20140429T. White DI.pdf

l- i-: -,
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OE IDAHO POWER )
COMPANY' S APPLICATION FOR )
APPROVAL OF ITS CAPACITY ) CASE NO. IPC-E-13-21
DEFICIENCY TO BE UTILIZED IN )
THE COMPANY' S SAR METHODOLOGY. )
)
IDAHO POWER COMPANY
DIRECT TESTIMONY OF
TAMI WHITE
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0. Please state your name and business address.
A. My name is Tami White and my business address
is 7221 West Idaho Street, Boise, Idaho 83702.
O. By whom are you employed and in what capacity?
A. I am employed by Idaho Power Company ("Idaho
Power" or "Company") as the Senior Manager of Rate Design
in the Regulatory Affairs Department.
O.
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Idaho Power.
degree in Accounting from Cal-ifornia State University,
Stanislaus. I have attended various electric utility
courses, including "Electric Utility System Operationr " a
course offered through Professional- Training Systems, Inc.,
and "Overview of System Operations" presented by the
Western Electricity Coordinating CounciI.
Pl-ease describe your educational- background.
I earned a Bachelor of Business Administration
Please describe your work experience with
A.I began my emplolrment with Idaho Power in L999
as a Einancial- Analyst in the Company's Delivery Finance
Support area where I provided accounting and financial-
support services to the Delivery Business Unit. In 2005, I
was promoted to Finance Team Leader where I was responsible
for leading a group of Fj-nancial Analysts, Accountants, and
Accounting Specialists in providing accounting and
financial support services to the Operations Business Unit.
WHITE, DI 1
Idaho Power Company
1 I was responsible for all aspects of the monthJ-y accounting
2 closing process for the Operations Business Unit and for
3 the monthly billing and settlements processes for
4 transmission sal-es and purchases, wholesale energy
5 transactions, Public Utility Regulatory Pol-icies Act of
6 7978 (PURPA) transactions, large special contracts, and
'7 )oint use transactions. While working in Operations
8 Finance Support, I was involved in the development of the
9 Company's Federal Energy Regulatory Commisslon (*EERC")
10 Open Access Transmissj-on Tariff (*OATT") formula rate for
1-1 transmission services.
L2 In October of 20L0, after 11 years in finance, I
13 accepted a position as Manager of FERC and Regional Affairs
L4 in the Regulatory Affairs Department. In this position, I
15 was responsible for managing reguJ-atory activities, such as
76 the preparation and fil-ing of Idaho Power's OATT rates for
Ll transmission servj-ce, supervising participation and
18 settlement negotiations of Bonneville Power Administration
L9 rate cases, and creating analyses that form the basis for
20 Idaho Power's FERC regulatory strategy.
27 In January of 20L2, I was promoted to Senj-or Manager
22 of Rate Desj-gn. As Senior Manager of Rate Design, I
23 oversee the Company's rate design activities, such as
24 regulatory ratemaking and compliance filings, tariff
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WHITE, DI 2
Idaho Power Company
1 administration, and the development of various pricing
2 strategies and policies.
3 Q. What is the purpose of your testimony in this
4 proceeding?
5 A. The purpose of my testimony is to provj-de the
5 Idaho Publ-ic Utilities Commission ("Commission") with an
7 update regarding the actual enrollments in the Company's
8 three demand response ("DR") programs for the 2074 season.
9 Q. Were you involvedr oD behalf of Idaho Power,
10 in Case No. IPC-E-13-14 regarding the contj-nuation of the
11 DR programs?
12 A. Yes. I provided testimony in that proceeding
l-3 describing the public workshop process undertaken in the
L4 case and the agreement (*DR Settlement Agreement") that was
15 signed by ldaho Power, Commission Staff, the Idaho
76 Irrigation Pumpers Assocj-ation, Inc., the Idaho
L7 Conservation League, the Snake River Al-l-iance, EnerNOC,
18 Inc., and Mike Seaman, (collectively referred to as the
19 "signing Partj-es") that addressed and settl-ed certain
20 aspects of the operation of Idaho Power's demand response
2! programs. My testimony in that proceeding provi-ded an
22 overview of the public workshops and the issues discussed,
23 expressed Idaho Power's support for the DR Settlement
24 Agreement, and recommended that the Commission adopt the DR
25 Settl-ement Agreement without material change or condition,
WHITE, DI 3
Idaho Power Company
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which it did in Order No. 32923 on November 12, 20L3. I
have attached as Exhibit No. 1 to my testimony a copy of
the Commission-approved DR Settlement Agreement.
o.What prompted the public workshop proceedings
that ultimately led to the DR Settlement Agreement?
