20111215Magic Wind, LLC Comments.pdf

McDevitt & Miller LLP
Lawyers Mlff";E'...t-¡_~t-i ._tc.i'L.,1 't.L.,~.J --"" 1,,/ 1,..-
[phone]
[phone] (Fax)
420 W. Bannock Street
P.O. Box 2564-83701
Boise, Idaho 83702
20 II DEC 15 Pt1 l: O~has. F. McDevitt
Dean J. (Joe) Miler
December 15, 2011
Via Hand Delivery
Jean Jewell, Secretar
Idaho Public Utities Cotnssion
472 W. Washigton St.
Boise, Idao 83720
Re: Case No. IPC-E-I1-20
Magc Wind, LLC
Dear Ms. Jewell:
Enclosed for fig, please fid an orial and seven (T copies of Magic Wind, LLC's Comments.
Kidly retu a fie staped copy to me.
Very Truy Yours,
McDevitt & Mier LL
DJM/hh
Encl.
OR\G\NAL
Dean J. Miler (ISB No. 1968)
Chas. F. McDevitt (ISB No. 835)
McDEVITI & MILLER LLP
420 West Banock Street
P.O. Box 2564-83701
Boise, ID 83702
Tel: [phone]
Fax: [phone]
joe~cdevitt-miller.com
chaiÆcdevitt-miller.com
"". l'- "''' 1
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Lon DEC IS Pro; i: 03
Attorneys for Magic Wind, LLC
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )
OF IDAHO POWER COMPANY FOR )APPROVAL AND/OR )
ACKNOWLEDGEMENT OF THE )
TERMATION OF THE FIRM ENERGY )
SALES AGREEMENT, REMOVAL FROM )
THE INTERCONNCTION QUEUE, AND )
DISPOSITION OF THE CLUSTER GROUP )
NETWORK UPGRAE FUNDS FOR MAGIC )WIND,LLC. )
CASE NO. IPC-E-1l-20
COMMENTS OF MAGIC WI,
LLC
COMES NOW Magic Wind LLC (Magic Wind) and submits the following Comments, in
response to the Commission's Notice of Application, Order No. 32395, dated November 9,2011.
INTRODUCTION AND BACKGROUND
From Magic Wind's perspective, ths case involves the fai treatment of a project
developer following termation by mutu acquiescence of a PUR A Fir Energy Sales
Agreement. Due to a long senes of unortate circumstaces, Magic Wind was unable to bnng
the intended project on line with contractu time frames, and, in consequence, Magic Wind
has not disputed termination of the FESA. However, in the unwiding of contractu relations
following termnation, Magic Wind is entitled to fai treatment, and Idaho Power's Application
COMMENTS OF MAGIC WIND, LLC-l
contans two proposals that are unfai to Magic Wind. As discussed in more detal below, the
issues upon which Magic Wind and Idao Power disagree are:
1. Whether Magic Wind is entitled to a refud of the entire amount advanced for
Network Upgrade costs; and
2. Whether refuds of amounts advanced for network upgrade costs should bear interest.
The relevant facts, as set fort in the Commssion's Notice of Application are as follows:
On October 11, 2006, Idao Power and Magic Wind entered into a 20-year Agreement
pursuant to PURP A. Magic Wind's first energy date was scheduled to be July 31, 2007, and its
Scheduled Operation Date was scheduled for December 31, 2007. The Commssion approved the
Agreement on December 21,2006, Order No. 30206. Magic Wind was unble to meet their
December 31, 2007, Scheduled Operation Date.
In December 2008, Idao Power agreed to revise the Scheduled Operation Date to be
September 30, 2010. Pursuat to the terms of the Agreement, the project must be online withn
ten (10) months of the Scheduled Operation Date to avoid an event of default. Magic Wind failed
to bnng the project online.
