20070222Comments.pdf

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BEFORE THE
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IN THE MATTER OF THE APPLICATION OF
IDAHO POWER COMPANY FOR APPROVAL
OF A POWER PURCHASE AGREEMENT WITH
TELOCASET WIND POWER PARTNERS, LLC
AND TO INCLUDE THE ASSOCIATED
EXPENSES IN THE COMPANY'S ANNUAL
POWER COST ADJUSTMENT.
) CASE NO. IPC-O6-
COMMENTS OF THE COMMISSION STAFF
IDAHO PUBLIC UTILITIES COMMISSION
FEBRUARY 22 , 2007
ALLEGEDLY PROPRIETARY DATA HAS BEEN
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DONOV AN E. WALKER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 5921
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Street Address for Express Mail:
472 W. WASHINGTON
BOISE, ID 83702-5983
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
IDAHO POWER COMPANY FOR APPROV AL )
OF A POWER PURCHASE AGREEMENT WITH)
TELOCASET WIND POWER PARTNERS, LLC )
AND TO INCLUDE THE ASSOCIATED
EXPENSES IN THE COMPANY'S ANNUAL
POWER COST ADJUSTMENT.
CASE NO. IPC-O6-
COMMENTS OF THE
COMMISSION STAFF
The Staff of the Idaho Public Utilities Commission, by and through its Attorney ofrecord
Donovan E. Walker, Deputy Attorney General, in response to Order No. 30230, the Notice of
Modified Procedure and Notice of Comment Deadline issued on January 26, 2007, respectfully
submits the following comments.
BACKGROUND
On December 15 , 2006, Idaho Power Company (Idaho Power; Company) filed an
Application seeking approval of a Power Purchase Agreement (PP A; Agreement) with Telocaset
Wind Power Partners, LLC (Telocaset). Idaho Power asked that the expenses associated with the
purchase of capacity and energy from the PP A be included in the Company s annual Power Cost
Adjustment (PCA).
STAFF COMMENTS FEBRUARY 22, 2007
This PPA is the result ofIdaho Power s Request for Proposals (RFP) for 200 MW of wind-
powered generation that originated with the Company s 2004 Integrated Resource Plan (IRP). The
Company issued an RFP for 200 MW of wind-powered generation on January 13, 2005. In
September 2005 , the RFP was revised to ask for 100 MW instead of the 200 MW level, because of
the quantity of wind the Company anticipated receiving from PURPA qualifying facilities (QFs).
In June 2006 , Telocaset Wind Power Partners of Houston, Texas was selected as the preferred
bidder of the 2005 Wind RFP process.
The PP A guarantees an annual output of 196 000 MWh and has a planned capacity of
100.65 MW. The term of the PPA is 20 years, with an option for Idaho Power to extend the term
ofthe Agreement an additional 1 0 years. If Telocaset should wish to sell the facility, the PP A
provides Idaho Power with a first right of refusal. The guaranteed operation date for the facility is
March 31 2008.
ANALYSIS
Need for Wind Power
Idaho Power identified a need for wind power in its 2004 Integrated Resource Plan (IRP).
Specifically, the 2004 IRP called for RFPs to be issued for 200 MW of wind-powered generation
during the fall of2004, and for an additional 150 MW in 2008. Wind was a significant part of the
new resource portfolio that also included 100 MW of geothermal generation, 500 MW of coal-
fired generation, 48 MW of combined heat and power at customer facilities, 62 MW of distributed
generation or market purchases, and 124 MW of demand response and energy efficiency programs.
In addition, the portfolio included 88 MW of simple-cycle gas-fired generation, which ultimately
was filled by the 170 MW Evander Andrews plant recently approved by the Commission.
Idaho Power s need for new generating resources was thoroughly debated recently in
Case No. IPC-06-09. The debate centered on whether the proposed Evander Andrews plant was
needed, whether a 170 MW plant should be pursued when only an 88 MW need was identified in
the Company s IRP, and whether there were other resource alternatives that should be pursued
instead. Although the Industrial Customers of Idaho Power disputed the need for the proposed
new capacity and maintained that other DSM and generation alternatives were preferable, the
Commission ruled that that the need for future power to meet the projected peak loads of Idaho
Power was supported by substantial and competent evidence. Furthermore, the Commission noted
in its order that the Industrial Customers' argument was not so much with the forecast of possible
STAFF COMMENTS FEBRUARY 22 2007
peak deficiencies, but with Idaho Power s solution for addressing peak loads. See Order No.