A.In December of 2072, Idaho Power filed a
request in Case No. IPC-E-I2-29 with the Commi-ssion for
authority to temporarily suspend two of its three demand
response programs (A/C Cool Credit and Irrigation Peak
Rewards). The request for suspension was prompted by the
l-ack of near-term, peak-hour deficits identified in the
peak load and resource bal-ance analysis prepared for the
20t.3 Integrated Resource Plan ("IRP") and Idaho Power's
desire to take prompt and prudent steps to avoid some of
the expenses associated with the programs in years where
the peak load and resource balance analysis does not show a
need. During the suspension, the Company was able to serve
l-oads with existing resources and work with stakehol-ders
through a collaborative workshop process to evaluate and
identify the best J-ong-term optimization for continuation
of these programs.
O. Could you summarize the DR Settlement
Agreement ?
A. Yes. The DR Settl-ement Agreement provides for
the continued operation of Idaho Power's demand response
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Idaho Power Company
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programs in a manner that is cost-effective and
operationally beneficial to the el-ectric system, and within
the parameters that the Company and Signing Parties agreed
upon. The DR Settl-ement Agreement requires the Company to
utilize existing DR resources and equipment and accept all
existing and some new DR participants. The DR Settlement
Agreement refers to "approximately 400 MW of potential
demand response capacity" and the exlstlng DR resources
provided 438 megawatts ("MW") of participation tn 20L2.
The DR Settlement Agreement discusses six high-IeveJ-
demand response concepts that are to guide Idaho Power in
the impJ-ementati-on of its DR programs. These high-1eveI
concepts are listed in Section 4. a of the DR Settlement
Agreement. The Signing Parties agreed on the value as set
forth in Section 6 of the DR Settlement Agreement.
Signing Parties also came to agreement on the design
of the DR programs as described in Section 7 for the A/C
Cool Credit program, Section 8 for the frrigation Peak
Rewards program, and Section 9 for the FlexPeak Management
program of the DR Settlement Agreement.
The DR Settlement Agreement allows the Company to
leverage the j-nvestment i-n existing DR infrastructure to
continue the operation of a cost-effective resource. The
DR Settl-ement Agreement aims to maintain participation in
the DR programs for a time in the future when they are
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truly needed while minimizing ongoing costs to Idaho
Power's customers. The additional program modifications
make the programs more flexible, re1iab1e, and useful
because of the ability to respond with shorter notice to
program participants. Ultimately, keeping the DR programs
viabl-e wiII help Idaho Power to provide its customers
rel-iabl-e servi-ce in times of extreme weather and water
conditions.
The DR Settlement Agreement will maintain existing
DR programs, equipment, and participation by providing an
opportunity for aII current program participants to
continue to participate if they choose. Through this
settlement, the Company wiII be able to utilize the
investment that Idaho Power's customers have made in the
existing equipment in the fie1d.
The DR Settl-ement Agreement provj-des DR programs
that are scalabl-e and f l-exible. As the need identif ied in
future IRPs changes, Idaho Power can more easily add DR
capacity, and will maintain a minimum capacity of DR on its
system.
The DR Settlement Agreement increases flexibility
for the Company's system by reducing the amount of advance
notification required for program participants and
i-mplementing a fixed and variable incentive design for two
of the three DR programs. The DR Settl-ement Agreement also
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provides for the inclusion of three dispatch events in the
fixed incentive structure that wil-l- ensure the programs are
used and ensure program participant engagement.
o.
envisi-oned?
Is the DR Settl-ement Agreement working as
A. Yes. The Company has current participation 1n
the programs that is meeting prior level-s and at reduced
costs to customers.
o.Has the Company enroll-ed any participants i-n
the DR programs for the 2074 season?
A. Yes. As of April 24, 20L4, fdaho Power has DR
program participants enrol-Ied to provide a maxj-mum load
reduction at generatj-on level of approximately 403 MW.