On August 3,2011, Idaho Power and Magic Wind entered into a final agreement
("Letter Agreement") allowing Magic Wind to extend its Scheduled Operation Date to
September 30, 2012, so long as Magic Wind posted a delay secunty in the amount of $45 per
kilowatt of the project's nameplate capacity by no later than September 30, 2011. In addition, the
Letter Agreement required that Magic Wind payor otherwse make credit arangements with
Idaho Power to pay the $500,000 constrction deposit for its interconnection (which was past
due from June 30, 2011) no later than September 30, 2011. The pares agreed that if Magic
Wind failed to post the delay secunty or the constrction deposit by September 30, 2011, the
COMMENTS OF MAGIC WIND, LLC-2
Firm Energy Sales Agreement would be terminated without fuher notice. Magic Wind did not
post either the requied delay security or the required constrction deposit by September 30,
2011. On October 4,2011, Idaho Power sent Magic Wind a Notice of Termintion of the Fir
Energy Sales Agreement.
At the time Magic Wind's Agreement was submitted to the Commission for approval, the
Cassia Wind case was also pending before the Commssion. See IPC-E-06-21. The Cassia Wind
case involved requests from (mostly PUR A) generators to integrate approximately 200 MW of
new wind generation on Idaho Power's 138 kilovolt transmission system in the Twin Falls area
(the "Cluster Group"). In June 2006, Idaho Power completed englneenng studies which showed
it would cost approximately $60 milion in network upgrades to interconnect the Cluster Group
to Idao Power's transmission system. The Cassia Wind case dealt with issues related to the
appropnate allocation of network upgrade costs among individua projects within the Cluster
Group and Idaho Power's other customers.
In August 2007, the Commission approved a Settement Stipulation in the Cassia Wind
case that set fort the methodology that would be used to allocate network upgrade costs among
the individua Cluster Group projects and other Idaho Power customers. Order No. 30414:
On March 9, 2010, Idaho Power sent a final Facilty Study Report to the Cluster Group
members (including Magic Wind). Invoices were sent to each member for their allocable share
of the network upgrades. On Apnl 9, 2010, Magic Wind tendered $562,536.75 as payment for its
allocable share.
In its Application, Idaho Power proposes to deduct from the $562,536.75 the sum of
$76,569.83, which amount, according to Idaho Power, "has been spent on network upgrade costs
for Magic Wind." (Application, Paragraph 15). Idaho Power proposes a net refud of $485,967.
COMMENTS OF MAGIC WIND, LLC-3
Furer, Idaho Power proposes tht the amount to be refuded should not bear interest.
(Application, Paragraph 16(b)).
On these two issues, Magic Wind disagrees with Idaho Power.
ARGUMENT
1. Magic Wind is Entitled to a Refund of the Full Amount Deposited, Without
Deduction.
To the extent the rights and obligations of the paries are denved from wntten documents,
the most relevant document is Attchment 6 to the Generator Interconnection Agreement (GIA)
executed by Magic Wind. Attachment 6 incorporated the provisions of the Cassia Stipulation and
Order No. 30414, approving that Stipulation. Attchment 6 is attached to these Comments as
ExhibitA.
Neither Atthment 6, the Cassia Stipulation nor Order No. 30414, specifically address
the question of refuds to projects that withdraw from the queue pnor to connecting to the IPCo
system.
Review of these documents make it apparent, however, that network upgrade costs are to
be allocated among those projects that finally connect to the system. Projects that withdraw from
the queue and are never connected should not be allocated any porton of constrction costs
incured, because a withdrawn project neither receives any benefit from the IPCo transmission
system, not nor imposes any costs upon it.
Provisions of Attachment 6 supporting ths interpretation are:
"The Seller will pay its pro-rata share of the Network Upgrade costs actually incured by
the Company to provide firm Network resource Interconnection Service to the
Generation Facilty. (Emphasis added).
COMMENTS OF MAGIC WIND, LLC-4
Seller recognizes that the final cost of its share of the Network Upgrades wil not be
known until construction is completed. The Seller also recognzes that its share of the
final Network Upgrade cost wil increase or decrease, subject to the provisions of
paragraph 6, depending on whether other Requesting Projects, both earlier and later in the
Joint Study Group One are constrcted. (Emphasis Added).
