20140904Supplementary Comments.pdf

KRISTINE A. SASSER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-03s7
BAR NO. 661 8
Street Address for Express Mail:
472W, WASHINGTON
BOISE, IDAHO 83702.5918
Attomey for the Commission Staff
IN THE MATTER OF'IDAHO POWER
COMPANY'S APPLICATION TO UPDATE ITS
WIND INTEGRATION RATES AND CHARGES.
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC.E-I3-22
SUPPLEMENTARY COMMENTS
OF THE COMMISSION STAFF
COMES NOW the Staff of the Idaho Public Utilities Commission, by and through its
Attorney of record, Kristine A. Sasser, Deputy Attorney General, and in response to the Notice of
Amended Schedule issued in Order No. 33075 on July 15,2014, in Case No. IPC-E-13-22,
submits the following supplementary comments.
BACKGROUND
On November 29,20l3,Idaho Power Company ("Idaho Power" or"Company") filed an
Application with the Commission seeking to update its wind integration rates and charges. The
Company's Application includes a2013 Wind Integration Study Report as well as the supporting
testimony of Philip DeVol and Michael J. Youngblood.
In its Application, Idaho Power requested that the Commission approve the updated wind
integration costs as identified in its 2013 Wind Study and set forth in the proposed Schedule 87.
Idaho Power proposed two overall changes to address the collection of wind integration costs.
The first change abandons the use of a percentage of avoided cost rate allocation and instead
STAFF SUPPLEMENTARY COMMENTS SEPTEMBER 4,2014
allocates a fixed amount based upon penetration level. The second change decouples the wind
integration charge from the avoided cost rate contained in the power sales agreement and instead
has wind integration costs assessed as a standalone tariff charge. These changes were
incorporated in three proposed methods for implementing integration charges. The first method
retained the existing structure of wind integration charges consisting of three different tiers of
charges for three different wind penetration levels, but simply updated the current charges
consistent with the results of the 2013 Wind Study. Under the second method, the Company
proposed adoption of a wind integration tariff that would specify integration charges at 100 MW
increments of wind penetration. The third method also involved a tariff-based approach, but
proposed that all wind generators, new and existing, would share equitably in the costs of
integrating wind onto the Company's system.
Motions to Dismiss were filed by twelve intervenors on January 31,2014. The intervenors
claimed that ldaho Power's Application illegally requests "that the Commission modifu the rates
and terms in existing contractual legally enforceable obligations for qualifying facilities (QFs)
without the consent of the QFs." The Petitioners asserted that unilateral modification of existing
contracts is a violation of PURPA and "the administrative process of entertaining Idaho Power's
Application" is preempted by federal law. In Order No. 33030, the Commission denied the
Motion to Dismiss, but did order that the outcome of the underlying proceeding only be applied
prospectively-to new contracts as they are entered into by the parties and submitted to the
Commission for approval.
On July 2,2014, comments on Idaho Power's Application were submitted by the
Commission Staff ("Staff') and the American Wind Energy Association/Renewable Northwest
("AWEA/RNW"). Idaho Power filed Reply Comments on July 22,2014 for three primary
purposes: 1) to correct statements from the Company's initial Application;2)to present Idaho
Power's revised recommendation to implement wind integration charges on an hourly incremental
cost basis for every 100 megawatts ("MW") of penetration through an intermittent generation
integration charge tariff, consistent with Order No. 33030 which restricted application of new
integration charges to new contracts only; and 3) to respond to comments of the Commission Staff
and AWEA/RNW. A Notice of Amended Schedule was issued on July 15,2014 to accommodate
additional discovery, and to establish supplementary comment and reply deadlines. See Order No.
33075.
STAFF SUPPLEMENTARY COMMENTS SEPTEMBER 4,2014
STAFF ANALYSIS
In its Reply Comments, Idaho Power agreed with the following Staff recommendations: l)
to accept the results of the Company's 2013 Wind Integration Study; 2) to recover the full
incremental cost of integration from new wind projects; and 3) to implement integration charges as
a dollar per megawatt-hour ("MWh") charge rather than as a percentage of avoided cost rates.