This includes 34 MW from the A/C CooI Credit program, 40 MW
from the Fl-exPeak Management program, and 329 MW from the
Irrigation Peak Rewards program.
The enrollment period for the Irrigati-on Peak
Rewards program began in March and the participants were
asked to respond by April 4, 20\4. Idaho Power has,
through April 24, 20L4, received the majority of the
enroll-ments from eligible participants and the Company does
not expect the enrollments to change significantly from the
329 MW.
The level of l-oad reduction provided by the A/C CooI
Credj-t and Irrigation Peak Rewards programs varies
wHrTE, Dr 7
Idaho Power Company
1 throughout the season, primarily based on weather. The
2 expected load reduction for this program is based on
3 analysis of meter data and compressor run-time data by a
4 third-party consultant tn 20L2. The enrollment in the A/C
5 CooI Credit program could increase based on the complete
6 replacement of the remaining radio-controlled cycling
7 switches, the number of customers that move into a house
8 with an existing load control switch that enroll, the
9 number of former participants that moved and wish to re-
10 enroll, and the number of customers that contact Idaho
11 Power wishing to enrol-l in the program, as stated in
72 Sectj-on 'l .a of the DR Settl-ement Agreement.
l-3 The Ioad reduction from the FlexPeak Management
L4 program (which is contingent upon Commissj-on approval of
15 the extension of the contract with EnerNOC, Tnc., Case No.
16 IPC-E-14-02) is expected to be stable throughout the
L7 program season based on the past performance of EnerNOC,
18 Inc. EnerNOC, Inc., has a good performance record for the
19 past five years and has a financial- incentive to contj-nue
20 providing the 40 MW of load reduction agreed upon.
2L O. Does this conclude your testimony?
22 A. Yes, it does.
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WHITE, DI 8
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STATE OF
County of
IDAHO )
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Ada )
ATTESTATTON OF TESIIMONY
SS.
Tt Tami White, having been duly sworn to testify
truthfully, and based upon my personal knowledge, state the
following:
I am employed by Idaho Power Company as a Senior
Manager in the Regulatory Affairs Department and am
competent to be a witness in this proceeding.
I declare under penalty of perjury of the l-aws of
the state of fdaho that the foregoing pre-filed testimony
and exhibit are true and correct to the best of my
information and belief .
DATED this 29th day of April 2074.
\ami [^lirit"
SUBSCRIBED AND SWORN to before me this 29th day of
April 201-4.
$ff
WHITE, DI 9
Idaho Power Company
,ffirrO?lt*
(Da(Dlollre
Notary PubI
Residing at:
My commission expire
BEFORE THE
IDAHO PUBLIG UTILITIES COMMISSION
CASE NO. IPG.E.13.21
IDAHO POWER COMPANY
WHITE, DI
TESTIMONY
EXHIBIT NO. 1
DEMAND RESPONSE PROGRAMS
SETTLEMENT AGREEMENT
This setflement agreement ("Settlement Agreemen{' ot " Agreement") is entered into by
and among the following participants to the demand response workshops: Idaho Power
Company ("Idaho Power" or "Company"), the Staff of the Idaho Public Utilities Commission
("Staff"), the Idaho Irrigation Pumpers Association, Inc. ("IIPA"), the Idaho Conservation
League ("lCL"), the Snake River Alliance ("SRA"), EnerNOC, Inc. ("EnerNOC"), and Mike
Seaman. These entities and individuals are collectively referred to as the "Parties," and
individually as a "Party," to the Agreement.
