20090807Intervenor Funding Petition.pdf

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Eric L. Olsen, ISB No. 4811
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHARTERED
P.O. Box 1391; 201 E. Center
Pocatello, Idaho 83204-1391
Telephone: [phone]
Fax: [phone]
RECEIVEr;
ZOOS AUG -7 PM 3: 43
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UTILITiES COMf.liSSiON
Attorneys for Intervenor
Idaho Irrigation Pumpers Association, Inc.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE COMPANY'S )
APPLICATION FOR A CERTIFICATE )
OF PUBLIC CONVENIENCE AN )
NECESSITY FOR THE LANGLEY )
GULCH POWER PLANT )
)
CASE NO. IPC-E-09-03
INTERVENOR FUNDING
APPLICATION FOR INTERVENOR FUNDING OF
THE IDAHO IRRGATION PUMPERS ASSOCIATION, INC.
COMES NOW the Idaho Irgation Pumpers Association, Inc. ("IIPA"), by and though
counsel of record, Eric L. Olsen, and hereby respectfully makes application to the Idaho Public
Utilities Commission ("Commission") for intervenor fuding, pursuant to Idaho Code § 61-617 A
and IDAPA 31.01.01.161 through .165, regarding the expenses and costs associated with IIPA's
paricipation in the above referenced matter, as follows:
(A) A sumar of the expenses that the LIP A requests to be recovered is broken down
into legal fees, consultant fees and other costs and expenses and is set forth in Exhibit "A" attached
hereto and incorporated by reference. Itemized statements are also included as Attachments 1 and
2 to Exhibit "A" in support of said sumar and are incorporated by reference.
APPLICA nON FOR INTERVENOR FUNING OF IDAHO IRGA nON PUMPERS ASSOCIA nON, INC. - i
(B) On March 9, 2009, Idaho Power Company ("IPC" or lithe Company") filed an
application (the "Application") seeking a Certificate of Public Convenience and Necessity ("CPCN")
to constrct the proposed Langley Gulch Power Plant ("Langley Gulch") and asking the Commission
to rule on the regulatory treatment of the expenses that IPC would incur in building Langley Gulch.
The proceedings were placed on a compressed time frame given IPC' s contractu commitments with
respect to the purchase of the tubines for Langley Gulch, with Techncal Hearings just recently
concluding on July 16, 2009. IIPA's legal counsel, Eric L. Olsen, and consultant, Anthony J.
Yanel, P.E., paricipated fully at the Techncal Hearings, as well as all other critical aspects of this
case.
The LIP A has asked the Commission to delay its ruling on the Company's CPCN for Langley
Gulch for at least 10 months. This requested finding is based upon the direct and live testimony
provided by Mr. Yanel at the Techncal Hearngs. Mr. Yanel testified that the underlyig data for
the 2006 IRP and the 2008 Updated IRP which formed the basis for the Company's need for Langley
Gulch relied on stale data that does not reflect the most recent economic upheavals that have
occured in Idaho's economy in the last 9 to 18 months. Mr. Yanel testified that the outlook for
Idaho's economy, as with the nation as a whole, is trending downward as a result of the recession.
This has resulted in fewer new residential and commercial customers and fewer overall customer
counts for residential and commercial customers for IPC than forecast under its 2006 IRP and 2008
Updated IRP, with the associated reduction in forecast load from those non-materializing customers.
Mr. Yanel testified that these changes are directly correlated to the decrease in overall energy
consumption on the IPC system that has been declining since June of 2008. Yanel Dir., at p24, lls.
11-13. Mr. Yanel fuher testified that the energy and peak demand deficits that IPC was
APPLICA nON FOR INTERVENOR FUNING OF IDAHO IRGA nON PUMPERS ASSOCIATION, INC. - 2
forecasting in 2012 when Langley Gulch was to come online would not materialize in light of the
reduced energy consumption. He fuher testified that there would not be any adverse impact to the
Company's abilty to serve the system load if the Commission acted upon the IIPA's
recommendation to delay its ruling for 10 months due to IPC's abilty to utilze import purchased
power and the impact of the changes in the Peak Rewards Program.