30201.
Unlike the need for peaking generation filled by the Evander Andrews plant, wind is
primarily intended to meet Idaho Power s need for energy. However, just as the 2004 IRP
demonstrated a need for capacity, Staffbeheves it also convincingly demonstrates a need for new
energy resources. More importantly, Idaho Power s 2006 IRP, which was filed on September 24
2006 and reflects more up-to-date analysis, supports the acquisition of new energy resources as
well. In the 2006 IRP, summer monthly energy deficits begin in 2009. By 2015, energy deficits
are expected to occur in ten months of the year absent the addition of new resources. The
preferred portfolio in the Company s 2006 IRP maintains the quantity and timing of new wind
resources as was called for in the 2004 IRP, except that the 2006 IRP recognizes that at least 100
MW of wind will come as PURP A QFs rather than through RFPs. The 2006 IRP also identifies
other resource alternatives including conservation, load management, geothermal, coal-fired
generation, nuclear, combined heat and power, and new transmission projects that will provide
access to market resources.
Request For Proposals/Overview of Process
Prior to the issuance of the RFP, Idaho Power assembled an evaluation team. The team
consisted of five Company employees, one outside environmental advocate, and an independent
consultant. This group began by identifying specific attributes the Company would require to meet
the needs specified in the IRP. Those attributes were documented in the RFP. Based on those
attributes, an evaluation manual was prepared and a scoring system developed for the purposes of
evaluating proposals.
On January 13 2005, Idaho Power issued the RFP to purchase energy from wind-powered
generation resources located inside or near the Company s service territory (2005 Wind RFP). The
RFP sought approximately 200 MW of nameplate generation. Bidders were required to offer a
minimum of 30 MW of nameplate energy in their proposals.
Bids
This section of Staff's comments contains confidential information subject to
protective agreement.
STAFF COMMENTS FEBRUARY 22, 2007
Stage 1 Bid Evaluation
This section of Staff's comments contains confidential information subject to
protective agreement.
Reduction in RFP from 200 MW to 100 MW
Soon after a short list was developed, Idaho Power filed a Petition (Case No. IPC-05-22)
requesting a temporary suspension ofIdaho Power s obligation under PURPA to enter into new
contracts to purchase energy generated by qualifying wind-powered small power production
facilities (QFs or Qualifying Facilities). On August 4 2005 , the Commission issued Interlocutory
Order 29839 reducing the published avoided cost rate eligibility cap for non-firm QF wind projects
to 100 kW, requiring individual negotiation for larger wind QFs and establishing criteria for
determining whether some QFs larger than 100 kW should be "grandfathered" to receive the
published avoided cost rate.
While Case No. IPC-05-22 was pending and the various "grandfathering" requests were
being evaluated, the Company postponed further consideration of the short-listed bids received in
STAFF COMMENTS FEBRUARY 22, 2007
response to the 2005 Wind RFP until late September 2005. In September 2005, Idaho Power
advised the short-listed bidders that the Company intended to resume the 2005 Wind RFP process
and requested that those bidders submit a renewed proposal for 100 MW of nameplate capacity.
The amount was reduced from the previous 200 MW level because of the quantity of wind the
Company anticipated receiving from Qualifying Facilities under PURP A. The Company also
directed the short-listed bidders to obtain interconnection costs for each of the projects.
Staff believes that the Company s decision to reduce the RFP to 100 MW was appropriate.
Moreover, Staff views the decision as further evidence of Idaho Power s efforts to just meet its
forecasted energy needs, without overbuilding or acquiring too much.
Short List Bid Evaluation
This section of Staff's comments contains confidential information subject to
protective agreement.
STAFF COMMENTS FEBRUARY 22, 2007
Staff believes that price should always be the most important criteria in any RFP
evaluation. Thus, Staff would have preferred that price be more heavily weighted. In addition, in
the case of wind projects, Staff believes that quality wind data should be a prerequisite in order for
a proposal to be considered at all. Assuming the wind data meet minimum criteria with regard to
the period of record and methods of analysis, then scoring based on the quantity and timing of
wind resources is appropriate, at least to the extent it is not already being accounted for in the
generation amounts used in the cost analysis. Nevertheless, despite some reservations, Staff
believes that the short list evaluation methodology was reasonable and fair.