WHEREAS, whery in late 2012, the Load and Resource Balance Analysis performed
during the development of tdaho Power's 2013lntegrated Resource Plan showed no peak-hour
capacity deficit until 2016, Idaho Power filed for changes to its A/C Cool Credit program,
Irrigation Peak Rewards program, and FlexPeak Management program (collectively "DR
Programs") in Docket Nos.IPC-E-L2-29 and IPC-E-13-04;
WHEREAT following the temporary suspension of the A/C Cool Credit program and
Irrigation Peak Rewards program in 2013 and contract changes for the FlexPeak Management
program, the Parties attended a series of five workshops ("DR Workshops") for all interested
parties and stakeholders to discuss how the Cornpany includes demand response ('DR") in its
Integrated Resource Plan ("[RP"), how it calculates cost-effectiveness of D& the purpose of D&
Idaho Power's DR Programs and design, and settlement options for Idaho Power's DR
Programs n 201 4 and beyond;
SETTLEMENT ACREEMENT
Page 1 of 11 Exhibit No. 1
Case No. IPC-E-13-21
T. White, IPC
Page 1 of 17
WHEREAS, these DR Workshops occurred in Case No. IPC-E-1T14, were noticed in
Docket UM 1553, and were attended by parties to both dockets, as well as members of the
public and other stakeholders;
WHEREAS, UM 1653 followed the workshop process in Case No. IPC-E-13-14 in an
effort to allow all interested Idaho and Oregon parties and stakeholders to collectively provide
input and agree upon Idaho Power's DR Program details; and
WHEREAS, throughout the course of the DR Workshops, the Parties reached agreement
on certain aspects of Idaho Power's DR Programs.
NOW THEREFORE, in consideration of the mutual promises set forth herein, the
sufficiency of which is hereby acknowledged, the Parties agree as follows:
1. Recitals. The above-stated recitals are incorporated and made a part of this
agreement to the same extent as if the recitals were set forth in full at this point.
2. Public Interest. This Agreement is a fatr, just and reasonable compromise of
contested issues and its acceptance by the Idaho Public Utilities Commission ("IPIJC" or
"Commission") would be in the public interest. The Agreement and its acceptance by the
Cornmission will reasonably resolve the issues related to tdaho Power's DR Programs.
Therefore, the Parties recommend that the Commission approve the Agreement and all of its
terms and conditions without material change or condition pursuant to IPUC RP 274.
3. Tenn. This Agreement shall be in effect beginning on the date it is approved by
the Commission and shall apply to [daho Powet's DR Programs for 2014 and beyond until a
change occurs in Idaho Power's system operations or cost-effectiveness of a DR Program that
would warrant reevaluation of the Agreement's terms. hr such event, Idaho Power will consult
SETTLEMENT AGREEMENT
Page2 of 11 Exhibit No. 1
Case No. IPC-E-13-21
T. White, IPC
Page2 of 17
its Energy Efficiency Advisory Group ("EEAG") and then make an appropriate filing at the
Cornmission. Similarly, a party to this Agreement may petition the Commission to open a
docket to reevaluate the terms of this Agreement if Idaho Power experiences a change in system
operations or the cost-effectiveness of a DR Program so warrants.
4, Concepts. The Parties and workshop participants agreed that the following
overarching demand response concepts should guide Idaho Power's implementation of its DR
Programs:
The Company must:
i. Use existing demand response resources when possible. This
includes using, to the extent possible, current demand response equipment owned or available
to Idaho Power and participating demand response customers, which currently represents
approximately a00 megawatts ("MW") of potential demand response capacity.
ii. Include demand response offerings for all three customer classes
(residentiaf commercial/indushial, and irrigation).
iii. Keep costs as low as possible.
iv. Reevaluate the value calculation as the IRP changes.
v. Take a long-term outlook. [n order to have viable demand
response programs in the long term, the programs must continue in the short term.
vi. Calculate the avoided cost used for demand response by using the
avoided capacity cost of a 170 MW single cycle combustion turbine ("SCCT") multiplied by the
effective load carrying capacity ("ELCC"), measured over 20 years, plus the corresponding
deferred energy savings for 60 program hours.
SETTLEMENT AGREEMENT
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Case No. IPC-E-13-21
T. Write,IPC
Page 3 of 17
vu.Strive for consistency in dispatch requirements across DR
Programs.
b. Uses for demand response beyond reducing peak loads may be: load
following, non-spinning operating reserves, improved reliability during emergency situations,
and flexibility to address delays in building new supply-side peaking resources. The workshop
participants broke into small groups and discussed the possibilities of load following and
reserves. Based upon these workgroup findings, Idaho Power will investigate the feasibility of
using demand response as operating reserves and make a determination on feasibility by the
end of the 3.d quarter o1201,4. If Idaho Power determines that a pilot is feasible, it will create a
proposal and work with Staff and other interested stakeholders to develop a pilot program.
c. This Agreement applies only to Idaho Power's Demand Response
Programs, and the concepts are not applicable to any of the Company's other DSM Programs.