(C) The expenses and costs incured by IIPA set forth in Exhbit A and accompanying
attchments are reasonable in amount and were necessarly incured to paricipate in this case. The
expenses and costs were incured in reviewing the Company's filing and intervenor testimony,
preparng and reviewing data requests and responses, drafing and filing direct testimony, preparing
cross examation questions for various witnesses, and paricipating in the techncal hearngs held
by the Commission. Without incurng these expenses and costs, the lIP A would not have been able
to fully paricipate in this matter.
(D) The costs described in Paragraph (A) above constitute a financial hardship for LIP A.
LIP A currently has approximately $55,000.00 in the ban with outstanding accounts payable from
paricipation in ths case and other concurrent cases totaling approximately $45,000.00.
LIP A is an Idaho nonprofit corporation that was organzed in 1968 to represent agrcultual
interests in electric utilty rate matters affecting farers in southern and central Idaho. lIP A relies
solely upon dues and contributions voluntaily paid by members, together with intervenor fuding,
to support activities. Each year mailings are sent to approximately 7,500 Idaho Irigators
(approximately two-thrds in the IPC service area and one-third in the Rocky Mountain Power
service area), soliciting anual dues. lIP A recommends that members make volunta contributions
based on acres irrgated or horsepower per pump. Member contributions have been falling
APPLICA nON FOR INTERVENOR FUING OF IDAHO IRGA nON PUMPERS ASSOCIA nON, INC. - 3
presumably due to the curent depressed economy, increased operating costs and threats relating to
water right protection issues.
From member contrbutions LIP A must pay all expenses, which generally include mailing
expenses, meeting expenses and shared office space in Boise, Idaho, in addition to the expenses
relating to paricipation in rate cases. The Executive Director, Lyn Tominaga, is the only par-time
paid employee, receiving a retaner plus expenses for offce space, offce equipment, and secretaral
services. Offcers and directors are elected anually and serve without compensation.
It has been and continues to be a financial hardship for LIP A to fully paricipate in ths case.
As a result of financial constraints, paricipation in ths case has been selective and, primarly, on a
limited basis.
(E) The testimony that the LIP A provided and positions that the lIP A has urged the
Commission to adopt materially differed from the testimony and positions put forth by Commission
Staf. Mr. Yanel compared the actual new residential and commercial customer counts for 2008
with those predicted under the 2006 IRP and the 2008 Updated IRP to look at curent trends that
affected the need for Langley Gulch. This, coupled with the curent economic data that Mr. Yanel
provided from the Idaho Division of Financial management, showed that is was very questionable
whether IPC would encounter the forecast customer growth and energy loads contained in the IRPs
that formed the basis for IPC's Application. This is born out by the trend since May of 2008 that
overall energy sold by IPC is decreasing, not growing, as pointed out by Mr. YaneL. This is
contrar to IRPs' forecasts that form the basis for the need for Laney Gulch. Furher, Mr. Yanel
pointed out that IPC' s load forecasts used since the 2006 IRP have been inconsistent in that they now
arificially limit the import of purchased power to meet resource deficits to meet peak demand.
APPLICATION FOR INTERVENOR FUNING OF IDAHO IRGATION PUMPERS ASSOCIATION, INC. - 4
Whereas there was no such limit in the 2006 IRP load forecasts. The LIP A also pointed out on cross-
examination that IPC used to model meeting any energy deficits though utilization of its peaker
unts, but that it has now changed that policy in the most recent load forecasts and taes the position
that the peakers canot be used to met any base load deficits. These recent changes in how IPC does
its load forecasting all appear to be manufactued to support the need for Langley Gulch and heighten
the dire consequences of not meeting forecast load if ths resource is delayed for any period of time.
Based on the above, the lIP A believes that its recommendation that the Commission delay
its decision on the Application until more up to date load forecasts are available differed materially
from the positions taken by the Staff and have materially assisted the Commission in making its
decision on this matter.
(F) The IIPA's recommendation of seeking to delay the Commission's decision on the
Application benefits all customer classes. It ensures that the Commission has all the necessar
information before it to make this historic decision. It also amounts to customer rate savings in the
the net present value cost of Langley Gulch is reduced and the costs associated with the project are
not put into rate base sooner than is needed.