It is the Company's intent that each QF Project in the Joint Study Group One will pay its
respective pro-rata share, based on nameplate generation capacity, of each phase of the
Network Upgrade they utilze." (Emphasis Added).
Idaho Power's proposal to deduct from the refud due to Magic Wind an allocated share
of constrction costs already incured is inconsistent with the intent of Attchment 6 which, as
demonstrated above, contemplates that network upgrade costs will be allocated to projects
actually connecting to the IPCo system. This is the only sensible interpretation of Atthment 6.
Furher, Idaho Power's proposal is inequitable. It would require Magic Wind to pay for a
benefit it will never receive. Costs for constrction of Network Upgrades, should be allocated to
those projects that receive the benefit of the Network Upgrades. In its Application, Idaho Power
does not, because it canot, ariculate a rationale for allocating Network Upgrade costs to
projects that never connect to the system. And, to the extent an amount is retaed by IPCo
from Magic Wind's deposit to pay for constrction costs, projects that do eventuly connect to
the IPCo system would receive a windfalL.
2. Magic Wind is Entitled to Interest on Amounts Refunded, Computed in Accordance
with 18 C.F.R.35.19a.
As noted above, Idaho Power proposes that any amount to be refuded to Magic Wind be
without interest. Idaho Power, in its Application does not ariculate any rationale for this
proposal.
In virtlly every other circumstance in which a utilty receives a deposit from a
customer, all or a portion of which is later refuded, the utility is obligated to compensate the
customer for the use of its money by the payment of reasonable interest. See e.g. IPUC
COMMENTS OF MAGIC WIND, LLC-5
Customer Relations Rule 106, IDAPA 31.21.106, Interest on Deposits and Idaho Power
Company TanffNo. 101, Rule L on Deposits.
The proposal is also inconsistent with Idao Power's coure of dealing with Magic Wind.
In connection with the Twin Falls Study Group, Magic Wind made a deposit of$II,765 for the
requied Facilty Study. As reflected by Exhbit B, Idaho Power refuded the deposit, less study
costs with interest.
Interest should be calculated using the methodology prescnbed by the Federal Energy
Reguatory Commission at 18 C.F.R. 35.l9a Which provides:
"(2) Interest shall be computed from the date of collection until the date refuds are made
as follows: (i) At a rate of seven percent simple interest per anum on all excessive rates
or charges held prior to October 10, 1974; (ii) At a rate of nie percent simple interest per
anum on all excessive rates or charges held between October 10, 1974, and September
30, 1979; and (iii)(A) At an average pnme rate for each calendar quaer on all excessive
rates or charges held (including all interest applicable to such rates or charges) on or afer
October 1, 1979. The applicable average pnme rate for each calendar quaer shall be the
anthetic mean, to the nearest one-hundredth of one percent, of the pnme rate values
published in the Federal Reserve Bulletin, or in the Federal Reserve's Selected Interest
Rates (Statistical Release G. 13), for the fourh, third, and second months preceding the
first month of the calendar quarer.
(B) The interest required to be paid under clause (iii)(A) shall be compounded quaerly.
(3) Any public utilty required to make refuds pursuat to this section shall bear all
costs of such refuding."
Use of the FERC methodology is consistent with Idao Power's practice of following
FERC methods and practices in matters relating to its transmission system. It is also consistent
with the Cassia Settlement Stipulation, in which the paries agreed the FERC methodology for
calculating interest on refuds. See Cassia Settlement Stipulation, page 8, paragraph 15.
COMMENTS OF MAGIC WIND, LLC-6
HEARNG NOT REQUESTED
Magic Wind does not request a hearg. If, afer review of Initial and Reply Comments,
the Commission believes ora arguent would be helpfu to its deliberations, Magic Wind
would, of course, paricipate.