Idaho Power proposes further that a wind integration charge be implemented to recover the full
incremental cost of integration at 100 MW increments, and that those charges be set forth in
Schedule 87 for intermittent generation integration charges.
Correction to Tier Levels and Costs in the Application
Idaho Power noted in its Reply Comments that Staffs recommendation with regard to the
three tiers that were set forth in Idaho Power's Application as "Method I " is based upon an
incorrect breakout of the tier levels that Idaho Power erroneously reported in its Application. The
Company's testimony correctly set forth the tier and cost information; however, it was summarized
erroneously in the Application. In addition, Idaho Power clarified that the 2013 Wind Integration
Study utilized a2017 test year, and reports all numbers in 2017 dollars. To correct the errors and
clarify the costs, Idaho Power provided the following tables, meant as replacement tables for those
that appear on pages 5 and 6 of the Application:
Average Integration Cost Per MWh
Build-out Scenarios 0-800 Mw 0-1,000 Mw 0-1,200 Mw
Integration Cost
(2017 dollars)$6.83 $10.22 $r4.22
Integration Cost
(2014 dollars)$6.2s $9.3s $ 13.01
Incremental Integration Cost per MWh
Penetration Level 678 - 800 MW 801 - 1,000 Mw 1,001 - 1,200 Mw
Integration Cost
(2017 dollars)$8.67 $24.00 $34.70
Integration Cost
(2014 dollars)$7.93 $21.96 $31.76
STAFF SUPPLEMENTARY COMMENTS 3 SEPTEMBER 4,2014
Staff acknowledges the corrections and clarifications provided by Idaho Power in its Reply
Comments. As it did in its initial Comments, Staff continues to support the integration costs as
determined by Idaho Power in its 2013 Wind Study for each of the respective penetration levels
considered. Moreover, as discussed in more detail below, Staff continues to support the
Company's proposal to assess integration charges to new projects on an incremental basis.
Proposed Intermittent Generation Integration Charge Tariff
Because Idaho Power's initial Application contained multiple options/proposals for the
implementation of updated wind integration costs, the Company's proposal to implement an
intermittent generation integration charge tariff as presented in its Reply Comments is now
somewhat different, given the Commission's determination in Order No. 33075 that integration
charges in existing contracts will not be changed. Idaho Power proposes a new tarifl Schedule
87, Intermittent Generation Integration Charges. This is the same Schedule 87 and proposal that
the Company recently submitted for the implementation of solar integration costs in Case No.
IPC-E-14-18. The tariff does not provide for modifuing or changing the integration cost that is
contained in a Commission-approved contract. The tariff, and any change to the integration
charge in the future, would only apply to new contracts and obligations entered into subsequent to
its approval by the Commission.
Idaho Power states that Schedule 87 is meant to provide the wind and solar integration
charges consistent with the most recent Commission-approved integration study applicable to both
wind and solar generation, respectively. The Company provided a draft of Schedule 87, submitted
as Attachment I to its Application that contains only the proposed incremental integration charges
for wind generation based upon the 2013 Study. It also contains a placeholder for the inclusion of
the appropriate solar integration charges, once they are determined by the Commission. (The
Company submitted the same draft Schedule 87 as Exhibit No. 2 in Case No. IPC-E-14-18 that
contains the proposed incremental integration charges for solar generation, and a placeholder for
the inclusion of an appropriate wind integration charge).
As proposed by Idaho Power, the charges set forth in Schedule 87 are the amounts to be
deducted from avoided cost rates each year, beginning in the year the project comes on-line, based
on the nameplate capacity of installed wind generation at the scheduled operation date of the
proposed new project. The integration charges set forth in Schedule 87, the Company states, are
formatted to appear in the same format as that used by the Commission to post the published
STAFF SUPPLEMENTARY COMMENTS SEPTEMBER 4, 2014
avoided cost rates. Each penetration level (for each 100 MW increment of wind penetration) has
its own table clearly identified and set forth in Schedule 87, and discloses both the levelized
integration charge as well as the non-levelized stream of integration charge amounts listed by year.