(G) LIP A represents the irrgation class of customers under Schedule 24.
Based on the foregoing, it is respectfully submitted that the LIP A is a qualifyng intervenor
and should be entitled to an award of costs of intervention in the maximum amount allowable
pursuat to Idaho Code § 61-617A and IDAPA 31.01.01.161 through .165.
APPLICATION FOR INTERVENOR FUING OF IDAHO IRRGATION PUMPERS ASSOCIATION, INC. - 5
DATED this the 7th day of August, 2009.
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHARTERED
BY~~-I
ERIC L. 0 E
APPLICATION FOR INTERVENOR FUING OF IDAHO IRGATION PUMPERS ASSOCIATION, INC. - 6
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on ths 7th day of August, 2009, I served a tre, correct and
complete copy of the Idaho Irrgation Pumpers Association, Inc.'s Application for Intervenor
Funding to each of the following, via U.S. Mail or private courier, e-mail or hand delivery, as
indicated below:
Jean D. Jewell, Secretar
Idaho Public Utilities Commission
472 W. Washington Street
P.O. Box 83720
Boise, Idaho 83720-0074
jjeweiicmpuc.state.id. us
Baron L. Kline/Lisa D. Nordstrom
Idaho Power Company
1221 W. Idaho St./P.O. Box 70
Boise, ID 83707-0070
bklinecmidahopower.com
lnordstromcmidahopower .com
Peter J. Richardson
Richardson & O'Lear
515 N. 27th Street/.O. Box 7218
Boise, ID 83702
petecmrichardsonandolear.com
Scott Woodbur
Deputy Attorney General
Idaho Public Utilities Commission
472 W. Washington
P.O. Box 83720
Boise, Idaho 83720-0074
scott. woodburcmpuc. idaho. gov
Don Reading
Ben Johnson & Associates
6070 Hil Road
Boise, ID 83703
dreadingcmmindspring.com
U.S. Mail/Postage Prepaid
E-mail
Facsimile
Overnght Mail
Hand Delivered
U.S. Mail/Postage Prepaid
E-mail
Facsimile
Overnght Mail
Hand Delivered
U.S. Mail/Postage Prepaid
E-mail
Facsimile
Overnight Mail
Hand Delivered
U.S. Mail/Postage Prepaid
E-mail
Facsimile
Overnght Mail
Hand Delivered
U.S. Mail/Postage Prepaid
E-mail
Facsimile
Overnght Mail
Hand Delivered
APPLICATION FOR INTERVENOR FUING OF IDAHO IRGATION PUMPERS ASSOCIATION, INC. - 7
Ken Miler
Clean Energy Program Director
Snake River Allance
P.O. Box 1731
Boise, il 83701
kmilercmsnakeriveralliance.org
Betsy Bridge
Idaho Conservation League
710 Nort Sixth Street
Boise, il 83701
bbridgecmwildidaho.org
Susan K. Ackerman
Northwest Intermountan Power Producers
Coalition
9883 NW Nottge Dr.
Portland, OR 97229
susan.k.ackermancmcomcast.net
U.S. Mail/Postage Prepaid
E-mail
Facsimile
Overnight Mail
Hand Delivered
U.S. Mail/Postage Prepaid
E-mail
Facsimile
Overnight Mail
Hand Delivered
U.S. Mail/Postage Prepaid
E-mail
Facsimile
Overnght Mail
Hand Delivered
~./~ERïN ~
APPLICATION FOR INTERVENOR FUNING OF IDAHO IRGATION PUMPERS ASSOCIATION, INC. - 8
EXHIBIT" A"
SUMMARY OF EXPENSES INCURRD BY
IRRGATORS IN CASE NO. IPC-E-09-03
1. Legal Fees:
Eric L. Olsen (Parer): 80.2 ~ $185.00 per hour $15,658.00
Jason E. Flaig (Associate): .60 hrs ~ $135.00 per hour $ 81.00
Costs: Postage and travel $ 856.62
Total Legal Fees:$16.514.62
2. Consultant Fees:
Anthony J. Yanel: 242 hrs ~ $125 per hour $30,250.00
Costs: Meals and travel $ 1,618.05
Total Consultant Fees:$31,868.05
TOTAL FEES AND EXPENSES:$48,382.67
APPLICATION FOR INTERVENOR FUNING OF IDAHO IRGATION PUMPERS ASSOCIATION, INC. - 9
Attachment 1
APPLICATION FOR INTERVENOR FUNDING OF IDAHO IRGATION PUMPERS ASSOCIATION, INC. - 10
00 DescriptionCI~d 00::
Apr 23 8 Review hourly system loads durg the sumer to see when peaks occur and the
need for a new base load unt; review 2008 Demand-Side Management report for
alternatives to Langley Gulch; review 2008 Updated Integrated Resource Plan to
see how Langley Gulch fits into the plan.
