20120301Comments.pdf

WELDON B. STUTZMAN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 3283
RECEI 0
ioiz ~îPR -I PH~: 0 ,
Street Address for Express Mail:
472 WWASHINGTON
BOISE ID 83702-5918
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )
IDAHO POWER COMPANY FOR AUTHORITY )
TO CONVERT SCHEDULE 54 - FIXED COST )
ADJUSTMENT - FROM A PILOT SCHEDULE )
TO AN ONGOING PERMANENT SCHEDULE. )
)
CASE NO. IPC-E-1l-19
COMMENTS OF THE
COMMISSION STAFF
COMES NOW the Staff of the Idaho Public Utilties Commission, by and through its
attorney of record, Weldon B. Stutzman, Deputy Attorney General, and in response to the Notice
of Modified Procedure issued in Order No. 32454 on February 14,2012, submits the following
comments.
BACKGROUND
On October 19,2011, Idaho Power Company (Idaho Power, Company) fied an
Application requesting a Commission Order authorizing the Company to convert its current
Schedule 54 - Fixed Cost Adjustment (FCA) - from a pilot program to a permanent schedule. In
March 2007, the Commission issued Order No. 30267 (Case No. IPC-E-04-15) approving
implementation of a three-year FCA pilot program applicable to residential and small general
service customers. In October 2009, the Company filed an Application seeking to convert the
pilot program to a permanent program. In April 2010, the Commission issued Order No. 31063
STAFF COMMENTS 1 MARCH 1,2012
denying the Company's request and instead extended the pilot program for an additional two-
year period. The FCA pilot program expired on December 31, 2011.
The FCA purports to remove recovery of a portion of the Company's fixed costs from its
energy sales. The present Application states that the purose of the pilot program was to test the
FCA mechanism to determine "its efficacy in removing the unintended rate design disincentive
for the Company to aggressively pursue DSM programs." Application at ~~ 8. The Company
contends in the present Application that the first four years of the pilot program indicate the FCA
mechanism is working as intended and operates to mitigate the adverse affects of energy
effciency by ensuring that the fixed costs authorized by the Commission for recovery are being
recovered through the FCA mechanism. ¡d. The Company again proposes making the program
permanent for the residential and small general service customer classes, and proposes to true-up
the FCA by combining the deferral balances of both classes and implementing uniform
percentage changes for both classes. Idaho Power asserts that by combining the FCA balances
and determining the rate adders on a uniform percentage rate adjustment for each class, the
overall rate impact to customers is more representative of the total amount of the required fixed-
cost recovery for each class. Application, pp. 5-6.
ST AFFANAL YSIS
Staff agrees that traditional ratemaking has an inherent disincentive toward utility-
sponsored energy efficiency investment, and that Idaho Power's FCA mechanism has worked to
parially offset this paradigm. Though Staff raises questions of causality, it is true that Company
sponsored program investment and energy savings have substantially increased since the advent
of the FCA. However, Staff is not convinced that the FCA is entirely responsible for these
increases. As wil be explained more fully, Staff recommends that the FCA should continue as a
permanent program subject to a symmetrical 50% sharing between customers and Idaho Power
of fixed cost recovery impacts caused by load changes.
Purpose of the FCA
Staff believes it is important to reiterate the principle rationale for the FCA in order to
differentiate what it was not intended to do. Decoupling in general is promoted as a means to
sever the linkage between a utility's revenue and its energy sales. Decoupling can come in many
forms, of which the FCA mechanism is only one. The FCA can be considered "partial revenue
STAFF COMMENTS 2 MARCH 1,2012
per customer" decoupling: parial in the sense that sales variations due to weather are
normalized; and per customer in the sense that revenues are allowed to change according to
customer growth. Idaho Power, in its Application for the FCA Pilot and through supporting
testimony of Ric Gale, regarded the FCA as a 'true-up' mechanism rather than a decoupling
mechanism. While not losing sight of the central purose, there are implications to moving away
from the generic notion of decoupling.
