level that meets the
customer neutrality test.However, current avoided cost rates do not include a
component for transmission expense because the current SAR is a combined cycle
combustion turbine which can be sited at an optimal location on the utility s transmission
system, thereby avoiding the need for transmission investment.
Cassia s proposal violates the above-described PURPA principles in several
ways. First , by arguing QFs should not fund the additional transmission investment
expense caused by QF interconnection, Cassia is urging the Commission to violate the
ratepayer neutrality test. If, in addition to paying the QF the full avoided cost for the
generation resource , Idaho Power is forced to fund additional transmission investment
and expenses required to interconnect the QF resource, customers will be paying more
ANSWER AND COMMENTS OF IDAHO POWER - 18
than avoided cost for QF resources. On the other hand , if QF resource developers are
required to initially fund the cost of transmission expenses they cause the utility to incur
or if avoided cost rates are reduced to reflect the additional cost of transmission system
improvements , ratepayer neutrality is maintained.
Second , Cassia s proposal asks the Commission to bypass the normal avoided
cost rate setting process. Allowing QF developers to escape paying the additional costs
for transmission system improvements necessitated by their interconnection has the
same effect as increasing avoided cost rates. Historically, this Commission has strongly
resisted changing avoided cost prices outside of a technical avoided cost rate setting
proceeding.
Third if the Commission accepts Cassia proposal and rules that only
distribution-related expenses directly associated with interconnection QFs to the system
should be funded by the QF developer, it will be ignoring the impact of the more
expensive transmission-related expenses in determining avoided costs. The upshot of
accepting Cassia s proposal will be that the total cost of QF resources will exceed the
approved incremental cost of alternative resources available to the utility.This is
inconsistent with PURPA principles and violates PURPA's ratepayer neutrality test.
Finally, Under PURPA principles , a valid argument can be made that
developers should not receive any refunds of principal or interest they contribute to
construct system upgrades required to accommodate their projects.Idaho Power
acknowledges that its proposal to treat QF payments as advances in aid of construction
subject to refund may result in QF payments that are higher than currently approved
avoided cost rates.Nevertheless , the Company believes there is a balancing of
ANSWER AND COMMENTS OF IDAHO POWER - 19
interests in the refund proposal it has made and is willing to proceed with its proposal so
long as the Commission is willing to allow Idaho Power to recover these QF-related
costs in the Company s rates.
Other States ReQuire QFs to Fund System Improvements.
On page 9 of its Memorandum , Cassia cites a Vermont Public Service Board
case. (Petition of Missisquoi Associates 1985 WL 287030 (Vt. P.B. 1985). In the
cited order, the Vermont Public Service Board indicates that it cannot predict what costs
the utility would have incurred had it not interconnected with the QF. The Vermont
Board "solved" the problem by presuming that the utility would have needed to construct
the system improvements to accommodate the QF sometime in the future anyway so
customers would not be harmed if they funded them today.
Of course in Idaho , that is not how avoided costs are set. In Idaho , system
improvements the SAR would require that can be avoided by QF purchases are
established in an avoided cost case. If transmission costs can be avoided by QF
purchases , those avoided transmission costs are reflected in higher avoided cost rates.
Simply presuming that purchases from QFs will always allow the utility to avoid incurring
costs equal to QF system improvement costs required to accept QF energy is almost
certain to be wrong. Making such a presumption will either disadvantage the utility
customers or the QF developer. Vermont's approach as articulated in 1985 may be
simple but it is neither accurate nor consistent with PURPA.
Other states nearby have recently confirmed that they will require QFs to pay for
the costs of the system upgrade facilities necessary to integrate generation.
ANSWER AND COMMENTS OF IDAHO POWER - 20
In 1998 , the Colorado Public Utilities Commission issued an order authorizing the
Public Service Company of Colorado to develop a bidding procedure to establish
avoided costs for capacity purchases from qualifying cogeneration and small power
production facilities. Re Public Service Company of Colorado Decision No. C88- 726
93 P.R. 4th 384 , 1988 WL 391456 (Colo. P.). The Colorado Commission found
that "it is proper for Public Service to require QFs to pay for all internal transmission
system upgrades needed to move QF power to the Denver load , because QFs may
locate wherever they choose within the State and without.Thus , transmission
upgrades if needed, and the contribution of interconnection facilities may be
necessitated solely by the location of the QF on the System.