24 6 Review testimonies ofBokenkamp,Gale, Smith, and Porter in the Langley Gulch
case; continue to review use of gas fired plants durng Febru of2008 in order to
discern how the company is using peakng versus base load unts.
May 18 7 Review 2006 IRP and 2008 Updated IRP as well as all appendix in order to
understand the changes in growt that were projected; determine how the projected
growth fit with the historic loads and assess how changes should have occured
because of the recession.
19 5 Review the Aurora Electrc Market Model simulation outputs associated with
Idaho Power's benchmark proposal as contained in the Response to Invenergy
Request 37 as it pertained to the cost and the energy associated with total
resources, market purchases and market sales durng each of the projected years.
20 5 Review the Aurora Electrc Market Model simulation outputs associated with the
Invenergy proposal as contaned in the Response to Invenergy Request 35 as it
pertained to the cost and the energy associated with tota resources, market
purchases and market sales durng each of the projected years.
21 4 Review 2008 Updated IRP for Idaho Power and see how it relates to conditions
that exist today; review data responses to the Industral customers and to Invenergy
regarding considerations of varous factors for building the plant.
26 7 Review 2008 Updated IR for Idaho Power and see how it relates to conditions
that exist today; review data responses to the Industral customers and to Invenergy
regarding considerations of varous factors for building the plant.
27 4 Review Langley Gulch fiing and search out data for futue prices of energy for the
sumer months at COB and elsewhere.
28 4 Review draft motion of joint interveners; teleconference with Irrgation Executive
Committee; review power cost data in order to define how gas unts are now being
used to supplement supply.
June 1 6 Review varous aspects of the Langley Gulch proposal and the varous Aurora
model outputs provided by the Company; discussion with the Staff; development
of interrogatories in order to determine what the impact of Langley Gulch is on the
Net Power Costs and see how this is impacted by the Irgation Peak Rewards
2 6 Review aspects of the Langley Gulch proposal dealing with the need for quick
action; review historic cases over the last 10 years where the Company also
requested quick action; paricipate in conference call with other interveners.
3 7 Review econometric data developed by the state ofIdaho; review 2006 IRP as well
as 2008 IRP update to determne what assumptions were used in the decision to go
with the Langley Gulch plant as indicated in the Company's testimony.
4 6 Review Idaho April 2009 econometrc forecast; review data requests from the last
rate case to glean data to be used/requested such as the bil frequency data by
month in the Staf data request.
5 7 Review forecasting data from the Idao Office of Management with that used in
the 2006 and the 2008 updated IRP's by Idaho Power; read the 2006 and 2008
updates to determine what historic data was actuly used; review responses to
production requests ofInvenergy.
8 Review 2008 IRP for detals when load data was gathered for inclusion in the IRP,
review discovery responses to determine when information was gathered for
forecast loads to be incorporated into the IRP's; review data responses to narow
down the responses that will be useful for testimony.
8
9 Begin comparsons of data regarding statewide housing stars and end of year
customers that are in the Company's varous documents such as the FERC Form 1
and the 2006 IRP; determine that a specific percentage of statewide housing stars
does not equate well to IPCo's year end residential customer figues; consider other
alternatives to define changes in IPCo data.