Short List Bid Evaluation Results
Horizon Wind Energy s Telocaset project scored the highest in all three major scoring
categories.
This section of Staff's comments contains confidential information subject to
protective agreement.
A summary of the scoring results for each of the
short-listed bids is included as Attachment 2. This section of Staff's comments contains
confidential information subject to protective agreement.
A summary of the non-price scores for each of the short-listed bids is included as
Attachment 3. This section of Staff's comments contains confidential information subject to
protective agreement.
STAFF COMMENTS FEBRUARY 22, 2007
Project Description
The Telocaset project, which has been named the Elkhorn Wind Power Project, will be
located on a 23 900-acre site in Union County, Oregon. The project will interconnect to the Idaho
Power Company transmission system at a point approximately three miles northeast of North
Powder, Oregon on the Company s Brown1ee-Quartz-LaGrande 230 kV transmission line. The
project will consist of 61 Vest as V82 wind turbine generators with a maximum installed nameplate
capacity of 104 MW, and an expected capacity of lOO.65 MW. The project's guaranteed operation
date is March 21 , 2008; however, Telocaset intends to attain an in-service date of December 31
2007.
Contract Terms and Conditions
The PP A with Telocaset guarantees an output of 196 000 MWh and a planned capacity of
100.65 MW. The term of the PPA is 20 years beginning with the operation date. Idaho Power has
an option to extend the term of the agreement an additional ten years. Should Telocaset choose to
sell its facility, the PP A provides that Telocaset first offer t9 sell its facility to Idaho Power.
The purchase price will start at a base rate of $48/MWh in 2007, with an annual escalation
adjustment of three percent. The rate will also be subject to the same seasonal adjustment factors
as are applied to PURP A contracts-generation in the springtime months of March, April and May
is priced at 73.5 percent of the contract rate, generation in the summer months of July and August
and the winter months of November and December is priced at 120 percent of the contract rate
and generation in all other months is priced at 100 percent of the contract rate. Based on the
expected generation of the proj ect over the 20- year contract term, the PP A has a present value
approximately $200 million. No payment is required by the Company for energy deliveries that
exceed the maximum contract amounts.
The PP A allows Idaho Power an option to purchase the project. Should Telocaset decide to
sell the facility assets comprised of all, or a substantial portion of the project, Telocaset must first
offer to sell the assets to Idaho Power. The PP A also allows Idaho Power to extend the term of the
agreement an additional 10 years if it chooses, at terms that would be negotiated between the
parties. Staff believes that both of these provisions add value to the Agreement.
STAFF COMMENTS FEBRUARY 22, 2007
Price Assessment
As stated above, the purchase price in the Agreement begins at $48/MWh in 2007 and
escalates at three percent annually. However, because the project's scheduled operation date is not
until December l , 2007 and its guaranteed operation date is not until March 31 2008, Staff
believes it is unlikely that any energy will be sold at the first year price of $48/ MWh. A more
likely first year rate is $49.44/MWh beginning in 2008. When levelized over the 20-year contract
term, the contract rate is $62.38 (year 2008 dollars). Under the terms of the Agreement, Idaho
Power is not required to pay for anything else other than the energy delivered by the project.
Furthermore, Idaho Power is only required to pay for energy it actually receives, i., there are no
take or pay" requirements in the contract.
One reasonable comparison to the purchase prices in the Agreement is the avoided cost
rates paid to PURP A QFs. The 20-year levelized PURP A rate for a project online in 2008 is
$63.84. Therefore, on a levelized cost basis, the rates in the Agreement are approximately 2.
percent below PURP A rates. Attachment 5 is a graph comparing the purchase prices in the
Agreement to the current avoided cost rates for PURP A QFs.
While it is encouraging that the purchase prices in the Agreement are below PURP
avoided cost rates, Staff believes it is very important to recognize that price alone should not be the
only factor considered. As will be discussed below, there are many other elements of the PPA that
make it different from a PURPA QF contract. Staff firmly believes that all of the PPA's terms and
conditions, including price, must be considered as a package in any comparison to other
alternatives.