Through a collaborative process, parties agreed in a Settlement Stipulation to the curent
pilot mechanism. Case No. IPC-E-04-15. Both the Company and Staff have echoed the notion
that the purpose of the FCA is to remove the financial disincentives in the current rate design to
encourage greater investment by the Company in energy effciency activities. There are
numerous methods that can and have been applied in other states i, but the paries in the
Stipulation agreed to this specific mechanism due to the transparency and potential to deliver
energy efficiency savings that otherwise might not occur. In approving the 2006 Stipulation, the
Commission noted that "(pJromotion of cost-effective energy efficiency...is an integral part of
least cost service," and that the "proposed FCA mechanism removes a Company-identified
disincentive to energy efficiency." Order No. 30267, p.13.
The intent of the Commission seems clear when directing the paries to "assess financial
disincentives inherent in Company sponsored conservation programs" in Case No. IPC-E-03-13.
Order No. 29505, p. 68. Staff has found no evidence that the Commission's main intent was to
separate Idaho Power's revenues from its sales, or, as Company witness Cavanagh states in his
testimony, "break the linkage between its financial health and its retail electricity sales."
Cavanagh, p. 3. Due to the design of the FCA, this certainly has been a byproduct, whether
intended or not. Staff believes that the current FCA provides benefits to the Company that
exceed removal of the DSM throughput disincentive, and has failed to address associated
concerns raised by various parties since its inception. Should the Commission agree that
removal of energy efficiency investment disincentives is the purpose of the FCA, Staff maintains
that modifications to the curent program are waranted.
i An early reference for alternative mechanisms can be found in "The Theory and Practice of Decoupling" by Eto,
et.a\. The Regulatory Assistance Project has a more recent overview of decoupling and revenue stabilzation
mechanisms, entitled "Revenue Regulation and Decoupling: A Guide to Theory and Application" from June 20 i i.
STAFF COMMENTS 3 MARCH 1,2012
Shortcomings of the FCA
In supporting the 2004 Stipulation, Staff noted several concerns with instituting the FCA.
Staff witness Randy Lobb listed such concerns as: 1) the potential impact on customer rates,
including fixed cost recovery associated with new customers; 2) recovery of lost fixed costs for
reasons other than the Company's DSM efforts; and 3) whether removal of the disincentives
would result in measurable improvement in the Company's DSM Programs. Case No. IPC-E-
04-15, Lobb Direct, p. 6. Staff fuher cited overlapping recovery with the PCA through the load
change adjustment rate (LCAR) and the impact of tiered rates of fixed cost collection as
additional concerns. Case No. IPC-E-09-28, Staff Comments, p. 9. Because of these issues,
Staff advocated a cautious approach toward implementing the FCA through first a three-year
pilot and the subsequent two-year extension.
Staffs primar concern with the curent FCA is that, with the exception of weather, there
is no regard as to the source of variation in sales per customer.2 In considering its position on
continuing the FCA, Staff compared the Company's efforts toward energy effciency, both
directly through its own programs and indirectly (such as energy code revision and market
transformation), against sources of declining consumption that are beyond the Company's
control, such as economic decline. The table below demonstrates that the amount of reduced
consumption attributed to non-Company sources is substantial:
IPC Residential Energy Effciency Savings and Calculated Reduced
Consumption
EE Savings (kWh)3
Total
Reduced
Consumption (kWh)4
% of Reduction
attributed to EE
20075 19,253,839 N/A N/A
2008 17,035,148 39,380,584 43%
2009 34,612,708 146,783,704 24%
2010 68,824,171 226,068,062 30%
2 Company witness Youngblood acknowledges this in his testimony, citing several factors that may impact usage per
customer. Youngblood, p.15.3 Energy Effciency savings are calculated as the cumulative first year savings from programs instituted in the time
period between rate fiings.