10 7 Review data responses that most reflect forecasting of load and the company's
treatment of this data; review the company's response to Staff request 84 which
lists new (larger) energy usage, but gives no support or basis for the change in
11 8 Develop information dealing with projected load growth from the two IRP's;
combine with information from the Idaho Economic Forecast from the State of
Idaho; begin to wrte testimony.
12 8 Continue to develop testimony regarding the results of the two IRP's as they apply
to the load forecasts that were incorporate; develop testimony regarding the results
of the Idaho Economic Forecast and how this differs with the forecast data used by
Idaho power before the economic downtu occured.
15 8 Review the 2009 IRP data, the December 2008 updated forecast, and the May 2009
updated forecast; compare information with 2008 Updated forecast; develop
comparsons and analyze changes per the change in the economy.
16 8 Write testimony regarding the impact or lack there of on the new forecasts that
were made in either the 2009 IRP or the updates to it.
17 8 Using data that was provided in the last thee forecasts, determine what was
changing with respect to the supply resources; evaluate grading the tyes of
changes as well as the magnitude of these changes.
18 8 Write testimony regarding the changes in supply resources; review impacts of
changes in the purchase power and why it was changed; wrte testimony on the
impact of Langley Gulch operations and surlus sales; wrte testimony regarding
the irrgation peak rewards program; discussion with other intervener witnesses.
19 7 Work testimony into final form; review for errors and tyos; incorporate Olsen's
comment into new draf of the testimony.
22 2 Review testimony of Staff witnesses Sterling, Carlock, and Hars
23 3 Review the two testimonies of Dr. Don Reading; compare with what I have done in
areas where he taes a slightly different direction.
July 3 4 Review rebuttal testimony of Company witnesses Smith, Pengily, Porter, Gale,
and Bokenkamp; outline possible areas of cross-examination.
6 6 Review testimony of Company witness Mace as well as his exhibits; begin to wrte
cross-examination questions for Company witness Bokenkamp; review
Fokekamp's direct testimony as well as previous IRPs.
7 8 Continue to work on cross-examination of Mace and Bokenkamp; wrte questions
and discussions and send to Olsen.
8 6 Review Mace's testimony for direction on where the Company may tr to cross-
examine me; check the sources and the data he used so that I would be fuly
familiar with his basis.
9 5 Review varous data responses from the Company and tr to correlate the various
load facts it had for Langley Gulch under different senaros; review the varous
forecasts used by the Company and why it changed the values that it assigned to
the non-firm purchases in the different filings that were made over the last few
10 7 Prepare for hearng; review all case material and determine what I needed to take to
Boise; review some of the data responses from the Company and try to determine
what was the basis of the rebuttal that the Company filed regarding my testimony;
coordinate testimony and cross-examination thoughts with the other paries.
13 8 Prepare for hearng; review all case material and determine what I needed to take to
Boise; review testimony and make notes as to the source of information; coordinate
testimony and cross-examination thoughts with the other paries.
14 9 Travel to Boise; attend hearng; assist in crossexamination.
15 9 Prepare for cross-examination; attend hearg.
16 6 Develop material for Olsen to use regarding the Pioneer plant and its similarties to
this case; attend hearng; assist with some cross-examnation regarding my
testimony; discussions with Olsen regarding what took place at the case while he
17
20
22
Total 242
8 Travel home; outline thoughts from the hearing that need to be incorporated into
the brief.
7 Review the testimonies of priarily Mace and Gale; develop an outline of the
arguments that need to be made in order to clarfy the difference between our
position and that of the Company's; wrte a draf of brief in the area of the problem
with the forecast data used by the company when compared to actual experience.
2 Continue to work on notes and material that may be of value for the brief.
Attachment 2
APPLICATION FOR INTERVENOR FUNDING OF IDAHO IRGATION PUMPERS ASSOCIATION, INC. - 11
RACINE OLSON NYE BUDGE & BAILEY, CHARTERED
Idaho Irrigation Pumpers Asociation, Inc.