It is somewhat difficult to directly compare the cost of the PP A to alternatives other than
PURP A contracts because there are no alternatives in which the prices are known with certainty
for 20 years. For example, market purchases might be considered an alternative, and forward
market prices can be ~eadily obtained, but certainly not for durations anywhere close to 20 years.
Prices from recently approved or built projects, such as Evander Andrews, are also poor
comparisons because those plants are dispatchable peaking plants, not base load energy plants like
this wind PP A. Furthermore, fuel costs for gas-fired plants are unknown in the future. Fuel costs
comprise a substantial portion ofPURP A avoided cost rates as well, but because they are assumed
for the life of the contract, they provide a baseline against which other alternatives can be
compared.
STAFF COMMENTS FEBRUARY 22, 2007
Staff believes that one of the best ways to judge the reasonableness of the price of a wind
PP A is to compare it to the price assumptions used in the utility s IRP for similar resources. The
price of the Telocaset PPA is very close to the cost of wind resources assumed in Idaho Power
2006 IRP. The IRP process compares the assumed costs of various resources, and then subjects
those resource alternatives to rigorous risk analysis including fuel price uncertainty. Because
recent Idaho Power IRPs have consistently selected wind as part of the preferred portfolio of new
resources, given reasonable cost assumptions and risk analysis, Staff is comfortable with Idaho
Power purchasing wind resources at the prices in the Te10caset PP
Transmission
The project is located in eastern Oregon, and would deliver its energy to a point on the
LaGrande-Brownlee 230 kV transmission line. Various transmission studies have been completed.
Those studies indicated that relatively minor transmission system upgrades will be required for the
Telocaset project. The estimated cost for transmission upgrades and interconnection of the project
is $3.6 million. Of that amount, $2.3 million will be considered interconnection costs, which
Telocaset will be required to pay without refund. The remaining $1.3 million will be considered
Network Upgrades " which under FERC's Large Generator Interconnection rules is eligible for
100 percent refund.This section of Staff's comments contains confidential
information subject to protective agreement.Final interconnection costs and
transmission upgrade costs will be spelled out in a Large Generator Interconnection Agreement
(LGIA), which is expected to be completed by February 28 2007.
The transmission upgrades discussed above will provide Telocaset with firm transmission
but only for 66 MW of the project's capacity. Because the transmission capacity is firm , no
curtailment of the first 66 MW of the project's output is expected due to congestion.
This section of Staff's comments contains confidential information subject to
protective agreement.
STAFF COMMENTS FEBRUARY 22, 2007
Performance Provisions
The Agreement contains numerous provisions designed to protect Idaho Power in the event
Telocaset is unable to perform in accordance with requirements of the PPA. Most of these
provisions are discussed individually below. Total liability for any and all damages during the
term of the PP A is capped at $15 million. This cap appears to be based entirely on negotiations
between the parties. It is difficult to judge the reasonableness of the cap amount because it is
nearly impossible to envision the degree of damage Idaho Power might incur as a result of non-
performance by Telocaset. As stated previously, the present value of the PP A over its lifetime is
approximately $200 million. However, if Telocaset defaulted completely, Idaho Power would
certainly incur some damages, but the Company could eventually acquire replacement power or a
different resource. There are no limits for damages attributable to willful breach of the PP A by the
proj ect.
Delivery Obligation Shortfall
Telocaset's guaranteed annual output under the PP A is 196 000 MWhs. The PP A includes
damage provisions if the project fails to deliver its guaranteed annual output. If the project is
unable to make up its delivery obligations to the Company during a three-year true-up period
(including the year at issue), the project will pay Idaho Power an amount equal to the rate of
STAFF COMMENTS FEBRUARY 22, 2007
$25IMWh, subject to a cap of $500 000/year for the delivery obligation shortfall. Both the price to
be paid for shortfalls and the cap of the project's liability for energy delivery shortfalls will be
escalated at three percent per year.
Staff believes that this contract provision, while it may seem reasonable, actually provides
very little protection to Idaho Power. First, the 196 000 MWh guaranteed annual output appears to
be based on generation from only the 66 MW portion of the project with firm transmission.
