20150428Application.pdf

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An IDACORP Company
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LISA D. NORDSTROM . I. , . .Leadcounsel t;tti_'ivii,,r_j"',:jt-,,,.'it-j;iit.)[e-mail]
April 28, 2015
VIA HAND DELIVERY
Jean D. Jewell, Secretary
ldaho Public Utilities Commission
472 West Washington Street
Boise, ldaho 83702
Re: Case No. IPC-E-15-15 - ldaho Power Company's Application for an Order
Approving Certain Computational Modifications to the True-Up Portion of the
Power Cost Adjustment
Dear Ms. Jewell:
Enclosed for filing please find an original and seven (7) copies of ldaho Power
Company's Application in the above matter.
Very truly yours,
X*-&fl^uh.o/,-
Lisa D. Nordstrom
LDN:kkt
Enclosures
LISA D. NORDSTROM (lSB No. 57
ldaho Power Company
1221West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
I nord strom@ idahopower. co m
Attorney for ldaho Power Company
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
AN ORDER APPROVING CERTAIN
COMPUTATIONAL MODI FICATIONS TO
THE TRUE.UP PORTION OF THE POWER
COST ADJUSTMENT.
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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CASE NO. IPC-E-15-15
APPLICATION
ldaho Power Company ("ldaho Powe/' or "Company") requests that the ldaho
Public Utilities Commission ("Commission") approve a settlement agreement
("Settlement Agreement") related to the Company's Power Cost Adjustment ("PCA")
entered into between ldaho Power and Commission Staff ("Staff'), hereafter referred to
individually as "Party" and jointly as "Parties." The Settlement Agreement primarily
addresses modifications necessary to convert the existing Load Change Adjustment
("LCA") in the PCA deferral calculation to the Sales Based Adjustment ("SBA") to
become effective January 1,2015. As described in more detail below, Parties agree that
the conversion to the SBA will more closely align the calculation of the PCA deferral
balance with the intent of the PCA, i.e., to "ensure the amount recovered is no more or
less than the actual power costs paid by the Company." Order No. 33089 at 2. ln
APPLICATION - 1
addition to the SBA transition, the Settlement Agreement also contains a provision to
modify the monthly interest calculation included in the PCA deferral balance to more
accurately reflect actua! interest expense incurred by the Company as a result of the
monthly accrued deferral.
Because application of the proposed SBA rate methodology effective January 1,
2015, would result in an additional $1,470,797.50 benefit to customers in the annual
2015-2016 PCA filed in Case No. IPC-E-15-14, the Parties request that the Commission
approve the Settlement Agreement no later than June 1,2015.
This Application is based on the following:
I. BACKGROUND
1. The PCA is a rate mechanism that quantifies and tracks annual
differences between Net Power Supply Expense ("NPSE") and the normalized or "base
level" of NPSE recovered in the Company's base rates for recovery or credit through an
annual rate change on June 1.
2. On May 30, 2014, the Commission issued Order No. 33049 in ldaho
Poweds 2014 PCA case, !PC-E-14-05, approving the Company's determination of the
2014 PCA components. However, through comments filed in that case, Staff expressed
concem regarding a potential line-loss bias impacting the Company's calculation of the
true-up amounts. ln response to these concems, the Commission ordered "that a separate
docket be opened to allow Commission Staff, the Company, and other interested persons
to hold a workshop to further evaluate the Company's application of the [PCA] true-up
[component] and whether a defenal balance adjustment is appropriate." Order No. 33049
at 13.
APPLICATION - 2
3. On July 1,2014, the Commission opened Case No. IPC-E-14-16 ('PCA
lnquiry Case") through Order No. 33067, and a workshop was subsequently scheduled for
July 30, 2014. Participants in the workshop included ldaho Power, Staff, the lndustrial
Customers of ldaho Power, the ldaho Conservation League, and the Snake River Alliance.
ln a Decision Memorandum dated July 30, 2014, Staff reported to the Commission that the
discussion had alleviated its concem regarding the Company's calculation of the true-up
component from the 2014 PCA case, and recommended that the Commission close the
docket. Staff also noted that it would continue to meet informally with the Company and
other interested persons to discuss possible refinements to the PCA mechanism.
4. On August 6, 2014, the Commission issued Order No. 33089 closing the
PCA lnquiry Case. ln that Order the Commission stated: "lf the parties' informal
discussions lead them to believe the PCA's accuracy can be improved, Staff should advise
us of that fact." Order No. 33089 at 2. Following the issuance of Order No. 33089, ldaho
Power and Staff continued to hold informal discussions regarding potential modifications to
the PCA to improve its accuracy. As a result of these discussions, ldaho Power and Staff
have agreed to a number of changes to the calculation of the PCA true-up balance that
Parties believe represent an improvement to the existing methodology.
5. The agreement of the Parties is summarized in this Application and is
more particularly described in the Settlement Agreement which has been executed by
the Parties and is included as Attachment No. 1 to this Application. In summary, the
terms of the agreement of the Parties as set out in the Settlement Agreement are as
follows:
APPLICATION - 3
II. SETTLEMENT AGREEMENT
6. Sales-Based Adiustment. Because the amount of power supply expenses
and other specific generation-related costs recovered through the Company's base
rates changes as loads increase or decline, the LCA is intended to adjust the PCA
deferral balance to account for actual recovery of certain energy-related expenses
through base rate revenue from actual sales. To correct for line-loss bias, the Parties
agree in Section 1 of the Settlement Agreement that the load-based LCA currently
utilized in the PCA deferral calculation will be replaced by a similar sales-based
adjustment or SBA. The SBA would function in the same manner as the existing LCA,
but the corresponding Sales-Based Adjustment Rate ("SBAR") would be calculated
utilizing test year sales rather than test year loads, and be applied to deviations in
ldaho-specific sales rather than total system loads. Parties agree that the transition to
the SBA will occur as of January 1, 2015.