Langley Gulch Power Plant
710.1518539
Client Date Att Rate Hours to Bil Amount Description
710,1518539 3/12/2009 ELO 185 0.2 $37.00 CONFERENCE WITH JEF RE: PREPARATION
OF APPLICATION FOR INTERVENTION IN
LAGLEY GULCH SITING AND BUILD CASE
710.1518539 3126/2009 JEF 135 0,6 $81.00 DRAFT A PETITION TO INTERVENE; REVIEW
IDAHO POWER'S NOTICE OF ACTION RE: THE
LANGLEY GULCH POWER PLANT
710.1518539 3/27/2009 ELO 185 0.3 $55.50 FINALIZE APPLICATION FOR INTERVENTION
AND SEE THAT SAME IS FILED
710.1518539 4/3/2009 ELO 185 0.2 $37.00 REVIEW CONFIDENTIALITY STIPULATION;
SIGN AND EMAIL SIGNATURE PAGE TO KLINE;
EMAIL YANKEL RE: SAME
710.1518539 4/8/2009 ELO 185 0.5 $92.50 REVIEW LAGLEY GULCH SCHEDULING
CONFERENCE ORDER; TELEPHONE
CONFERENCE WITH PET RICHARDSON RE:
LANGLEY GULCH CASE AND SCHEDULING
CONFERENCE
710.1518539 4/9/2009 ELO 185 0.8 $148,00 CALL AND LEAVE MESSAGE WITH YANKEL ON
LANGLEY GULCH CASE; TELEPHONE
CONFERENCE WITH TONY YANKEL RE: SAME
710.1518539 4/1412009 ELO 185 2 $370.00 PREPARE FOR AND ATTEND LAGLEY GULCH;
ATTEND SCHEDULING CONFERENCE
710.1518539 4/14/2009 ELO 185 3 $555.00 TRAVEL ONE WAY TO BOISE FOR
SCHEDULING CONFERENCE
710.1518539 4/16/2009 ELO 185 0.2 $37.00 REVIEW RESPONSES TO STAFF'S DATA
REQUESTS RE: LAGLEY GULCH
710.1518539 5/8/2009 ELO 185 0.5 $92.50 REVIEW EMAILS RE: PROTECTIVE
AGREEMENT FOR VIEWING BID MATERIALS;
SIGN EXHIBITS AND SEE THAT SAME ARE
SENT OUT
710.1518539 5120/2009 ELO 185 0.4 $74.00 REVIEW AND PREPARE DATA REQUESTS
710.1518539 5/21/2009 ELO 185 0.8 $148,00 REVISE IPPA'S DATA REQUESTS
710.1518539 5/26/2009 ELO 185 2.8 $518.00 TELEPHONE CONFERENCE WITH TONY
YANKEL RE: LANGLEY GULCH CASE AND
UPCOMING CONFERENCE CALL; PREPARE
FOR CONFERENCE CALL; PARTICIPATE IN
INTERVENOR CONFERENCE CALL;
TELEPHONE CONFERENCE WITH YANKEL RE:
ISSUES RAISED
Client Date Att Rate Hours to Bill Amount Decription
710.1518539 5/27/2009 ELO 185 1.3 $240.50 REVIEW DRAT OF PROPOSED MOTION TO
STAY; TELEPHONE CONFERENCE WITH SID
ERWIN RE: LAGLEY GULCH CASE;
TELEPHONE CONFERENCE WITH MARK
MICKELSEN RE: CONFERENCE CALL;
TELEPHONE CONFERENCE WITH DEAN
STEVENSON RE: CONFERENCE CALL;
TELEPHONE CONFERENCE WITH TONY
YANKEL RE: COMMENTS ON MOTION
710.1518539 5/28/2009 ELO 185 3.2 $592.00 DRAFT LANGUAGE FOR JOINT MOTION FOR
STAY; CONFERENCE CALL WITH EXECUTIVE
BOARD RE: UPDATE ON VARIOUS CASES AND
LANGLEY GULCH MOTION TO STAY; FINALIZE
MOTION LANGUAGE AND EMAIL FOR
INCLUSION IN MOTION; REVIEW FINAL JOINT
MOTION AND EMAIL PETE RICHARDSON RE:
SAME