"Reduced consumption" was calculated by dividing the FCA balance by the FCE for each year.5 Customers received a credit in 2007, thus, technically, there was no reduced consumption.
STAFF COMMENTS 4 MARCH 1,2012
The issue has been raised several times by Staff in comments and testimony since the
inception of the FCA. Staff recognized in the 2009 FCA filing that approximately 42,000 MWh
of the 54,000 MWh reduction in sales were due to non-DSM related factors. IPC-E-09-06, Staff
Comments, pA. Staff noted the downtur in the Idaho economy and the waning use of electric
space heating has resulted in declining electric consumption in the 2010 and 2011 FCA fiings.
See Case No. IPC-E-IO-07, Staff Comments, 3 and IPC-E-II-03, Staff Comments, p.4. The
FCA's disregard for causes of consumption variation is also evident in periods of increased use
per customer. Staff pointed this out in its comments in Case No. IPC-E-09-28, stating, "...when
2007 energy usage increased, the Company had to pay customers $2,400,588, thus penalizing
IPC for factors that did not have anything to do with its energy efficiency programs." Staff
Comments, p.6.
Staff stated in comments that "while (problems with non-DSM related reduced
consumption J were identified before the FCA was implemented, the magnitude of the problem
was not." Case No. IPC-E-09-28, Staff Comments, p.6. Staff has no evidence that DSM savings
have contributed to any more than 43% of reduced consumption during the FCA timeframe.
Even in 2010, two years removed from the base year, cumulative energy effciency savings
accounted for approximately 30% of reduced consumption. It is important to modify the FCA
mechanism to adequately address lost fixed revenue due to Company DSM programs while not
excessively compensating Idaho Power for non-DSM usage reduction. It is just as important to
maintain a mechanism that remains relatively straight forward and does not rely solely on the
Company's DSM Reports in calculating lost sales/reduced consumption.
Staff has raised other issues with the FCA, which Idaho Power's Application does not
address. Staff first cited concerns with assumed fixed costs for new customers in IPC-E-04-15
(Lobb Direct, p. 8), and reiterated the point in IPC-E-09-28. Staff Comments, pp. 8-9. There are
two categories of "new customers": 1) those that occupy existing premises (like an existing
home) and 2) those that require the construction of new distribution facilties. The Company has
not addressed the "new customer" issue in its Application. Since the FCA recouples fixed costs
to customer counts, the implication is that new customers cause fixed costs to increase
proportionately to the average embedded costs of existing customers based upon the most recent
rate case. It is entirely possible that the fixed costs for new customers is higher than that
embedded in rates, such as new home construction requiring distribution and metering
equipment. Conversely, a new customer may require virtually no additional fixed costs, such
STAFF COMMENTS 5 MARCH 1,2012
as a customer moving into an existing home. Despite Staff s request, the Company was unable
to provide the level of fixed costs associated with new customers, both existing and new homes.
Additional fixed costs for new customers are presumptive by nature, but contain a portion
of generation and transmission costs that Staff believes is not incrementally incurred as customer
counts grow. As a result of recoupling fixed costs to customer counts, the FCA mechanism to
date has recovered a higher level of class fixed costs than what was approved in the rate case, not
"no more or no less" as the Company maintains. When customer growth outpaces sales growth,
the FCA simply results in a higher level of fixed cost for the class. In other words, the FCA
increases the class revenue requirement.
Also, one of the FCA design criteria stated by the paries was that cross-subsidies would
be minimized across customer classes. See Youngblood, p. 11 and IPC-E-04-15, Gale
Supplemental, p. 9. Staff does not believe this has been accomplished in practice. The cost of
service study from the general rate case serves as the basis for calculating the fixed cost per
customer (FCC) and fixed cost per energy (FCE). Since the advent of the FCA, the residential
class revenue requirement has included fixed costs from other classes that were not moved to full
cost of service, meaning the FCC and FCE contains fixed costs beyond those incurred by
residential and small commercial customers.6 In both Staffs and the Company's opinion,
residential customers have been responsible for more fixed cost recovery than recent cost of
service studies show is reasonable. Staff believes this is more appropriately a cost of service
issue, and should be addressed by the Company in its next general rate case. See Order No.