Last year the Colorado Commission reaffirmed its finding that QFs will be
required to pay for all Company transmission system upgrades necessary to transport
power to the Denver load center as part of QF interconnection costs in Docket No. 04S-
164E, Decision No. C05-0412. Re: The Investigation and Suspension of Tariff Sheets
Filed by Public Service Company with Advice Letter No. 1411 - Electric 240 P.
323, 2005 WL 850285 (Colo. P.). See also Re Chapter 480-107 WAC Docket
No. UE-030423, Gen. Order No. R-530 , 2006 WL 1650702 (Wash. U.T.C.
As Mr. Sikes indicates in his Affidavit , in the ordinary course of business Idaho
Power would not construct the system improvements described in the System Impact
Study to address load growth in the Twin Falls area. The only reason that Idaho Power
would construct these system improvements is to accommodate the generation that
would be injected into the system by the generation facilities described in the System
Impact Study. (Sikes Aff. p. 7-8).
ANSWER AND COMMENTS OF IDAHO POWER - 21
Adoption of Cassia s Proposal Could Expose Idaho to Expensive
FERC Compatibility RulinQs.
Since the FERC issued its landmark Order No. 888, in 1997 , the FERC has
made sweeping changes to transmission rules to eliminate the possibility that utilities
will use their control of their transmission facilities to favor network resources such as
utility and QF generating resources serving predominately native loads , to the detriment
of merchant generators seeking to use the transmission system to deliver energy to
wholesale markets. This Commission is well aware of the lengths the FERC has gone
to manage the transmission system to protect merchant generators seeking to move
power in the wholesale markets , sometimes to the detriment of generating utilities
serving native loads.
In some instances FERC has levied substantial fines against utilities that it
believes are maintaining practices that do not provide equitable treatment between the
utilities generation function and merchant generators.FERC uses the term
comparability" when it is looking at how utilities operate their transmission system
dealing with the utilities' own resources as compared to how they operate the system to
accommodate merchant generation and wholesale transactions moving across the
transmission system. See Carolina Power Light Co.93 FERC ~ 61 032 (2000).
In an effort to comply with the FERC's comparability concerns, Idaho Power
Delivery Business Unit ("Delivery ) currently conducts its transmission engineering
analyses and system impact studies for both QFs and non-QFs in the same manner
prescribed by the FERC. (Aff. at 2-3). This allows Delivery to manage its workflow by
implementing policies and procedures in a uniform way, thereby ensuring equal
treatment to all entities seeking interconnection. Delivery imposes the same payment
ANSWER AND COMMENTS OF IDAHO POWER - 22
processing and improvement funding requirements on Idaho Power s own power supply
business unit when it makes application to interconnect new resources to the
Company s system even when those new resources will serve native load almost
exclusively.
Adopting Cassia s proposal would give QFs preferential treatment compared to
Idaho Power s own new generation and new merchant generation developers. Idaho
Power is concerned that giving preferential treatment to QF developers will invite
negative repercussions or even precipitate a FERC investigation. It is certainly possible
that a non-QF resource seeking to interconnect with the Company s system and/or
transport its power across the Company s system will complain to the FERC if it is
required to initially fund network upgrades when QF network resources are not required
to do the same. If Idaho Power s concerns are realized , FERC's response could be to
require Idaho Power to provide initial funding of transmission upgrades for wholesale
transmission customers including merchant generating plants seeking to interconnect
with Idaho Power s system and transport their energy over Idaho Power s transmission
system.
Consider this hypothetical. Assume that the Commission had adopted Cassia
proposal that Idaho Power s general body of customers fund QF network upgrades and
Sempra Energy had received permission to construct a merchant coal-fired generating
resource near Jerome. Under FERC's comparability standard , Sempra could logically
argue to the FERC that Idaho Power should be required to initially fund the system
improvements needed to transmit Sempra generation across Idaho Power
transmission system. This would have required Idaho Power to undertake additional
ANSWER AND COMMENTS OF IDAHO POWER - 23
financing, perhaps to the detriment of its ability to finance needed infrastructure
improvements needed to serve native load.