5. Resource Size. The minimum size of the deferred resource used for the value
calculation is 170 MW. It is appropriate for Idaho Power to incur and recover costs based on
deferring this resource.
6. Value. The annual value of demand response is equal to the levelized annual
cost of the minimum size deferred resource, measured over a period of 20 years, plus the
corresponding deferred energy savings for 50 program hours. As of the date of this Agreement
the calculation leads to an annual value of $1,6.7 million dollars for the entire DR Program
portfolio. The demand response value calculation shall include this value even in years when
the IRP shows no peak-hour capacity deficit. The annual value calculation will be updated with
SETTLEMENT AGREEMENT
Page 4 of 11 Exhibit No. 1
Case No. IPC-E-13-21
T. White,IPC
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each IRP based on changes that include, but are not limited to need, capital cost or financial
assumptions.
7. A/C Cool Credit Program. Idaho Power will implement the A/C Cool Credit
program in a marrner consistent with the tariff Schedule 81. A true and correct copy of the tariff
is attached to this Agreement as Attachment 1 and is incorporated herein as if set forth in fuIl at
this point.
a. Participants. Participants are residential customers who are presently
enrolled in the program and have a load control device installed. AII paging devices installed at
current participants' residences will be replaced with AMl-compatible devices, with the goal of
completing replacement in time for the 2074 program season. Idaho Power will not actively
promote the A/C Cool Credit program to solicit new participants through marketing tactics, but
will accept new participants in this program who request to participate, regardless of whether
they were previously participants in the program. In order to use existing equipment Idaho
Power will contact and attempt to recruit customers who move into a home that already has a
load control device installed. If a customer enrolls in the A/C Cool Credit program at a
residence that has a paging device, the load control device will be replaced with an AMI-
compatible device. Idaho Power will also attempt to recruit participants who change residences
to a location that does not have a load control device. An A/C Coo[ Credit program load control
device will remain in place unless a customer requests the load control device be removed.
b. Program Details. The A/C Cool Credit program will be available from
June L5 through August 15, Monday through Friday, excluding holidays. Each dispatch event
will last no longer than four hours for each participant. Dispatch events will not occur more
SETTLEMENT AGREEMENT
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Case No. IPC-E-13-21
T. White, IPC
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than 15 hours per week or 60 hours per season. In the event of a system emergency, demand
response capacity from the A/C Cool Credit program will be available for immediate dispatch.
Idaho Power will conduct a minimum of three dispatch events per season. No advanced notice
to participants is required prior to executing each dispatch event. Participants, with advance
notice, may opt out of two events per season.
c. Incentive. Participants will receive a fixed incentive of $15 for the seasor;
which will be issued as a credit on one or more of the participant's monthly bills for the
program months.
d. Program Size. If participation in the A/C Cool Credit Program changeg
Parties to this Agreement may file an application to modify the program as set forth in Section
3.
8. Irrigation Peak Rewards Program. Idaho Power will implement the Irrigation
Peak Rewards program in a manner consistent with the tariff Schedule 23. A true and correct
copy of the tariff is attached to this Agreement as Attachment 2 and is incorporated herein as if
set forth in full at this point.
a. Participants. Participation is limited to past lrrigation Peak Rewards
service locations where an active, working load control device exists as described in more detail
in Attachment 2. The Company will not actively market the lrrigation Peak Rewards program
as described in more detail in Attachment 2.
b. Program Details. The Irrigation Peak Rewards program will be available
from June 15 through August 15, Monday through Saturday, from 1:00 p.m.-9:00 p.m.,
excluding holidays. Each dispatch event will last no longer than four hours for each
SETTLEMENT AGREEMENT
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Case No. IPC-E-13-21
T. White,lPC
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participant. Dispatch events will not occur more than fifteen (15) hours per week or sixty (60)
hours per season. In the event of a system emergency, demand response capacity from the
Irrigation Peak Rewards progtam will be available for immediate dispatch. Idaho Power will
conduct a minimum of three dispatch events per season. Participants with Interruption Option
3 will be given at least four hours advanced notification. There will be no notification required
for participants with hrtemrption Options 1 and 2. Participants may opt out of an event. An
opt-out fee of $5.00 per kilowatt ("kW") per event will apply for the first three events and $1.00
per kW per event for subsequent events. The opt-out fee will not exceed the total bill credit for
the program season.