32426 at 11. Coupled with the disproportionate amount of DSM rider revenue generated by the
residential class, it is hard to argue that cross-class subsidies are minimized under the FCA.
The Company's Application does not address continuation of the discretionary 3% cap on
FCA rate adjustments. Through the first four years, the FCA balance has not exceeded the
discretionar cap.7 Individual customer bils have seen modest, but not trivial, surcharges the
past three years, as well as a slight refund the first year of the FCA, as shown in Attachment A of
Staffs comments.s It should be noted that the class revenue requirement increased three times
during the pilot period due to general rate increases, thus the magnitude of the FCA rate changes
6 3. I % of the current residential FCC is attibutable to other customer classes. Idaho Power's revised residential
FCC in this Application contains 3.4% of fixed costs from other customer classes.7 Had the FCA balances not been blended for the residential and small commercial classes, small commercial
customers would have exceeded the cap in each of the four years.8Staffprefers to characterize the rate adjustments as "modest" rather than "trivial", as Mr. Cavanagh states on page
8 of his supporting testimony.
STAFF COMMENTS 6 MARCH 1,2012
on a dollar basis increased at a greater rate than on a percentage basis. If rate increases through
general rate cases occur with relative frequency in the future, Staff believes that the possibilty of
exceeding the 3% cap remains relatively low. However, if the Commission decides to continue
the FCA, Staff recommends maintaining the 3% cap on FCA rate adjustments in the event that
sales do deviate significantly from the base year, along with blending the residential and small
commercial FCA deferral balances for collection/refund as proposed by the Company.
Finally, Staff acknowledges that Idaho Power's investment in energy effciency has
grown since the inception of the FCA. Staff is cautious to credit the FCA for all of the increased
energy efficiency gains. One would expect that the customer classes covered by the FCA would
see significant growth in energy effciency savings relative to other customer classes. That has
not been the case. Three of the four customer segments9 for Idaho Power have seen considerable
growth in energy savings. Residential energy savings have been on par with Industrial savings
on a percentage growth basis, though industrial customers are not subject to the FCA, and a
fraction ofthe percentage growth relative to the Commercial segment. 10 These results raise the
question whether the FCA has had a meaningful effect on Idaho Power's energy efficiency
activities. There is stil a considerable amount of cost-effective achievable energy efficiency
savings, and Staff believes maintaining some form of fixed cost recovery mechanism should aid
the Company in its continued pursuit to prudently acquire additional DSM energy savings.
Staff Proposal for Continuing the FCA
Due to the shortcomings of the curent FCA, Staff believes it is inappropriate to continue
the mechanism in its current form. Staff acknowledges that the FCA provides value to both the
Company and customers, and does not propose terminating it at this time. Staff recommends
modifying the existing mechanism to focus on lost fixed cost recovery caused by Company DSM
programs and its support of non-programatic energy efficiency activities.
9 Prior to 20 I I, Idaho Power did not keep track of energy savings by schedule, but rather customer segments.
Customer segments include multiple rate classes in the segments Residential, Commercial, Industrial, and Irrigation.10 Due to the grouping of commercial customers in the DSM Report, Staff is not able to distinguish between
Schedule 7 (covered by the FCA) savings and Schedule 9 (not covered by the FCA) savings. For perspective,
Schedule 7 comprises roughly 3% of Commercial energy sales.
STAFF COMMENTS 7 MARCH 1,2012
Staffs proposal maintains the relative simplicity of the FCA and limits introducing elements that
may make it cumbersome or contentious. Staffs proposal is outlne in greater detail below.