Just like published avoided cost rates, the scheduled operation date for the proposed generation
project is used as the starting point in the table, and each yearly amount through the term of the
proposed contract is set out accordingly. Idaho Power proposes that these amounts would be
included in the PURPA energy sales agreement for a new project, and would remain as set forth in
that agreement for the entire term of the agreement.
Staff reviewed the calculations performed by Idaho Power to translate the incremental
wind integration charges from the 2013 Wind Study into the proposed Schedule 87 tariff. In its
computations, the Company assumed a three percent inflation rate to convert real into nominal
charges, and applied a discount rate of 6.7 percent to levelize the charges. In response to Staff
production requests, Idaho Power states that both of these rates were chosen because they were the
percentage rates used in the 2013 Integrated Resource Plan. Staff believes that use of a three
percent inflation rate is reasonable. However, Staff would prefer that the Company use a discount
rate consistent with that used for levelizing avoided cost rates computed in the Surrogate Avoided
Resource (SAR) methodology. That rate is equal to the utility's weighted cost of capital from its
most recent general rate case, unadjusted for tax effects. Currently for Idaho Power, that rate is
8.18 percent, established in 2009 in Case No. IPC-E-08-10, the last general rate case in which cost
of capital was explicitly specified. Use of an 8.18 percent discount rate and a three percent
inflation rate produces the wind integration charges shown on Attachment 1. These rates are
comparable to, but slightly lower than those proposed by Idaho Power in its Schedule 87.
Idaho Power's Recommended Implementation of Wind Integration Charges
In its Reply Comments, Idaho Power also clarified how its proposed intermittent
generation integration charge tariff would be structured and how it would work. The Company
explained that the 2013 Study identified wind integration costs at 800 MW, 1,000 MW, and 1,200
MW. The incremental integration costs at 100 MW increments were then determined by first
fitting a smooth curve to each of the studied penetration level costs identified in the 2013 Study,
then using the respective curye's formula to identi$ the associated costs at each 100 MW
penetration level. Idaho Power's proposal to implement wind integration costs at 100 MW
increments is the same as its proposal to implement solar integration costs at 100 MW increments.
STAFF SUPPLEMENTARY COMMENTS SEPTEMBER 4,2014
Idaho Power explained that the 2013 Wind Integration Study identified an average
integration cost for all wind generation from 0-1,200 MW of $14.22. That means that if the total
cost of integrating 1,200 MW of wind were to be spread equally to all 1,200 MW of wind
generation, the cost of integration would be $14.22 for each MWh generated. However, if that
same cost of integrating 1 ,200 MW of wind were to be broken up into increments, the incremental
integration cost for the first increments would be much lower, while the cost for the later
increments increases. In aggregate, the total cost of integrating wind indentified by either method,
the average integration cost or the incremental integration cost, is the same. The cost of wind
integration increases as the penetration level of wind increases on the system. The 2013 Study
identified the discrete cost to integrate wind generation at three discrete penetration levels.
However, the Company explained that if costs are assigned on an incremental basis, then costs are
more closely assigned with the cause of those costs, and thus the initial generation is assigned a
lower cost than generation that comes on line later when it is more costly to integrate.
Idaho Power proposed that a wind integration charge be established to collect the
incremental cost of integration at each 100 MW level of wind generation penetration. Because
Idaho Power currently has 678 MWI of wind currently operating on its system, the updated wind
integration charge starts at the 678 MW to 700 MW penetration level, and increases consistently
with the costs of integration identified in the 2013 Study, at every 100 MW of wind nameplate
capacity penetration level. This results in proposed wind integration charges, in2017 dollars, of:
$13.10 for 678 MW to 700 MW; $17.00 for 701 MW to 800 MW; $21.35 for 801 MW to 900
MW; $20.16 for 901 MW to 1,000 MW; $:1.41 for 1,001 to 1,100 MW; and $37.08 for 1,101
MW to 1,200 MW.