This section of Staff's comments contains confidential information subject to protective
agreement.Although Telocaset may be unable to guarantee an annual output of
more than 196 000 MWhs due to having only 66 MW of firm transmission capacity, it seems
highly unlikely to Staff that the project's actual annual generation would ever be this low. Staff
believes it would be reasonable to assume that the remaining 34 MW portion of the project will be
able to deliver a significant amount of generation each year, despite only having non-firm
transmission.
Second, the penalty amount of $25 per MWh seems quite low. Idaho Power may be able to
purchase replacement power at or below that price sometimes during the year, but market prices
will likely exceed that price most of the time.
Wind Data Forecasting/90-110 Performance Band
To better enable Idaho Power to integrate the project's wind generation into the Company
resource supply mix, the Agreement requires Telocaset, at its own expense, to provide the
Company with real-time access to the wind forecasting service used by the project, including
forecasts of the energy to be delivered during the next hour, next day, and next week. Should the
Telocaset project fail to provide timely and reliable wind forecast data, the PP A contains a
provision that allows the Company to implement the same 90%-110% performance band
provisions as have been included in typical PURP A wind contracts.
This PP A marks the first time a wind generator supplying electricity to Idaho Power will
deliver detailed wind velocity and duration forecast data to the Company. Staff supports the wind
data forecasting requirements contained in the Agreement. Staff believes that forecasting is
important for large wind projects due to the intermittent nature of the resource. Accurate
forecasting can help minimize integration costs. In a separate case filed recently by Idaho Power
the Company is proposing, among other things, to eliminate the 90%-110% performance band
STAFF COMMENTS FEBRUARY 22, 2007
provision for PURP A QFs, provided that QFs reimburse the Company for their share of the
ongoing cost of the wind forecasting service. Reference Case No. IPC-07-03.
Delay Damages
Under the terms of the Agreement, Telocaset will be subject to delay damages of$100/MW
for each day the project does not become operational beyond the guaranteed in-service date of
March 21 2008. This delay damage provision is capped at $1.8 million.
Staff believes that this damage provision is somewhat weak. If the entire project capacity
is delayed, for example, the penalty would amount to about $10 000 per day. Assuming a 34
percent capacity factor, the plant could generate approximately 816 MWhs per day. Dividing
$10 000 per day by 816 MWhs per day gives an equivalent penalty amount of$12.25 per MWh.
As long as Idaho Power could obtain replacement power for no more than $12.25 above the
contract rate ($49.44 in 2008), it would be unharmed. Staff believes that replacement power could
easily exceed this price, however.
Performance Assurances
Prior to the project's in-service date, Telocaset will provide a performance assurance of $1
million. On or after the in-service date, Telocaset will maintain performance assurance of $10
million. In addition, if damages such as those described above are incurred, the PP A includes
security assurances that allow the Company to collect the calculated damages. The obligations
Telocaset will be secured by a guaranty issued by Goldman Sachs, Horizon Energy s parent
company. Should the credit rating of Goldman Sachs fall below a predetermined level, Goldman
Sachs will be required to post a liquid form of performance assurance.
The amounts of the performance assurances were negotiated between the parties. Once
again, there is no precise way of measuring whether the amounts are sufficient. Nevertheless
Staff believes that the amounts are high enough to provide strong incentive for Telocaset to
perform as required by the PP
Horizon Energy/Goldman Sachs Experience
Telocaset's parent company, Horizon Wind Energy, is an experienced wind developer.
Horizon has developed more than 1 000 MWs of operating wind farms and currently owns and
operates eight wind generation projects with generation capacity of 569 MWs. Horizon Wind
STAFF COMMENTS FEBRUARY 22 , 2007
Energy s holding company, Goldman Sachs maintains credit ratings of A+ (Standard & Poor) and
Aa3 (Moody s Investors Services). Staff considers both Horizon and Goldman Sachs to be
desirable counterparties to a PP A.
Renewable Energy Credits
In accordance with the Agreement, Idaho Power will retain all renewable energy credits
(RECs) or green energy tags from the project. In its 2006 IRP , the Company stated that it
recognizes that the acquisition and retention of green tags is necessary to accurately fulfill the
renewable energy component of Idaho Power s resource portfolio. The Company believes that
green tags are necessary in order to assure customers that it has acquired the energy from
renewable resources. Idaho Power also states that by retaining the green tags from the Telocaset
project, it would stand prepared should future federal or state law impose renewable energy
requirements on the Company.