c. Incentive. Participants will receive a fixed incentive in the form of a
demand and energy component which is approximately $16 per kW per seasory as set forth in
more detail in Attachment 2. The fixed incentive shall include the above-mentioned three
minimum dispatch events. If Idaho Power conducts dispatch events in the Irrigation Peak
Rewards program in addition to the three minimum dispatch events, Participants will receive a
variable incentive of S0.148 (or $0.198 for the 9:00 p.m. option) per kl,Vh as set forth in more
detail in Attachment 2, which, with the realization rate included, results in a cost to Idaho
Power of approximately $0.22 per kWh.
9. FlexPeak Management Program. Idaho Power will implement the Flex Peak
Management program using the following design parameters.
a. Participants. Idaho Power will not actively seek to expand the capacity of
the FlexPeak Program. Participants are industrial and large commercial customers.
SETTLEMENT AGREEMENT
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Case No. IPC-E-13-21
T. White, IPC
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b. Program Details. The FlexPeak Management program will be available
from ]une 15 through August 15, Monday through Friday, from 2:00 p.m.-8:00 p.m., excluding
holidays. Each dispatch event will last up to four hours per participant within the available
program hours. Dispatch events will not occur more than 50 hours per season. In the event of a
system emergency, demand response capacity from the FlexPeak Management program will be
available. Idaho Power will conduct a minimum of three dispatch events per season. There will
be two hours advanced notice to participants.
brcentive. A fixed and variable incentive structure may be appropriate,
as long as the variable portion is low enough that it does not prevent the program from being
dispatched. If a variable and fixed incentive structure is used, a minimum of three dispatch
events will be included in the fixed incentive. The variable incentive will be paid to participants
if Idaho Power conducts dispatch events in the FlexPeak Management program for more than
the three minimum dispatch events.
10. Confidentiality. As provided in RP 272, other than any testimony filed in
support of the approval of this Agreement and except to the extent necessary for a Party to
explain before the IPUC its own statements and positions with respect to the Agreemenf all
statements made and positions taken in negotiations relating to this Agreement shall be
confidential and will not be admissible as evidence in this or any other proceeding.
LL. Commission Procedute. The obligations of the Parties under this Agreement are
subject to the Commission's approval of this Agreement in accordance with its terms and
conditions and upon such approval being upheld on appeal by a court of competent
jurisdiction. The Parties will submit this Settlement Agreement to the Commission and
SETTLEMENT AGREEMENT
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Case No. IPC-E-13-21
T. White, IPC
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recorunend approval in its entirety pursuant to RP 274. Parnes shall support this Agreement
before the CommissiorL and no Party shall appeal a Commission order approving the
Agreement or an issue resolved by the Agreement. If this Agreement is challenged by any
person not a party to the Agreement the Parties to this Agreement reserve the right to file
testimony, cross-examine witnesses, and put on such case as they deem appropriate to respond
fully to the issues presented, including the right to raise issues that are incorporated in the
settlements embodied in this Agreement. Notwithstanding this reservation of rights, the Parties
to this Agreement agree that they will continue to support the adoption of the terms of this
Agreement.
If the Commission reiects any part or all of this Agreement, or imposes any additional
material conditions on approval of this Agreement, each Party reserves the righq upon written
notice to the Commission and the other Parties to this proceeding, within 14 days of the date of
such action by the Commission, to withdraw from this Agreement. In such case, no Party shall
be bound or prejudiced by the terms of this Agreement and each Party shall be entitled to seek
reconsideration of an IPUC Order, file testimony as it chooses, cross-exarnine witresset and do
all other things necessary to put on such case as it deems appropriate.
No Party shall be deemed to have agreed that any method, theory, or principle of
regulation or cost recovery employed in arriving at this Agreement is appropriate for resolving
any issues i. *y other proceeding in the future.
12. Entire Ageement. This Agreement and its attachments constitute ttre entire
agreement between the Parties regarding the subject matter hereof. There are no oral or wriften
SETTLEMENT ACREEMENT
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Case No. IPC-E-13-21
T. White, IPC
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understandings, representations, or commibnents of any kind, express or implied, which are
not expressly described in this Agreement.