Staff appreciates the much clearer explanation in Idaho Power's Reply Comments of how
it proposes to apply wind integration charges identified in its 2013 Wind Integration Study. Staff
supports the tariff-based approach proposed by Idaho Power in its Reply Comments. Staff also
supports application of incremental wind integration charges such that integration charges increase
as wind penetration level increases, and that once set forth in an agreement, they remain
unchanged for the entire term of the agreement.
' Witt the recent inclusion of 50 MW of wind generation from five fully executed PURPA energy sales agreements in
its Oregon jurisdiction, Idaho Power's total current wind generation penetration level is 728 MW.
STAFF SUPPLEMENTARY COMMENTS 6 SEPTEMBER 4,2014
RECOMMENDATIONS
Staff continues to support the following recommendations from its initial July 22,2014
comments: 1) to accept the results of the Company's 2013 Wind Integration Study; 2) to recover
the full incremental cost of integration from new wind projects; and 3) to implement integration
charges as a dollar per megawatt-hour ("MWh") charge rather than as a percentage of avoided cost
rates. Staff further recommends that wind integration costs from the 2013 Study be applied using
a tariff-based approach in which integration costs are assessed as either levelized or non-levelized
charges applied as a discount to avoided cost rates. Staff supports the introduction of Schedule 87
as proposed by Idaho Power, with the exception of the discount rate. Idaho Power applied a
discount rate of 6.7 percent to levelize integration charges because it was used in the 2013
Integrated Resource Plan. However, Staff believes that Idaho Power should apply the discount
rate used for levelization of published avoided cost rates computed under the SAR methodology,
which is currently 8.18 percent. The resulting wind integration charges supported by Staff are
shown on Attachment 1.
Staff also recommends that Idaho Power be expected to periodically conduct new wind
integration studies as electric markets, technologies, and operating practices evolve, and to update
its wind integration charges accordingly as they are contained in any approved tariffs such as
Schedule 87.
Respecttully submitted this 4Y day of September 2014.
Technical Staff: Rick Sterling
Yao Yin
i:umisc:comments/ipce I 3.22ksrps)? supp comments
Deputy Attorney General
STAFF SUPPLEMENTARY COMMENTS SEPTEMBER 4,2014
0 - 100 MW Wind Capacity Penetration Level
LEVELIZED
ON-LINE YEAR
20 YEAR
CONTRACT
TERM
LEVELIZED
RATES
2014
2015
2016
2017
2018
2019
0.27
0.27
0.28
0.29
0.30
0.31
NON.LEVELIZED
CONTRACT
YEAR
NON-
LEVELIZED
RATES
2014
2015
2016
2017
2018
201 9
2020
2021
2022
2023
2024
2025
2026
2027
2028
2029
2030
2031
2032
2033
2034
2035
2036
2037
2038
2039
0.21
0.22
0.23
0.23
0.24
0.25
0.25
0.26
0.27
0.28
0.29
0.29
0.30
0.31
0.32
0.33
0.34
0.35
0.36
0.37
0.38
0.40
0.41
0.42
0.43
0.45
Attachment 1
IPC-E,-T3-22
Staff Supplementary Comments
09104114 Page 1 of 12
101 - 200 MW Wind Capacity Penetration Level
LEVELIZED
ON-LINE YEAR
20 YEAR
CONTMCT
TERM
LEVELIZED
RATES
2014
2015
2016
2017
2018
2019
1.22
1.25
1.29
1,33
1.37
1.41
NON.LEVELIZED
CONTRACT
YEAR
NON.