1. Sharing
In order to address Staff s concerns while maintaining the relative transparency of the
FCA, Staff recommends that the FCA balance be equally shared between customers and the
Company. Staff arived at the 50% sharing formula when evaluating the impact of Company-
sponsored DSM savings on reduced consumption (shown earlier in the table on page 4). DSM
savings accounted for a range of24 - 43% of reduced consumption. Non-programmatic savings,
such as support of building and appliance codes, market transformation, energy education and
rate design, are more difficult to quantify. Idaho Power committed to pursuing these areas when
initially agreeing to the FCA. IPC-E-04-15, Stipulation, Section 8. Setting the FCA recovery at
50% allows the Company to recover lost fixed costs associated with these activities as well as
traditional DSM programs.
2. Symmetry
Staff also recommends that the sharing band be symmetrical in that it would be
applicable to both under- and over-recovery of fixed costs. By maintaining symmetry, the
Company would issue a smaller credit to customers during periods of rising use per customer.
Staff believes this is appropriate since, as evidenced in 2007, other factors may have
overshadowed the Company's energy efficiency efforts. In staying true to the mission of the
FCA, the Company would retain a portion of fixed cost revenues for its programmatic and non-
programmatic DSM savings. The table below shows the historical impact of implementing
Staffs proposal on each FCA year, and reflects the lower credit customers would have received
in 2007.
Effect of Staff's Proposal on FCA Balance
FCA Balance With 50% Sharing
2007 $ (2,300,424)$ (1,150,212)
2008 $ 2,663,866 $1,331,933
2009 $ 6,263,983 $3,131,992
2010 $ 9.261,879 $4.630.940
Total $ 15,889,304 $7,944,652
STAFF COMMENTS 8 MARCH 1,2012
3. Tracking and Reporting
Under Staffs proposal, Idaho Power would continue to set the baseline FCC and FCE
and track the FCA deferral balances in the same maner as is currently in practice. Upon fiing
for deferral collection/refund, the Company would calculate the portion of the balance, including
any accrued interest, to be apportioned to customers. Monthly reporting of the FCA balance
should continue concurrent with the PCA monthly report.
Staff Consideration of Alternative Proposals
Many state commissions have authorized some type of mechanism to recover lost
revenues associated with energy efficiency investment. According to the "American Council for
an Energy-Efficient Economy," 34 states currently have at least one utilty with some type of
decoupling or lost-margin recovery mechanism in their jurisdiction. Of the 34 states, 22
(including Idaho) have full or parial decoupling; 18 states have a utility enrolled in a lost
recovery revenue mechanism; and 1 state has straight fixed variable pricing for natural gas.
2011 ACEEE State Energy Efficiency Scorecard, Appendix D. These mechanisms have been
authorized in a highly irregular and patchwork manner across the states. Oftentimes, a
Commission will authorize different types of decoupling for different utilities depending upon
the utilities' characteristics. The common thread cited by Commissions is a desire for increased
energy effciency savings. A number of jurisdictions have implemented safeguards to protect
against some of the issues raised by Staff. Many state Commissions, such as Oregon and
Vermont, have established energy effciency targets or performance incentives that are evaluated
by a third-party in conjunction to decoupling. Others, like Washington, exclude new customer
counts as a method to reign in excessive revenues due to customer growth. 1 1 The states of
Vermont and Hawaii have established an earings sharing mechanism based on a utilty's actual
retur on equity to reflect reduced risk.
Staff considered various options regarding the FCA, including a deadband on the deferral
balance, reduction in the return on equity to reflect reduced risk, and terminating the program.
Staff acknowledges that the FCA has merit, and determined that terminating the FCA at this
point would be counterproductive. Staff decided against the deadband approach as it failed to
ii Washington Commission Staff also promoted a deadband around the rate ofretum for Puget Sound Energy (2011
General Rate Case, Dockets UE-ll 1048 and UG-ll 1049). Staff advocated for a 25 basis point deadband above the
authorized ROR that, when met, would trigger an adjustment to decrease recovery into the deferral amount.