710.1518539 6/1/2009 ELO 185 1.3 $240.50 REVIEW FILED MOTION AND PRESS RELEASE
FOR MOTION TO STAY IPC APPLICATION;
PREPARE FOR AND PARTICIPATE IN
CONFERENCE CALL; TELEPHONE
CONFERENCE WITH TONY Re: PLAN OF
ACTION ON STIPULATION
710.1518539 61212009 ELO 185 1.1 $203.50 PARTICIPATE IN INTERVENOR CONFERENCE
CALL; TELEPHONE CONFERENCE WITH TONY
YANKEL RE: SAME
710.1518539 61212009 ELO 185 0.4 $74.00 PREPARE SECOND DATA REQUEST AND SEE
THAT SAME ARE FILED AND SERVED
710.1518539 6/2/2009 ELO 185 0.2 $37.00 TELEPHONE CONFERENCE WITH BART KLINE
RE: SIGNING NDA; TELEPHONE CONFERENCE
WITH TONY YANKEL RE: SAME; SIGN NDA AND
EMAIL TO IPC
710.1518539 6/4/2009 ELO 185 0.2 $37.00 REVIEW DATA REQUESTS AND SEE THAT
SAME ARE SENT OUT; TELEPHONE
CONFERENCE WITH TONY YANKEL RE: SAME
710.1518539 6/8/2009 ELO 185 $185.00 TELEPHONE CONFERENCE WITH SCOTT
WOODBURY RE: THE INTERVENOR
COMMUNICATION ISSUE; TELEPHONE
CONFERENCE WITH TONY YANKEL RE: SAME;
DRAFT EMAIL RETRACTING THE YANKEL
EMAIL
710.1518539 61812009 ELO 185 0.1 $18.50 TELEPHONE CONFERENCE WITH TIM TATUM
AND TONY YANKEL RE: CLAIFICATION OF
DATA REQUEST
710.1518539 6110/2009 ELO 185 1.8 $333.00 REVIEW IPC DIRECT TESTIMONY IN
PREPARTION FOR HEARINGS
710.1518539 6/11/2009 ELO 185 1.4 $259.00 CONTINUE REVIEW OF IPC DIRECT
TESTIMONY
710.1518539 6/12/2009 ELO 185 0.5 $92.50 REVIEW IPC'S RESPONSE TO MOTION TO
STAY PROCEEDINGS
710.1518539 6/16/2009 ELO 185 1.5 $27750 REVIEW DRAT TESTIMONY OF Y ANKEL;
TELEPHONE CONFERENCE WITH TONY
YANKEL RE: DRAFT OF TESTIMONY
Client Date Att Rate Hours to Bil Amount Description
710.1518539 6/17/2009 ELO 185 2 $370.00 PARTICIPATE IN INTERVENOR CONFERENCE
CALL; CONTINUED REVIEW OF YANKEL DRA
TESTIMONY
710,1518539 6118/2009 ELO 185 0.9 $166.50 TELEPHONE CONFERENCE WITH TONY
YANKEL RE: REVISION OF TESTIMONY;
TELEPHONE CONFERNECE WITH PETE
RICHADSON RE: TESTIMONY POSITIONS;
TELEPHONE CONFERNECE WITH YANKEL RE:
SAME
710.1518539 6119/2009 ELO 185 2.8 $518.00 FINALIZE YANKElS TESTIMONY AND
PREPARE FOR FILING; TELEPHONE
CONFERNECE WITH TONY YANKEL RE: SAE
AND SEE THAT SAME IS FILED
710.1518539 6/19/2009 ELO 185 1.4 $259.00 REVIEW TESTIMONY OF INTERVENORS AND
STAFF
710.1518539 6/22/2009 ELO 185 1.8 $333.00 CONTINUE REVIEW OF INTERVENOR AND
STAFF TESTIMONY
710.1518539 6/29/2009 ELO 185 0.3 $55.50 REVIEW CONFIDENTIAL PORTION OF
TESTIMONY OF RICK STERLING
710.1518539 7/2/2009 ELO 185 0.2 $37.00 TELEPHONE CONFERENCE WITH TONY
YANKEL RE: REVIEW OF REBUTTAL
TESTIMONY
710.1518539 7/6/2009 ELO 185 0.6 $111.00 TELEPHONE CONFERENCE WITH TONY