CONCLUSION
Based on the reasons and authonties cited herein, Magic Wind respectfly requests that
any final order of the Commission approving termination of the Magic Wind FE SA contai the
following provisions:
1. That Idaho Power Company promptly refud to Magic Wind the ful deposit amount
of $562,536.75.
2. That Idaho Power Company pay to Magic Wind interest on the deposit, from the date
of deposit to the date of retu, calculated in accordace with 18. C.F.R. 35.19a.
DATED ths \,/t day of December, 2011.
MC\l. & MILLER, LLP.By: \~
Dean J. Miler
Attorneys for Magic Wind, LLC
COMMENTS OF MAGIC WIND, LLC-7
CERTIFICATE OF SERVICE
I hereby certify that on the JçQ~y of December, 2011, I caused to be served, via the
methodes) indicated below, tre and correct copies of the foregoing document, upon:
Jean Jewell, Secreta
Idao Public Utilties Commission
472 West Washington Street
P.O. Box 83720
Boise,ID 83720-0074
jjeweiicæpuc.state.id. us
Donovan E. Walker
Jason B. Wiliams
Idaho Power Company
1221 W. Idaho Street
P.O. Box 70
Boise, ID 83707
dwalkercæidahopower.com
jwillmascæidahopower.com
Kristine Sasser
Idao Public Utilties Commission
472 West Washington Street
P.O. Box 83720
Boise,ID 83720-0074
kns.sasseriguc.idaho.gov
COMMENTS OF MAGIC WIND, LLC-8
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Idaho Power Company Generator Interconnection Agreent # 135
I.P.U.C. No. 29, Tarif No. ,¡C1
Page 1 of4
Attachment 6
Company's Descriotíon of Speia! Facilities and Upgrades Required to Integrate the Generation
FacUity and Best Estimate of Costs
As provided in Schedule 72 this Attachment describes Upgrades, Special FaciJrties, including
Network Upgrdes, and provides an itemizd best estimate of the cot of the Upgrades.
Distribution Upgrades
Idaho Power Company will upgrade 2.5 miles of Blue Gulch distribution line (BUGU042) to 336 Al on
700E from 4300N to 4550N.
Desiotion Ower Estimated st
luoorade 2.5 miles distribution feëder to 336 AL ¡PC I $ 500,000.00
!
Total 1 S 500,000.00
Co
Transmission Netor Upgade
Network Upgrades for ths project were detailed in a searate Facmty Study Report for the Joint Study
Group identid in the March 14, 2008 System Impact Study Report for up to 353MW of New
Generation on the 138kV Transmission System in the Twin Falls area. The final cost wil be allocated
to the partcipants remaining in Joint Study Group One upon completion of each phase of the prjec.
See Attachment 6 for more information.
1) Regulatory Requirements:
A. A number of generation project seekí Network Resource
Interconnecion Serce, (as
that term is defined in FERC Order 2003 and the Company's FERC approved Open Accs
Transm¡ssion Tariff eOAIT)) including the Generation Facíliy, propose to interconnect to the poron
of the Company's transmission system is located in the Twin Falls, Idaho geographic area, and have
submitted interconnection requests to the Company during the period January 1, 2005 through
Octobe 1, 2007 (collectively, the "Requests" or "Requesting Projects").
B. In accordance with FERC Order 2003, the Company's OATI, Commission Order No.
30414 and in the Interest of maintaining comparabilty and economic efficiency in responding to the
Requests, the Company has established "Joint Study Group One (1)" for the Requesting Projects.
C seller is ready and willng to start immediate construction of the Generation Facility.
One or more Requesting Projects which precede or follaw Seller in the Joint Study Group One are not
yet prepared for immediate construction or may not be constructed at alL.