STAFF COMMENTS 9 MARCH 1,2012
meet the primary objective of the FCA in times when reduced consumption fell within the
deadband. The notion that a fixed cost recovery mechanism reduces Company risk has been
highly debated; Staff or other paries may pursue this in a general rate case setting. Staff
concludes that none of these options, including maintaining the FCA as it currently stands, aligns
the mechanism with its intent more effectively than Staffs proposal.
Staff does not believe that a perfect mechanism exists for removing the disincentive
toward energy effciency investment. Staff s research has found that parameters can be set too
broad (as in the case of the current FCA) as to provide a "found" revenue source that is
marginally or totally unrelated to conservation endeavors. Similarly, many mechanisms are
complex, cumbersome to administer, and rife with contention. Based on Staff s calculations of
reduced consumption, it is clear that Idaho Power's conservation efforts, though noteworthy,
compose but a fraction of overall reduced consumption. Based on historical observation, Staff
believes setting an FCA recovery at 50% allows ample collection of unrecovered fixed costs due
to Company-specific programs while providing additional revenues to reflect non-programatic
energy reduction. Staff believes its approach represents a modest, but appropriate, adjustment to
the current FCA. Adopting the Staffs proposal wil maintain the simplicity of the mechanism
while demonstrating strong support for the Company's growing energy efficiency achievements.
Staff Proposal Addressing the FCA on Customers' Bils
The FCA does not appear as a separate line item on customers' bils. It is combined with
the Energy Efficiency Rider charge and appears on customers' bils with the label "Energy
Effciency Services." Staff recommends that the FCA component be removed from the Energy
Efficiency Services line itein and instead be combined with the Power Cost Adjustment (PCA).
Staff is not proposing that calculation of the PCA change in any respect except for addition of
the FCA to the line item on customers' bils. From a practical perspective, both the FCA and
PCA adjust anually and concurently. The Energy Efficiency Rider, which is currently
combined with the FCA in a line item, changes far less frequently.
The transparency of billng elements on customers' bils has become an issue as energy
rates have increased and the Energy Efficiency Rider amount has changed over time. The
amount that actually appears on bils under the Energy Efficiency Services line item is greater
than the tariff rider itself due to the addition of the FCA. The difference between the Energy
STAFF COMMENTS 10 MARCH 1,2012
Efficiency Rider at 4% of base rate charges and the FCA as a fixed charge per kWh increases the
complexity of the calculation for customers trying to verify that their bil is correct, if in fact they
are aware of the FCA "adder" to this line item. Staff believes that this is a simple step that wil
improve customers' understanding of the components that make up the total bil.
In addition, Staff recommends that the line item currently entitled "PCA" be renamed
"Annual Adjustment Mechanism." The total amount shown on bils as the Annual Adjustment
Mechanism would be the sum of the PCA as calculated under Schedule 55 and the FCA as
calculated under Schedule 54. Instead of simply piggybacking the FCA on the PCA (as is
curently done with the FCA and the Energy Efficiency Rider), a new line item label wil more
appropriately describe the biling elements that customers are being biled. The fact that the
PCA mechanism itself recently expanded in scope to include recovery of the DSM deferral
balance provides furher justification for renaming the line item as it appears on customers' bils.
2012 FCA Rates
Idaho Power has fied updated FCC andFCE rates to reflect the terms of the Settlement
Stipulation in the recent general rate case (Case No. IPC-E-II-08). Though no formal cost of
service study was agreed upon, the Company did prepare a functionalized and classified revenue
requirement analysis as part of the 2011 Settlement Stipulation. Company witness Youngblood
testifies that the methodology used in determining the FCC and FCE for Residential and Small
Commercial customers is unchanged relative to previous studies. Youngblood, p. 22.