13. Severability. If, after Cornmission approval of this entire Agreement without
modification, any immaterial term or provision of this agreement that is found to be void,
prohibited, or unenforceable by local, state, or federal law shall be ineffective only to the extent
of such prohibition or unenforceability without invalidating the remaining provisions of this
Agreement. Upon a determination that any material term or provision is void, prohibited, or
unenforceable by local, state, or federal law, the Parties shall negotiate in good faith to modify
this Agreement to maintain the original intent of the Parties without such material provision.
'1,4. No Third-Party Beneficiaries. No right or obligation contained in this
Agreement shall inure to the benefit of any person or entity not a Party or successor or assign of
a Party.
15. Counterparts. This Agreement may be executed in counterparts and each signed
counterpart shall constifute an original document.
[signature page follows]
SETTLEMENT AGREEMENT
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Case No. IPC-E-13-21
T. White,lPC
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DATED this
-day
of September2013.
ldaho Power Company ldaho Public
Staff
Utilities Commission
By
Customer Relations & Energy Efficiency
Manager
Karl Klein
Deputy Attorney General
ldaho lrrigation Pumpers Association, ldaho Conservation League
lnc.
By By.
Sid Erwin
Vice President of llPA
Ken Miller
Clean Energy Program Director
Benjamin J. Ofto
Attorney for ldaho Conservation
League
EnerNOC, lnc.
By
Melanie Gillette
Director, Regulatory Affairs
Snake River Alliance
By
By
Mike Seaman
ldaho Power Customer
SETTLEMENT AGREEMENT
Page 11 of 11 Exhibit No. 1
Case No. IPC-E-13-21
T. \flhite, IPC
Page 11 of '17
DATED tfris 2f,ay of Septerrrber 2013.
ldaho Power Company
By
Theresa Drake
Customer Relations & Energy Efficiency
Manager
ldaho lrrlgation Pumpers Association,
lnc.
ldaho Public Utilities Commission
Staff
ldaho Conservation League
By
Sid Erwin
Vice President of llPA
Snake River Alliance
By
Benjamin J. Otto
Attorney for ldaho Conservation
League
EnerNOC, lnc.
Melanie Gillette
Director, Regulatory Affairs
By By
Ken Miller
Clean Energy Program Director
By
Mike Seaman
ldaho Power Customer
SE'TTLEMENT AGREEMENT
Page L1 of 1,1
Exhibit No. 1
Case No. IPC-E-13-21
T. White, IPC
Page 12 ol 17
Deputy Attorney General
Oct O? 13 O4:4Oa
DATED this
-day
of September 2013.
ldaho Power Gompany
By
Theresa Drake
Customer Relations & Energy Efiiciency
Manager
ldaho lrrigation Pumpers Association,
!nc.
p.1
Public lJtilities Gommissionldaho
Staff
Bn
Karl Klein
DeputyAttomey General
ldaho Gonseruation League
Snake Rlver Alllanee
Ken Miller
Clean Energy Program Director
By.
Benjamin J. Otto
Attorney for ldaho Conservation
League
EnerNOC,lnc.
Melanie Gillette
Director, Regulatory Affairs
By By
By.
Mike Seaman
ldaho Power Customer
SETTLEMENT AGREEMENT
Page 11 of 11 Exhibit No. 1
Case No. IPC-E-13-21
T. \A/hite, IPC
Page 13 of 17
Vice President of llPA
DArED ,*CArof September 2013.
ldaho Power Gompany
Theresa Drake
Customer Relations & Energy Efficiency
Manager
ldaho Public Utilities Commission
Staff
By
Karl Klein
Deputy Attorney General
ldaho lrrigation Pumpers Association, ldaho Conservation League
lnc.
By
Ken Miller
Clean Energy Program Director
--?
By {1 ', k-
Benjamin J. Otto
Attorney for ldaho Conservation
League
EnerNOG, lnc.
Melanie Gillette
D irector, Regulatory Affa irs
Sid Erwin
Vice President of IIPA
Snake River Alliance
By-By
By
Mike Seaman
ldaho Power Customer
SETTLEMENT AGREEMENT
Page 11 oI 11
Exhibit No. 1
Case No. IPC-E-I3-21
T. White, IPC
Page 14 of 17
.By-.