LEVELIZED
RATES
2014
2015
2016
2017
201 8
2019
2020
2021
2022
2023
2024
2025
2026
2027
2028
2029
2030
2031
2032
2033
2034
2035
2036
2037
2038
2039
0.98
1.00
1.04
1.07
1.10
1.13
1.'t6
1.20
1.24
1.27
1.31
1.35
1.39
1.43
1.48
1.52
1.57
1.61
1.66
1|71
1.76
1.81
1.87
1.93
1.98
2.04
Attachment 1
IPC-E-I3-22
Staff Supplementary Comments
09104114 Page 2 of 12
201 - 300 MW Wind Capacity Penetration Level
LEVELIZED
ON.LINE YEAR
20 YEAR
CONTRACT
TERM
LEVELIZED
RATES
2014
2015
2016
2017
2018
2019
2.78
2.87
2.95
3.04
3.13
3.23
NON.LEVELIZED
CONTRACT
YEAR
NON-
LEVELIZED
RATES
2014
2015
2016
2017
201 8
2019
2020
2021
2022
2023
2024
2025
2026
2027
2028
2029
2030
2031
2032
2033
2034
2035
2036
2037
2038
2039
2.23
2.30
2.37
2.44
2.51
2.59
2,67
2.75
2.83
2.92
3.00
3.09
3.19
3.28
3.38
3.48
3.59
3.69
3.80
3.92
4.04
4.16
4.28
4.41
4.54
4.68
Attachment I
IPC-E-13-22
Staff Supplementary Comments
09104114 Page 3 of 12
301 - 400 MW Wind Capacity Penetration Level
LEVELIZED
ON.LINE YEAR
20 YEAR
CONTRACT
TERM
LEVELIZED
RATES
2014
2015
2016
2017
2018
2019
4.95
5.10
5.26
5.41
5.58
5.74
NON.LEVELIZED
CONTRACT
YEAR
NON-
LEVELIZED
RATES
2014
2015
2016
2017
2018
2019
2020
2021
2022
2023
2024
2025
2026
2027
2028
2029
2030
2031
2032
2033
2034
2035
2036
2037
2038
2039
3.98
4,10
4.22
4.35
4.48
4.61
4.75
4.89
5.04
5.19
5.34
5.51
5.67
5.84
6.02
6.20
6.38
6.57
6.77
6.97
7.18
7.40
7.62
7.85
8.08
8.33
Attachment I
IPC-E-|3-22
Staff Supplementary Comments
09104114 Page 4 of 12
401 - 500 MW Wind Capacity Penetration Level
LEVELlZED
ON-LINE YEAR
20 YEAR
CONTRACT
TERM
LEVELIZED
RATES
2014
2015
2016
2017
201 8
2019
7.71
7.95
8.18
8.43
8.68
8.94
NON.LEVELIZED
CONTRACT
YEAR
NON.
LEVELIZED
RATES
2014
2015
2016
2017
2018
2019
2020
2021
2022
2023
2024
2025
2026
2027
2028
2029
2030
2031
2032
2033
2034
2035
2036
2037
2038
2039
6.19
6.38
6.57
6.77
6.97
7.18
7.39
7.62
7.84
8.08
8.32
8.57
8.83
9.09
9.37
9.65
9.94
10.23
10.54
10.86
1 1.18
11.52
1 1.86
12.22
12.59
12.96
Attachment I
rPC-E-13-22
Staff Supplementary Comments
09104114 Page 5 of 12
501 - 600 MW Wind Capacity Penetration Level
LEVELlZED
ON.LINE YEAR
20 YEAR
CONTMCT
TERM
LEVELIZED
RATES
2014
2015
2016
2017
2018
2019
11.05
1 1.38
11.72
12.07
12.43
12.81
NON.LEVELIZED
CONTRACT
YEAR
NON-
LEVELIZED
RATES
2014
2015
2016
2017
201 I
2019
2020
2021
2022
2023
2024
2025
2026
2027
2028
2029
2030
2031
2032
2033
2034
2035
2036
2037
2038
2039
8.87
9.13
9.41
9.69
9.98
10.28
10.59
10.91
11.23
11.57
11.92
12.28
12.64
13.02
13.41
13.82
14.23
14.66
15.10
15.55
16.02
16.50
16.99
17.50
18.03
18.57
Attachment I
tPC-E-r3-22
Staff Supplementary Comments