Staff maintains that once a renewable energy project is built and operating, the
environmental benefits created by the facility are realized by customers and nearby project
residents whether green tags are sold or not. The sale of a green tag from an operating project
creates no more environmental benefit than would otherwise exist if no tags were sold. Staff sees
the proper role of green tags as increasing the revenue generation potential of a project to such an
extent that it causes the project to be built when it otherwise would not be built. Unless there is a
requirement for utilities to possess green tags, Staff believes it would be foolish not to sell them
and flow the sales revenues back to customers. By selling the green tags, customers enjoy both the
environmental benefits of the project and the green tag sales proceeds. Recognizing that Idaho
Power might be required to possess green tags at some time in the future, however, Staff
recommends that they be sold for now on a short-term basis only.
Ratemaking Treatment
The PP A provides for certain "bridge" financing to Telocaset by Idaho Power to cover
Telocaset's cost exposure to acquire certain long lead-time items such as a transformer and certain
engineering and design expenditures while the Commission is considering this Application. Idaho
Power will establish a reserve account and fund the cost to enable Telocaset to proceed prior to
IPUC approval of this Application. Staff understands that bridge financing is typically a lower
STAFF COMMENTS FEBRUARY 22 , 2007
cost alternative for financing. Staff recommends that any expenses related to the "bridge
financing be considered for approval in a future rate proceeding.
Staff agrees with the proposed accounting treatment of the costs associated with the PP
The Company proposes that the costs of the PP A be recovered in a manner similar to non-QF
expenses, with 90% of variations captured through the Company s PCA mechanism until the
Company s next general rate case, at which time the Company be allowed to include the costs of
the PP A in base rates. Staff recommends that the Company keep track of the PP A as a separate
line item in the PCA until it is included in base rates in the Company s next general rate case.
Staff's Overall Assessment of the Agreement
Many of the principal provisions of the PP A are similar to provisions contained in the
Company s existing PURP A contracts. The price in the Agreement, for example, is only slightly
below PURP A avoided cost rates.
There are many key differences, however, between the PP A and a typical PURP A contract.
First, PURP A contracts are considered firm energy agreements, implying that firm transmission
capacity is available for the QFs entire output. Under the Telocaset Agreement, only 66 MW of
the project's 100 MW capacity has access to firm transmission capacity. Second , although typical
PURP A contracts contain some performance requirements, they are not nearly as stringent as those
contained in this PP A. The PP A contains online delay damages, guaranteed annual output
requirements, and delivery obligation shortfall penalties. In addition, the Telocaset Agreement has
performance assurances that are secured by Goldman Sachs guarantees. Finally, green tags are
provided to Idaho Power at no additional cost under the PP A, whereas the project developer under
PURP A contracts retains them.
As stated previously, Staff believes that judgment as to the reasonableness of the PP A must
be based on the PP A in its entirety. Specific provisions in the PP A could have been stronger in
Staffs opinion, but we recognize that all provisions are negotiated as part of a package. On the
whole, Staff believes that the PP A is more attractive than if the project had contracted with Idaho
Power as a PURP A QF. If approved, Staff believes that the Telocaset Agreement will become a
valuable piece of the Company s resource portfolio.
STAFF COMMENTS FEBRUARY 22, 2007
RECOMMENDATION
Staff recommends that the Commission issue an order finding that the Power Purchase
Agreement with Telocaset Wind Power Partners LLC is prudent and approving inclusion of the
prudently incurred power purchase expenses associated with the Telocaset PP A in the Company
Power Cost Adjustment.
Respectfully submitted this day of February 2007.
Gbt
!!!
Deputy Attorney General
Technical Staff:Rick Sterling
Kathy Stockton
i:umisc/commentslipceO6.31 dWIT'skls
STAFF COMMENTS FEBRUARY 22, 2007
ATTACHMENTS 1 THROUGH 4
CONTAIN CONFIDENTIAL INFORMATION
SUBJECT TO PROTECTIVE AGREEMENT
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CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 22ND DAY OF FEBRUARY 2007
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN
CASE NO. IPC-06-, BY MAILING A COpy THEREOF, POSTAGE PREPAID, TO
THE FOLLOWING:
MONICA B MOEN
BARTON L KLINE
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
JIM MILLER
RIC GALE
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
SECRETARY
CERTIFICATE OF SERVICE