-.-.--.---pATED this
-day
of September 2013.
lslaho-P_oWer- C_g-npa rty
Theresa Drake
Customer Relations & Enerqf-fflsiglsy
Nl-e-raser
tda.ho lri&tiqrr PUODSE_A.qWieUgrt
lnc.
F.y-
Sid ErWiN
Vice President of llPA
Snake River Alli?nqe. '
Clean Enqrgy f.t'egLam Director
Mike Seaman
ldaho Power Customel
ldaho_ Public U0ities Com.nniSi$qn
Staff
Elu
lGrJ(lelp
Aepgg 3tg&ey-Cerere]
!-4ahe-c-src9lteliso-Leellqe
Bv
Benlamjn J, otto
Attornev for ldaho Conservalion
Lp_agqe
EnerNOC. lnc.
Fv .-
Melanie Gillette
trtre cte1.Beg uE& f y_}ff a i r s
SBTTLEMENT AGREEMENT
Page 11 of 11
Exhibit No. 1
Case No. IPC-E-13-2'1
T. White, IPC
Page 15 of 17
DATED this
-day
of September 2013.
ldaho Power Gompany ldaho Public Utilities Commission
Stetr
By,By
Theresa Drake Karl Klein
Customer Relations & Energy Efficiency Deputy Attomey General
Manager
ldaho lrrigaUon Pumperc Association, ldaho Conservation League
lnc.
Sid Erwin Benjamin J. Otto
Vice President of llPA Attorney for ldaho Conservation
League
Snake River Alliance EnerNOC, lnc.
By.By
By,avfnrao,^r, #l,r++"-Melafiie Gillette
D irector, Regulatory Affairs
Ken Miller
Clean Energy Program Director
By
Mike Seaman
ldaho Power Customer
SETTLEMENT AGREEMENT
Page 11 of 11
Exhibit No. 1
Case No. IPC-E-13-21
T. Write, IPC
Page 16 of 17
By By
Theresa Drake Kad Klein
Customer Relations & Energy Efficiency Deputy Attorney General
Manager
ldaho lrrigation Pumpers Association, Idaho Conservation League
lnc.
ByBy
DATED this
-day
of September 2013.
ldaho Power Company
Sid Erwin
Vice President of !lPA
Snake River Alliance
By
Ken Miller
Clean Energy Program Director
By /sl Mike seaman
Mike Seaman
Idaho Power Customer
ldaho Public Utllltles Commission
Staff
Benjamin J. Otto
Attorney for ldaho Conservation
League
EnerNOG, lnc.
By.
Melanie Gillette
Director, Regulatory Affairs
SETTLEMENT AGREEMENT
Page 11 of 11 Exhibit No. 1
Case No. IPC-E-13-21
T. White, IPC
Page 17 ot 17
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 29fr day of April 2014 I served a true and conect
copy of the DIRECT TESTIMONY OF TAM! WHITE upon the following named parties
by the method indicated below, and addressed to the following:
Commission Staff
Kristine A. Sasser
Deputy Attomey Genera!
ldaho Public Utilities Commission
472 West Washington (83702)
P.O. Box 83720
Boise, ldaho 83720-007 4
J. R. Simplot Company
Peter J. Richardson
Gregory M. Adams
RICHARDSON ADAMS, PLLC
515 North 27th Street
Boise, ldaho 83702
Dr. Don Reading
6070 Hill Road
Boise, ldaho 83703
ldaho lrrigation Pumpers Association
Eric L. Olsen
MCINE, OLSON, NYE, BUDGE, &
BAILEY, CHARTERED
201 East Center
P.O. Box 1391
Pocatello, ldaho 83204-1 391
Hand Delivered
U.S. Mail
Overnight Mai!
FAX
Email kris.sasser@puc. idaho.sov
Hand Delivered
U.S. Mail
Overnight Mai!
FAXX Email [e-mail]
[e-mail]
_Hand Delivered
_U.S. Mail
Overnight Mail
FAXX Email [e-mail]
_Hand Delivered
_U.S. Mail
Overnight Mail
FAX
Email [e-mail]
CERTIFICATE OF SERVICE