09104114 Page 6 of 12
601 - 700 MW Wind Capacity Penetration Level
LEVELIZED
ON-LINE YEAR
20 YEAR
CONTRACT
TERM
LEVELIZED
RATES
2014
2015
2016
2017
2018
2019
14,94
15.39
15.85
1 6.33
16.82
17.32
NON.LEVELIZED
CONTRACT
YEAR
NON-
LEVELIZED
RATES
2014
2015
2016
2017
2018
201 9
2020
2021
2022
2023
2024
2025
2026
2027
2028
2029
2030
2031
2032
2033
2034
2035
2036
2037
2038
2039
11.99
12.35
12.72
13.10
13.50
13.90
14.32
14.75
15.19
15.65
16.12
16.60
17.10
17.61
1 8.14
18.68
19.24
19.82
20.42
21.03
21.66
22.31
22.98
23.67
24.38
25.11
Attachment I
IPC-E-I3-22
Staff Supplementary Comments09/04/14 Page 7 of t2
701 - 800 MW Wind Capacity Penetration Level
LEVELIZED
ON-LINE YEAR
20 YEAR
CONTRACT
TERM
LEVELIZED
RATES
2014
2015
2016
2017
2018
2019
19.38
19.96
20.56
21.17
21.81
22.46
NON.LEVELIZED
CONTMCT
YEAR
NON-
LEVELIZED
RATES
2014
2015
2016
2017
2018
201 9
2020
2021
2022
2023
2024
2025
2026
2027
2028
2029
2030
2031
2032
2033
2034
2035
2036
2037
2038
2039
15.55
16.02
16.50
'17.00
17.51
18.03
18.57
19.13
19.70
20.29
20.90
21.53
22.18
22.84
23.53
24.23
24.96
25.71
26.48
27.27
28.09
28.93
29.80
30.70
31.62
32.57
Attachment I
IPC-E-t3-22
Staff Supplementary Comments
09/04114 Page 8 of t2
801 - 900 MW Wind Capacity Penetration Level
LEVELIZED
ON-LINE YEAR
20 YEAR
CONTRACT
TERM
LEVELIZED
RATES
2014
2015
2016
2017
2018
2019
24.34
25.07
25.83
26.60
27.40
28.22
NON.LEVELIZED
CONTRACT
YEAR
NON-
LEVELIZED
RATES
2014
201s
2016
2017
2018
2019
2020
2021
2022
2023
2024
2025
2026
2027
2028
2029
2030
2031
2032
2033
2034
2035
2036
2037
2038
2039
19.54
20.13
20.73
21.35
21.99
22.65
23.33
24.03
24.75
25.50
26.26
27.05
27.86
28.70
29.56
30.44
31.36
32.30
33.27
34.26
35.29
36.35
37.44
38.56
39.72
40.91
Attachment I
rPC-E-13-22
Staff Supplementary Comments
09104114 Page 9 of 12
901 - 1000 MW Wind Capacity Penetration Level
LEVELIZED
ON.LINE YEAR
20 YEAR
CONTMCT
TERM
LEVELIZED
RATES
2014
2015
2016
2017
2018
2019
29.82
30.72
31.64
32.59
33.57
34.57
NON.LEVELIZED
CONTRACT
YEAR
NON-
LEVELIZED
RATES
2014
2015
2016
2017
2018
2019
2020
2021
2022
2023
2024
2025
2026
2027
2028
2029
2030
2031
2032
2033
2034
2035
2036
2037
2038
2039
23.94
24.66
25.40
26.16
26.94
27.75
28.59
29.44
30.33
31.24
32.17
33.14
34.1 3
35.16
36.21
37.30
38.42
39.57
40.76
41.98
43.24
44.54
45.87
47.25
48.66
50.12
Attachment I
rPC-E-l3-22
Staff Supplementary Comments
09104114 Page 10 of l2
1001 - 1100 MW Wind Capacity Penetration Level
LEVELIZED
ON-LINE YEAR
20 YEAR
CONTRACT
TERM
LEVELIZED
RATES
2014
2015
2016
2017
2018
2019
35.81
36.88
37.99
39.1 3
40.30
41.51
NON.LEVELIZED
CONTRACT
YEAR
NON.