2) Generation Ouput Limi Control: The Generator Facilit is a PURPA OF. Seller will, at its
sole expense, install, operate and maintain the equipment and communications facilties necessary to
enable the Generation Facmty to reduce its Maxium Hourly Output to a not-to-ex.ced set point, within
ten (10) minutes of when the Company calls for the reduction. Th Company wil speciy the set point
when it notifes Seller of the need to initiate Geneation Output Umit ControL Generation Output Umit
Control cannot be used to increase the Generation Fadliy's output above such MaxImum Hourly
Output for then existing turbine and wind conditions. Seller wil normaHy. subject to ttose conditions,
seek to maximize the energy output of the Generation Facility, but Generation Output Lim1t Control \'i1i
limit the outut of the Generation Facilit whenever the Maximum Hourly Output level wauld otherw
exceed the required set point in any scheduling hour. Seller has elected to be subject to Generation
Output Limit Control.
ExIBIT A
PAGEloF4
Idaho Power Company Generor Intconncton Agreement '# 135
I.P. U.C. No. 29, Tari No. 101 Page 20f4
3) Cost Risk for Netork Upgrades: Network Upgrade costs wit be allocated to each
Requesting Project including the Generation Facity, based on: a) their election of whether to be
subiect to Generation OUtput limit Control, b) their order in the Joint Study Group One, and c) based
on the megawatt interconnection capacity of each Requesting Project, their prorata share of the cost for
the Network Upgrade reuired to inteconnec one or more Requesting Project and the added
interconnection capacit of that parcular Netwrk Upgrade. The Seller will pay non-reimbursed
amoonts of no more than 25% of the actual as-constructed cost of the Generator Facilities currenUy-
allocated share of the Network Upgrades required to interconnect the Generation Facilty witout
Generation Output Liit Control (see pararaph 6 below - Shat;ng of Network Upgrade Costs.
4) Genertion Output limt Conrol Rights: The Company may issue a set point or limit and
initate Generatin Output Limit Control to respond to transmission system emergencies, or respond to
circumstances where the transmission line(s) identified k1 Comission Order No. 30414 are out of
service and for 'Wicl Geeration Outt Limit Control was determined necessar and did fower the
amount of Network Upgrade cost obligation to the Generation Facility. In most circumstnces,
Generation Output Liit Control wil not be require when all the lines specifed in Commission Order
No. 30414 are in service. Ary use of Generation Output Limit Control to establish a set point below the
Generation Facilty's capacity shall be pro-rata with other Requesting Projects subject to Generation
OutPlJt limit Control. The Company wi not purchase or pay for energy which wou:d have been
produced by the Generatiol1 FaciJity, but for operation of Generation Output Limit Control.
5) Responsibility for Network Upgrade Costs: )n addition to funding all cots of direc¡y
interconnecting the Generation Facilty to the Company's system, the Seller will pay its pro-rata share
of the Network Upgrade costs actually incurred by the Company to provide firm Netwk Resource
Interconnecton Service to tle Generalion Facilty but the Generation Facility shall not be obligated to
share the on-going operatfon and maintenance costs of such NetworK Upgraces.
Seller recognizes that the final cot of its share of the Netwrk Upgrades will not be known until
constrction is complted. The Seller also reconizes that its share of the final Network Upgrade cost
wll increase or decrease, subject to the provisions of paragraph 6, dependin on whether other
Requesting Projects, both earlier and later in the Joint Stud Group One are constcted.
6) SharIng of Networ Upgrade Costs:
A. The Seller and th Company \.Yi~ share the five phases of Netwrk. Upgrade costs
attutable to the Generation Facilty as fallows:
1. Phase 1: the Company wil assume 100% cost responsibilty for Phase 1 and
indude this cost in its rate base.
2. Phases 2, 3, 4 and 5:
(a) 25% of the costs wil be provided by the Generation Facilit as a non-refundable
contribution in aid of constrr..ction ("CIAC").
(b) 25% of the costs will be funåed by the Company and included in the Company'srate base.
(c) 50% of the costs will be funded by Generation Facilit as an advance in aid ofconstruction ("AIAC") subject to refund as provided in paragraph 7 below. As
rends are made, the refunded amounts wilt be included in rate base using standard
regulatory accounting pncip~.