Cassia s Proposal to Exempt QFs From PayinQ Their Share of
ReQuested Transmission System Improvements Will Accelerate
Increases in Customer Rates.
On page 13 of its Memorandum , Cassia states: "Under normal circumstances , in
the regular course of the rate-making process , utility investments of the nature proposed
here (transmission system improvements) would be subject to prudence review in a
general rate case at the time Idaho Power proposes to include them in rate base.
Among other things, the Commission would examine whether the investments were the
least cost solution to the identified problem.(emphasis added). Idaho Power agrees.
Unfortunately, when QF resources are driving the requirement for the Company to make
an investment, the normal Commission review process is stymied. In this instance
several QF developers have decided they want to develop resources in the Twin Falls
area. Idaho Power is required to purchase the power generated by these resources.
The QF developers' decisions will require Idaho Power to make $50 - $60 million in
transmission upgrades in order to accommodate their resources.
If Cassia s proposal is adopted , because Idaho Power is required by law to
purchase energy from QF resources, the transmission investment must be made to
integrate the resource whether or not it is the least cost solution to the identified
problem.(Cassia Memorandum p. 13).In fact , it is almost a certainty that the
resources will not be least cost if the cost of transmission system upgrades needed to
accommodate the new generation are shifted up front to customers.If Cassia
proposal is accepted by the Commission as its new policy on transmission cost funding,
ANSWER AND COMMENTS OF IDAHO POWER - 24
QF developers can ignore transmission interconnection costs when they select the least
expensive location for them to site a generation resource even in extremely remote
locations.
Cassia is correct that, under Idaho Power s proposal , the initial cost of the
transmission upgrade investment would not be added to the Company s rate base in a
single generation rate case as would be the case if the Commission adopts Cassia
position and requires rate base treatment of the entire transmission upgrade
investment. (Cassia Memo p. 13). Cassia is also right that under Idaho Power
proposal the entire cost of the transmission upgrade would not be an issue in a single
rate case. (Cassia Memo p. 13). Only a small portion of the system upgrade cost
would be included in rates each time the utility conducted a general revenue
requirement proceeding.What Cassia does not say however, is that the upward
pressure on retail rates would be substantially reduced under Idaho Power s proposal
as compared to Cassia s proposal.
On page 13 of its memorandum Cassia argues that rolled-in treatment of grid
related upgrades is the least -cost approach for rate payers. Cassia s assertion ignores
basic ratemaking facts.Under Cassia s proposal, a return on all of the QF-driven
transmission system improvement investment will immediately become a part of Idaho
Power s revenue requirement.Under Idaho Power s proposal, customers will see
slower growth in revenue requirement due to smaller investment increments over a
longer period of time. As a result , Idaho Power s proposal will exert less upward
pressure on retail rates than will Cassia s proposal.
ANSWER AND COMMENTS OF IDAHO POWER - 25
Cassia goes on to argue that Idaho Power s cost of capital is less than the cost of
financing available to QF developers so it would be better for society, on a global basis
to require Idaho Power to bear the cost of transmission system improvements. The
Company has never been permitted to undertake discovery to determine the actual cost
of capital for QFs. Therefore, the accuracy of Cassia s cost-of-capital association can
neither be confirmed nor denied by Idaho Power.
It is important to note that Idaho Power is not proposing to pay interest on the QF
developers' contribution in aid of construction at the QF developers' actual cost of
capital. Idaho Power has proposed to pay interest at the FERC interest rate for refunds.
This is the rate Idaho Power would pay to FERC jurisdictional customers under FERC'
rules.The FERC rate is a floating rate that is currently set at 8.17%.(see
www.ferc.qov/leqal/acctmatts/interestrates.asp That rate can go up or down
depending upon the prime rate of interest. Idaho Power s current authorized rate of
return is 8.1 %.