Staffhas reviewed the Company's proposed updates to the FCC and FCE, and believes
that the figures reflect the approved methodology. If the Commission authorizes the FCA to
continue, Staff recommends that the FCC for Residential customers be set at $650.63 per
customer per year, and the Residential FCE be set at $0.051602 per kWh. The Small
Commercial FCC of$360.57 per customer per year and FCE of $0.068633 per kWh are also
appropriate. As outlined in section 1 O(b) of the Settlement Stipulation, the FCC and FCE would
be retroactively applied as of Januar 1,2012, concurent to when the new rates went into effect.
Staff notes that this does not impact the curent collection of the FCA balance from 2010, but
updates the baseline for the deferral year of2012.
STAFF COMMENTS 11 MARCH 1,2012
STAFF RECOMMENDATIONS
Staff recommends continuing the FCA on a permanent basis with the modification that
the deferral balance be shared equally among customers and Idaho Power. Doing so would
better align the mechanism with the intent of removing the disincentive toward energy efficiency
investment. Staff recommends that the 3% cap on rate adjustments remains in place, and that
any FCA deferral balance be blended between the Residential and Small Commercial classes.
Staff does not oppose the Company's request to discontinue documenting its commitment
to energy efficiency outside of the anual DSM Report. The Company agrees to continue
reporting the monthly FCA balance as par of the PCA report. Staff also recommends that the
FCA be removed from the Energy Effciency Charges line item on customer bils. It is more
fitting to combine the FCA with the PC A, and create a line item entitled "Annual Adjustment
Mechanism." Finally, Staff has reviewed the Company's updated FCC and FCE, and believes
the rates stated above are appropriate, and should be applicable from January 1, 2012 going
forward.
Respectfully submitted this 1.~l'day of March 2012.
rO'( Weldon B. tzmanDeputy Attorney General
Technical Staff: Bryan Lanspery
Stacey Donohue
Nikki Karavich
Donn English
Beverly Barker
i:umisc:commentslipce II .19wsblcomments.doc
STAFF COMMENTS 12 MARCH 1,2012
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Attachment A
Case No. IPC-E-1l-19
Staff Comments
3/01/12
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 1ST DAY OF MARCH 2012,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN CASE
NO. IPC-E-II-19, BY E-MAILING AND MAILING A COpy THEREOF, POSTAGE
PREPAID, TO THE FOLLOWING:
JASON B. WILLIAMS
LISA D NORDSTROM
IDAHO POWER COMPANY
P.O. BOX 70
BOISE IDAHO 83707
E-MAIL: jwillams(iidahopower.com
Inordstrom(iidahopower .com
CBear~idahopower.com
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
710N 6TH ST
BOISE ID 83701
E-MAIL: botto(iidahoconservation.org
THORV ALD A NELSON
FREDERICK J SCHMIDT.
BRIAN T HANSEN
MARY V YORK
HOLLAND & HART LLP
6380 S FIDDLERS GREEN CIR
STE 500
GREENWOOD VILLAGE CO 80111
E-MAIL: tnelson(ihollandhar.com
fschmidt(ihollandhart.com
bhansen(ihollandhart.com
myork(ihollandhar.com
Inbuchanan(ihollandhar.com
MICHAEL J YOUNGBLOOD
ZACHARY L HARRIS
IDAHO POWER COMPANY
P.O. BOX 70
BOISE IDAHO 83707
E-MAIL: myoungblood(iidahopower.com
zharris(iidahopower .com
RICHARD E MALMGREN
SR ASST GEN COUNSEL
MICRON TECHNOLOGY INC
800 S FEDERAL WAY
BOISE ID 83716
E-MAIL: remalmgren(imicron.com
NANCY HIRSH POLICY DIR
NW ENERGY COALITION
8111 1 ST AVE STE 305
SEATTLE WA 98104
E-MAIL: nancy(inwenergy.org
.\t(~
SECRETARY
CERTIFICATE OF SERVICE