B. As project in the Joint Study Group One are intercnnect. the Company wil
reHocate the CIAC and AIAC portons oftl costs of Phases 2 through 5. For example, when
additioal projects in the Joint Study Group One are constructd after the Generation Facilit is
constructed, the Company wil collect monies from these subseq uent projects and refund
monies lo Seller. It is the Company's intent that each OF Project in the Joint Study Grup One
will pay its respective pro-rta share, based on nameplate generation capacity, of each phase of
the Nework Upgrade they uWize. Tabfes B-7, 8, 9 and 10 in the Settement Stipulation adopted
EXHIBIT A
PAGE20F4
Idaho Power Company Generator lntercnneet Agrement # 135
I.P.u.c. No. 29. Tarif No. 101 Page 3 of4
in Commission Order No. 30414 ilustrte how this re-alloction would occur on a hypothetical
basis.
7) Refnd provisions: The Seller 1,;1I be entitled to a cash repayment, in monthly, equal
installments, for the total AlAe amount the Seller advances to the Company for Network Upgrades.
including any tax gross-up or other tax related payments associated with the AlAC for Network
Upgrades. Repayment will be made in accrdance wih Artcle 11.4 of the Large Generator
Interconnection Agreement (ULGIA") included in the Company's OATT and Qccur over a term not to
excee ten (10) yea after the date the Generation Facilit achieves commercial operation. Monthly
repayments will be contingent on the FESA's bein in good standing (no uncured defaults) and upon
the Generation Facilit achieving a mechanical availabilty in that month in excess of 50%, define as
100% multiplied by the ratio of (1) the Slim of the capacity available to generate in each hour, over an
hours of the month, divided by (2) the installed capacity multiplied by the number of hours in the month.
In computng the mechanical availabilty, the capacity available in each hour wil not be reduced from
the instaUed capacity, if the reson for the reduction is an event of force majeure, (as that term is
defined in the FESA) or a reducton in genertion due to Generation Output Umit Control required by
the Company as describe in paragraphs 2 and 4.
8) Interet on Refunds: Monthly refund payments on AIAC amounts shal! include interest
calculated in accordance with the methodology set fort in FERC regulatins at 18 C.F,R.
35.19a(a)(2Xiii) from the date of any payment for Network Upgrades thol.gh the date on ,,\'ich Seller
receives final repayment
9) Seurity for Payment: Until it is finany determined which of th Projects in the Joint Study
Group One will be constructed and interconnected and the final cost of those interconnections is
detennined, upon execution of this intercnnection Agreement Seller will provide and maintain a cash
escrow or a letter of credit to the Company in a form and by an issuer satisfactory to the Company as
securit for payment. initially in the amount of the Generator Faciltys allocation of Network Upgrade
oosts as provided herein and adjusted from time to time pursuant to the status of the Requests. Th
total security amount at any time will not exceed the amount that would be owed if the Requests then
remaining in the Joint Study Group One tht are scheduled for constrction later than the Generation
Facility is not constrcted. Other OF participants in the Joint Study Group One will be held to a similar
requirement
10) Generation Output Umit Contol Protocols: This Interconnection Agreeent addresss
interconnecion of the Generation Facilty to the Company transmission sytem with Network Resource
Interconnecton Service. However. Seller acknowledges that. until sufcient Network Upgrades are
installed to aUow the Generatior. Facilty to qualif for Network Resource Interconnection Service. the
Generation Facilty wll be subject to Generation Output Umit Control as descrbe in paragraphs 2 and4. .
11 ) Network Upgrade Cost Determination: Network Upgrade costs, allocated to the Generation
Faclli for initial funding. wil be determined in a comparable manner and wih the same criteria used by
the Company when studying the interconnection of other generation, whose output can be ohanged
withIn ten (10) minutes, at other locations on its transmission sytem. Upon request by the Generation
Facilty, the Company wil provide a wrtten explanation of the methods a:i assumptions leading to any
such alloction of Network Upgrade cost obligation to th Generation Facility.