Finally, Cassia s cost-of-capital proposal seems to presuppose that Idaho Power
has an unlimited supply of capital to make transmission investments. That simply is not
correct. As Mr. Sikes notes on page 7 of his Affidavit, there are numerous other
locations on Idaho Power s system where spending limited transmission investment
dollars would provide more benefit to Idaho Power transmission system than
transmission investments in the Twin Fall area. That is why Idaho Power includes
major transmission projects in its Integrated Resource Plan that it files with the
Commission every two years. Allocating scarce transmission capital investment should
be done in an orderly and planned way. Adoption of Cassia s proposal would mean that
ANSWER AND COMMENTS OF IDAHO POWER - 26
QF developers' decisions to build resources in locations favorable to QF developers will
drive transmission capital investment rather than the more systematic approach
embodied in the integrated resource planning process.
ReQuirinQ QFs to Initially Fund Their Share of Transmission
UpQrades Will Not Stop Renewable Resource Development.
Cassia argues that renewable resources are unique because the siting of those
resources is dependent upon the location of the motive force. (Cassia Memorandum p.
9). In fact, one of the renewable resources that is included in the "cluster" is Idaho
Power s proposed Shoshone Falls hydro plant capacity upgrade. This increase in
renewable resource generation capacity must be installed at the existing Shoshone
Falls project site to take advantage of the existing infrastructure. Unlike Cassia, Idaho
Power understands that the cost of system improvements to integrate Shoshone Falls
should be included in the Commission s consideration of whether certificate of
convenience and necessity should be issued for the Shoshone Falls upgrade. Idaho
Power knows it must demonstrate that the Shoshone Falls upgrade is cost-effective
including additional transmission cost, when compared to other resource alternatives.
Other renewable resources should be held to the same standard. Just because
a particular developer s renewable resource may not be able to proceed because the
costs of transmission for that site make it uneconomic does not mean that other
renewable resources' projects sponsored by other developers at other locations will not
be developed. For example , Idaho Power is in the final stages of contract negotiations
with renewable resource developers proposing to site renewable resources in the
Mountain Home area and in Eastern Oregon. It appears likely that these resources will
not require major transmission investments to interconnect to the system.
ANSWER AND COMMENTS OF IDAHO POWER - 27
In the final analysis, renewable resources are not unique. Like all resources
some renewable resources will have higher costs than others when the cost of
transmission is included in the total cost.Ignoring transmission cost just because
renewable resources are involved will almost certainly guarantee that inefficient siting
decisions will be made and Idaho Power s customers will pay more for their energy than
they should. Ignoring the total cost of a resources just because it is a renewable
resource is not in the public interest.
RequirinQ QFs to Fund Their Share of Required Transmission
System UpQrades is not Discriminatorv
In its Memorandum , Cassia argues that requiring QFs to fund their share of
transmission system upgrades is discriminatory. Cassia argues that Idaho Power s plan
for recovering the costs of transmission system upgrades required to integrate new
generation resources from the developers of those new resources would discriminate
against new generating facilities. Cassia argues that such discrimination is prohibited
by the Idaho Supreme Court holding in Building Contractors Assoc. of Southwest Idaho
Inc. v. Idaho Pub. Util. Comm 128 Id. 534, 916 P.2d 1259 (1996). Cassia s attempt to
equate the fact situation presented to the Court in Building Contractors with the fact
situation presented in this case is misdirected.
In the Building Contractors case, the Idaho Supreme Court addressed the
disparate impact on new and old customers of an increase in the "hook-up fee" charged
by Boise Water. The increased hook-up fee was intended to recover a portion of the
incremental cost of new infrastructure required by new legal requirements and by
overall system load growth.
In this case , Idaho Power is proposing to recover from all of the affected
ANSWER AND COMMENTS OF IDAHO POWER - 28
developers the costs it will actually incur to install specifically identified transmission
facilities and equipment needed to physically accept the energy the developers propose
to inject into Idaho Power s system.Idaho Power s cost-recovery proposal is very
similar to the cost-recovery program the Company operates under Commission-
approved Rule H. Rule H requires developers to pay the work order costs of line
extensions needed to safely deliver energy to a new residential subdivision. It is also
akin to the Commission-approved cost-recovery program under which QF developers
pay the actual costs of physically connecting their individual projects to Idaho Power
distribution system when additional transmission system improvements are required.