YANKEL RE: REVIEW OF REBUTTAL
TESTIMONY; REVIEW IPC REBUTTAL
TESTIMONY
710.1518539 7/6/2009 ELO 185 1.6 $296.00 REVIEW REBUTTAL TESTIMONY OF MICHAEL
MACE
710,1518539 7/7/2009 ELO 185 2.8 $518.00 CONTINUE REVIEW OF TESTIMONY IN
PREPARTION FOR HEARINGS
710.1518539 7/8/2009 ELO 185 0.2 $37.00 TELEPHONE CONFERENCE WITH TONY
YANKEL RE: ISSUES FOR CROSS
EXAINATION
710.1518539 719/2009 ELO 185 1.6 $296.00 CONTINUE REVIEW OF TESTIMONY IN
PREPARATION FOR HEAING
710.1518539 7/10/2009 ELO 185 1.9 $351.50 CONTINUED REVIEW OF TESTIMONY IN
PREPARATION FOR HEARINGS
710.1518539 7/13/2009 ELO 185 8.4 $1,554.00 PREPARE CROSS EXINATION; TELEPHONE
CONFERENCE WITH (MULTIPLE) WITH TONY
YANKEL RE: SAME
710.1518539 7/14/2009 ELO 185 3.5 $647.50 TRAVEL TO BOISE
710,1518539 7/14/2009 ELO 185 8.3 $1,535.50 PREPARE CROSS EXINATION EXHIBITS;
PARTICIPATE IN TECHNICAL HEARING
710.1518539 7/1512009 ELO 185 8.5 $1,572.50 PARTICIPATE IN TECHNICAL HEAINGS
710.1518539 7/16/2009 ELO 185 1.8 $333.00 PARTICIPATE IN TECHNICAL HEARINGS
Client Date Att Rate Hours to Bil Amount Description
710,1518539 7/1612009 ELO 185 1.4 $259.00 TELEPHONE CONFERENCE WITH TONY
YANKEL RE: OUTLINING POST HEARING BRIEF
TO MEET FILING DEADLINES; OUTLINE ISSUES
FOR POST HEARING BRIEF
710.1518539 7/16/2009 ELO 185 0.1 $18.50 SEE THAT ARTICLE IN SENT TO YANKEL ON
PIONEER POWER PLANT
710.1518539 7/17/200 ELO 185 0.5 $92.50 PARTICIPATE IN INTERVENOR CONFERENCE
CALL
710.1518539 7/20/2009 ELO 185 2.1 $388.50 TELEPHONE CONFERENCE WITH TONY
YANKEL RE: POST HEAING BRIEF ISSUES;
EMAIL PETE RICHARDSON RE: SAME;
ORGANIZE FILE; REVIEW DRAFT OF POST
HEAING BRIEF ON DECREASING DEMAD
TRENDS
710.1518539 7/21/2009 ELO 185 1.8 $333.00 CONTINUED REVISION OF BRIEF ON
FORECAST VERSUS ACTUAL DEMAD;
REVIEW YANKElS COMMENTS AND FINALIZE
BRIEF SECTION; FORWARDING ON TO PETE
RICHARDSON FOR INCLUSION IN JOINT BRIEF
710.1518539 8/7/2009 ELO 185 4 $740.00 PREPARE APPLICATION FOR INTERVENOR FUNDING
Total for Fees 84.8 $15,658.00
Expenses
710.1518539 6/512009 ELO $15,09 POSTAGE 5/28 - PETER RICHARDSON
710.1518539 6/18/2009 ELO $257.40 RT MILEAGE POCATELLO-BOISE - 4/14
710.1518539 6/19/2009 ELO $36,00 COPIES OF YANKEL TESTIMONY FOR FILING
WITH THE PUC
710.1518539 7/20/2009 ELO $257.40 RT MILEAGE POCATELLO/BOISE
710.1518539 7/20/2009 ELO $196.48 LODGING AND MEALS
710.1518539 7/20/2009 ELO $94.25 CONFERENCE CALL
Total for Expenses $856.62
Togal for Fees & Expenses $16,514.62
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