12) Reques Unceaint: The Company wil follow goo utility practice. the LGIP and SGIP, and
all Commisslon orders in processing the Joint Study Group One within Idaho Power Company's
Generator Interconnecton Queue. Any Requests that fail to meet those requirements to remain in the
Joint Study Group One, or fail to proceed to construct their interconnecton or fail to initially fund or
secure their allocated share of the Network Upgrade costs. wil foifeit their position in the Idaho POVvr
EXHIBIT A
PAGE30F4
Idao Power Company Generator Intercton Agreement # 135
I.P.U.C. No. 29. Tarif No. 101 Page 4 of 4
Company Generator lnterconnection Queue and their nghts to the intercnnection and transmissin
system capacity associatd wit thir Request.
13) Generation Facilty Respsibility for Networ Upgrde Costs: Th Company will initially
and throughout the life of fte Generation FaCllit¡. consistent with good utility practice. determine the
least cost solution. given the current status of the Requests in the Joint Study Group One, that will
result in the lowest reasonable allocaion .of ¡nitial fuding responsibilit for Netwrk Upgrades to the
Generation Facility. The Company will apply the same critena to all Projects in the Joint Study Group
One.
14) seller Constructon Resposibilty
Trasmission Networ Upgrades:
Descnotion Ower Estimate Ccst
Under 3114108 System Imoact Studv Reoo fo the Twin Falls area:
Phase 4 - Midpoint 113 Series Capacitor 8voass IPC $47,647.00
Phase 5 - Kino 2301138 kV transformer !P $ 702402.00
Total $750,049.00
Full payment IS required up front for each Phase in accordance with Setion 9 of this Attachment 6.
The final cost will be allocated to the paricipants remaining in Joint Study Group One upon completion
of each phase of the project.
Allocation of Transmission Network Upgrade Costs
Seller and Idaho Power wil share the actual Network Upgrde costs attbutable to the project as
follows:
1. 25% of the costs wil be provided by Seller as a non-refundable contrbution in aid of
construction ("CIAC.).
2. 25% of the costs will be funded by Idaho Power and included in Idaho Power's rate base.
3. 50% of the costs will be funded by Seller as an advance In aid of construon ("AIAC") subject
to refund. As refunds are made the refunded amounts wil be included in rae base usig
standard regulatory accounting principles.
Comoanv Costs (25%'5187,512.25
Non-rimbursable CIAC Costs (25%'S187.512.25
Reimbursabl AlAC Costs (50%'5375,024.50
EXHIBIT A
PAGE40F4
J~ne 1~ 201 i
Magi \V.Rd. LtC
AUn: Atn.ld Eckert
1i~D.!t 490 Nor
Bubl. III 8;316
Re:Ptjeri~13;) facihty Study Refund (Tw1n Fans Cluster Group)
Da Mr. i~tker:
_.4flf",'i-r~
The f:icilìy study hii the Twm FaU!' Chi.'tti: Grp his be' copleted. As. 1''Uh, we at
refuooiii~ llieSll.7(i..00 depos.iL i~s sttJ. ççst of $1,912.K3, plus inter 0($881.91. PII'-=
fi.nd endO$M. a check in the àmltmt of S4.680.08.
If I ~an hE) of my fuherasir$lånc.e. J'lea~ ('.aU (lOSt 388-5697
Siiierel y.
AubroeN. Sloan
Ct;: Rß"'~ Bi!ìaop. I PC'.
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EXHBITB .
PAGE10F2
~1I
a POR.
An lo;OR Campy
PAYM AlUN CURl
4,680.08 USDI DATE
06/01/2011PYM COMM:
L." .
000105005483
INVOICE NO.
GCRll05311328
#135 TWIN FAL CLUSER
GROUP FSA RE
TOTAL FOR CHECK 0001392778 $4 ,680.08
PLEASE DETACH AND RETAIN BEFORE DEPOSITING CHECK
EXHIBITB
PAGE20F2