LEVELIZED
RATES
2014
2015
2016
2017
2018
2019
2020
2021
2022
2023
2024
2025
2026
2027
2028
2029
2030
2031
2032
2033
2034
2035
2036
2037
2038
2039
28.74
29.60
30.49
31.41
32.35
33.32
34.32
35.35
36.41
37.50
38.63
39.78
40.98
42.21
43.47
44.78
46.12
47.51
48.93
50.40
51.91
53.47
55.07
56.72
58.43
60.1 I
.A,ttachment I
IPC-E-L3-22
Staff Supplementary Comments
09/04114 Page I I of 12
1101 - 1200 MW Wind Capacity Penetration Level
LEVELIZED
ON-LINE YEAR
20 YEAR
CONTRACT
TERM
LEVELIZED
RATES
2014
2015
2016
2017
2018
2019
42.27
43.54
44.85
46.1 I
47,58
49.0'l
NON.LEVELIZED
CONTRACT
YEAR
NON.
LEVELIZED
RATES
2014
2015
2016
2017
2018
2019
2020
2021
2022
2023
2024
2025
2026
2027
2028
2029
2030
2031
2032
2033
2034
2035
2036
2037
2038
2039
33.93
34.95
36.00
37.08
38.1 I
39.34
40.52
41.73
42.98
44.27
45.60
46.97
48.38
49.83
51.33
52,87
54.45
56.09
57.77
59.50
61.29
63.12
65.02
66.97
68.98
71.05
Attachment I
IPC-E-13-22
Staff Supplementary Comments
09104114 Page 12 of 12
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 4.h DAY OF SEPTEMBER 2014,
SERVED THE FOREGOING SUPPLEMENTARY COMMENTS OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY, IN CASE NO. IPC-E-13-22,
BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWNG:
DONOVAN E WALKER
REGULATORY DOCKETS
IDAHO POWER COMPANY
PO BOX 70
BOISE rD 83707-0070
E-MAIL: [e-mail]
dockets@ idahopower.com
DEAN J MILLER
McDEVITT & MILLER LLP
420 W BANNOCK ST
BOISE ID 83702
E-MAIL: [e-mail]
KEN MILLER
SNAKE RIVER ALLIANCE
PO BOX 1731
BOISE ID 83701
E-MAIL: [e-mail]
BENJAMIN G HUANG MGR
c/o MOUNTAIN AIR PROJECT
6000 N FOXTAIL WAY
GLENNS FERRY ID 86623
E-MAIL: [e-mail]
PAUL ACKERMAN
ASST GENERAL COLINSEL
EXELON BUSINESS SER CORP
1OO CONSTELLATION WAY
BALTIMORE MD 21202
MICHAEL J YOUNGBLOOD
GREG SAID
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: [e-mail]
[e-mail]
zuCK KOEBBE PRESIDENT
IDAHO WINDS LLC
5420 W WICHER RD
GLENNS FERRY TD 83623
E-MAIL: [e-mail]
PETER J RICHARDSON
RICHARDSON ADAMS PLLC
515 N 27TH STREET
BOISE ID 83702
E-MAIL: [e-mail]
GREGORY M ADAMS
RICHARDSON ADAMS PLLC
515 N 27TH STREET
BOISE ID 83702
E-MAIL: [e-mail]
TERESA A HILL
K&L GATES LLP
ONE SW COLUMBIA ST
STE 19OO
PORTLAND OR 97258
E-MAIL: [e-mail]
CERTIFICATE OF SERVICE
DINA M DUBSON
RENEWABLE NW PROJECT
421 sw 6rH AVE srE 1125
PORTLAND OR 97204
E-MAIL: [e-mail]
DEBORAH E NELSON
PRESTON N CARTER
GIVENS PURSLEY LLP
PO BOX 2720
BOISE rD 83701-2720
E-MAIL: [e-mail]
prestoncarter@ givenspursley. com
CERTIFICATE OF SERVICE