Those types of cost-recovery programs were not at issue in the Building Contractors
case. In fact, the Court specifically noted in its opinion that the fees at issue in the
Building Contractors case "are not those charged to offset the actual per customer cost
of physically connecting to Boise Waters distribution system.Building Contractors 128
Id. 534 at 535 fn. 1.
Idaho Power s proposal to recover from Cassia the actual costs it will incur to
construct the necessary transmission upgrades needed to accommodate Cassia
generation are not similar to the more generalized impact fees that were at issue in the
Building Contractors case. As Mr. Sikes notes in his Affidavit on page 7, the need to
construct the system upgrades at issue is not driven by load growth in the Twin Falls
area. The only reason Idaho Power would construct the transmission system upgrades
at issue is to accommodate generation Cassia and others desire to construct in the
Twin Falls area.
ANSWER AND COMMENTS OF IDAHO POWER - 29
In this instance, the costs Idaho Power desires to recover are not related to load
growth but to specific facilities required to physically integrate QF resources which are
constructed regardless of load growth.
IV.ISSUES TO BE ADDRESSED IN PHASE 2.
As Idaho Power noted in its statement to the Commission at the Commission
decision meeting on September 25, 2006 , Idaho Power believes that the Commission
can comply with due process and create an adequate record during the first phase of
this case so long as the Commission defers consideration of Cassia factual
allegations , until a later phase of this case.As Idaho Power suggested in the
Commission s Decision Meeting on September 25, one way for the Commission to
assure that the "paper record" process is fair would be for the Commission to follow the
procedure the courts utilize in considering motions for summary judgment.
In considering a motion for summary judgment, a court assumes that the facts
alleged by the entity against whom the motion for summary judgment is directed , are
correct. Then , based on those facts, the courts determine whether, as a matter of law
the motion for summary judgment should be granted. Idaho Power believes that if the
Commission makes a similar assumption , i.e. that the facts Idaho Power alleges are
correct, a reviewing court would understand the process used and a decision based
solely on the paper record would withstand judicial review.For this reason, Idaho
Power has included the Affidavit from Mr. Sikes that provides a summary response to
the factual allegations contained in Cassia s Complaint. The factual allegations are as
follows:
ANSWER AND COMMENTS OF IDAHO POWER - 30
(a).Generation Sheddinq is an Alternative to Adequate Transmission
Facilities.
On page 7 of its Memorandum in support of Complaint, Cassia argues that Idaho
Power should be required to accept a generation shedding scheme or remedial action
scheme ("RAS") in lieu of constructing transmission system improvements necessitated
by the interconnection of QF generating resources. Idaho Power does not agree that
deferring transmission system upgrades by the use of generation shedding schemes is
a prudent, long-term approach to the problem of inadequate transmission capacity.
Idaho Power has summarized its position on this issue on pages 5-7 of Mr. Sikes
Affidavit in Support of Comments.
(b).Borah-West Capacity Increase
On page 12 of its Memorandum , Cassia quotes a portion of testimony Idaho
Power Company filed in its currently pending FERC transmission rate case. Cassia
selects one small portion of the testimony and draws an incorrect inference. Mr. Sikes
in his Affidavit in support of these Comments briefly discusses how the Idaho Power
position on the Borah-West upgrade was included in the Company s 2004 IRP and the
benefits it brings to the Company s system. He also explains how cost responsibility for
the Borah-West upgrade is spread through the IRP process.
(c).Idaho Power s Thermal Overload Assumptions
On page 2 of its Memorandum in Footnote 2 at the bottom of the page, Cassia
alleges that Idaho Power is too conservative in its engineering and planning
assumptions regarding the need to construct the system improvements to avoid thermal
overloads. Cassia indicates that the Company should be willing to stress its system to a
greater degree than the Company is willing to accept.In his Affidavit, Mr. Sikes
ANSWER AND COMMENTS OF IDAHO POWER - 31
explains why Idaho Power is not comfortable with Cassia s approach.
(d).Other Factual Alleqations
Additional factual allegations are laid out in the Affidavit of Jerrod Grover. In his
affidavit, Mr. Grover essentially states that if the Cassia Projects are required to fund
any transmission system improvements , the Projects will become uneconomic. In the
past, the Commission has determined that, it will not allow Idaho Power to undertake
discovery to confirm the accuracy of statements made by QF developers regarding the
economics of their projects. Without such discovery, there is no way for Idaho Power to
refute Mr. Grover s allegations and , as a result, it is not be possible for Idaho Power to
present any affidavit in this first phase to address Mr. Grover s claims. Idaho Power
hopes that the Commission will take Idaho Power inability to respond into
consideration in making its policy determination.
Idaho Power also respectfully requests that the Commission recall that in prior
proceedings, QF developers have often stated that a particular Commission decision
will make their QF projects unfinanceable and uneconomic. The most recent example
of this type of testimony occurred in Case No. IPC-04-, the US. Geothermal case.
In that case , the QF developers unanimously asserted that adoption of the 90%/110%
performance band would render all QF projects particularly wind projects
unfinanceable. History has demonstrated that those dire predictions were unfounded.
Since the issuance of the US. Geothermal decision , Idaho Power has signed contracts
with QFs equal to a cumulative capacity of more than 200 MW.
ANSWER AND COMMENTS OF IDAHO POWER - 32
Conclusion
Idaho Power respectfully requests that the Commission decline Cassia
invitation to transfer funding responsibility for system improvements from resource
developers to Idaho Power.
As might be expected , multi-party discussions regarding Idaho Power s cost-
recovery proposal essentially came to a standstill when Cassia filed its Complaint. If the
Commission agrees with Idaho Power that resource developers , including QFs, should
bear responsibility for initial funding of required system improvements , it is Idaho
Power s intention to restart the discussions and work diligently to effectuate a resolution
that protects customers and allows cost-effective QF projects to move forward.
Dated this z.::r day of October 2006.
~J1
Barton L. Kline
Attorney for Idaho Power Company
---
ANSWER AND COMMENTS OF IDAHO POWER - 33
CERTIFICATE OF MAILING
I HEREBY CERTIFY that on the Z 7 "'day of October 2006 , I served a
true and correct copy of the within and foregoing document upon the following named
parties by the method indicated below , and addressed to the following:
Scott Woodbury
Idaho Public Utilities Commission
472 W. Washington Street
O. Box 83720
Boise, Idaho 83702
Hand Delivered
S. Mail
Overnight Mail
FAX
Email: scott.woodburv(Q2puc.idaho.qov
Dean J. Miller
McDevitt & Miller, LLP
420 W. Bannock
Boise, Idaho 83702
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Email: dean (Q2 mcdevitt-miller.com
Ronald K. Arrington
Associate Chief Counsel
John Deere Credit
6400 NW 86th Street
Johnson , IA 50131
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Email: arrinqtonronaldk(Q2johndeere.com
Peter J. Richardson
Richardson & O'Leary
515 N. 2ih Street
O. Box 7218
Boise, Idaho 83702
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Email: peter(Q2 richardsonandolearv.com
Lawrence R. Lieb Hand Delivered
Exergy Development Group of Idaho, LLC x U.S. Mail
910 W. Main Street, Suite 310 Overnight Mail
Boise, Idaho 83702 FAX
Email: Irllal(Q2sbcqlobal.net
David J. Meyer
Vice President, Chief Counsel for
Regulatory and Government Affairs
Avista Corporation
O. Box 3727
1411 E. Mission Ave.
Spokane, WA 9220
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Email: dmeyer(Q2 avistacorp.com
ANSWER AND COMMENTS OF IDAHO POWER - 34
Brian Dickman
Dean Brockbank
Pacificorp
201 S. Main, Suite 2300
Salt Lake City, UT 84111
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Email: brian.dickman (Q) pacificorp.com
dean.brockbank (Q) pacificorp.com
Jeff Schlect
Manager, Transmission Services
Avista Corporation
O. OBx 3727
1411 E. Mission Ave., MSC-
Spokane, VV A 99220
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Email:
(lMcL:-
BARTON L. KLINE
ANSWER AND COMMENTS OF IDAHO POWER - 35