7. SBAR Determination. As detailed in Section 2 of the Settlement
Agreement, Parties agree that the SBAR will be calculated in the same manner as the
existing Load Change Adjustment Rate ("LCAR'), with the only modification being the
replacement of the load-based megawatt-hour ('MWh") denominator (i.e., 2011 Rate
Case test year ldaho loads) with corresponding sales-based MWh denominator (i.e.,
2011 Rate Case test year ldaho sales). The Parties do not propose modifying the costs
included in the LCA at this time. Application of the proposed SBAR determination
method results in an SBAR of $26.72 per MWh.
8. One-Time Transitional Adiustment. Upon implementation of the SBA, a
one-time adjustment will be necessary to eliminate double counting that would
APPLICATION - 4
otherwise exist between calendar-month loads utilized in the final months of the LCA
determination and billing-month sales utilized in the initial months of the SBA
determination. To conect for this double counting, the proposed adjustment in Section
3 of the Settlement Agreement identifies and removes December 2014 calendar month
sales from January and February 2015 billing month sales according to the billing
methodology applied to each rate schedule. Because the SBAR is applied to changes
between actual sales and test year sales, the Parties agree that 2011 Rate Case test
year sales must be also be prorated according to the same methodology to allow for a
consistent sales change determination for use in the SBA calculation
9. ldaho Allocation of NPSE Deferral. Due to the ldaho-specific nature of the
SBA, a modification to the PCA deferral calculation is required to align the jurisdictional
assignment of NPSE with the jurisdictional assignment of base rate revenue recovery
(i.e., the SBA). The existing methodology calculates the difference between base and
actua! NPSE on a system basis, then assigns this deviation to the ldaho jurisdiction
utilizing the current ldaho allocation percentage of 95 percent from the Company's most
recent case in which base NPSE was reset. ln Section 4 of the Settlement Agreement,
Parties agree that it is more appropriate under the SBA to first assign actual monthly
system NPSE to the ldaho jurisdiction according to the ldaho proportion of actual billed
sales within each month, then compare these ldaho-allocated actual expenses to
approved Idaho-allocated base NPSE to determine the deferral amount. By allowing
the allocation of the NPSE deferral to float with the ldaho proportion of actual billed
sales, the jurisdictional assignment of revenue recognition and NPSE will remain
APPLICATION - 5
consistent, removing the potential undue impact of inconsistent allocation factors from
the resulting PCA deferral balance.
10. Monthlv NPSE Shapinq for lnterest Calculations. As detailed in Section 5
of the Settlement Agreement, in order to calculate monthly interest on the accrued
balance of the PCA deferral, annual base NPSE must be spread over the 12 months of
the PCA year. ln the Settlement Agreement, Parties agree to transition from the existing
methodology that assigns NPSE to each month based on the output of the Company's
NPSE modeling software, AURORAxmp ("AURORA'), to a monthly shaping that reflects
normalized test year base revenue as determined in the most recent case in which base
NPSE was reset. The Parties agree that the proposed modification to the monthly
shaping of base NPSE for interest calculations will become effective as of January 1,
2015. Therefore, the proposed adjustment to the Company's 2015 PCA filing includes
interest calculations for the first nine months of the 2014-2015 PCA year (April through
December 2014) that reflect the AURORA shaping methodology, while interest
calculations for the final three months of the PCA year (January through March 2015)
reflect the base revenue shaping methodology. Parties agree that ldaho Power will
discontinue the interest calculation report utilizing the AURORA shape with the
commencement of the 2015-2016 PCA year beginning April 1,2015.
11. Onooino Proration Requirement. The Parties agree that proration
adjustments will be required whenever the SBAR is recalculated to apply the
appropriate SBAR to sales that occur before and after the rate change effective date.
Parties agree that the proration methodology detailed in Section 3 of the Settlement
APPLICATION - 6
Agreement will appropriately identify and separate billing month sales that occurred
before and after the rate effective date in the event of a change to the SBAR.
III. MODIFIED PROCEDURE
12. Pursuant to RP 274, the Commission has discretion to determine the
manner with which it considers a proposed settlement. ldaho Power believes that a
technical hearing is not necessary to consider the issues presented herein and
respectfully requests that this Application be processed under Modified Procedure, i.e.,
by written submissions rather than by hearing. RP 201, ef seg. lf, however, the
Commission determines that a technical hearing is required, the Company stands ready
to support the Application in such hearing.
13. lmpact on Pendino 2015-2016 PCA Filino. As contemplated by the
Settlement Agreement, implementation of the SBAR methodology effective January 1,
2015, would result in a reduction of $1,470,797 to the April 2014 through March 2015
PCA deferral amount of $34,515,981 , which was filed by the Company in Case No. IPC-
E-15-14 on April 15,2015. The resulting deferral amount to be collected in the 2015-
2016 PCA would be $33,045,184.ldaho Power and the Staff agree that it is appropriate
to adjust this year's requested PCA deferral amount to align with the terms of the
Settlement Agreement and will recommend in comments to be filed in Case No. !PC-E-
15-14 that the Commission approve such an adjustment. Acceptance of the proposed
2015-2016 PCA deferral adjustment will result in a greater PCA decrease for customers
effective June 1,2015, adjusting the total PCA revenue decrease from $10.1 million to
approximately $11.6 million. For the changes agreed to above to be included in the
Commission's order associated with the Company's annual 2015-2016 PCA filing, the
Parties request that the Commission approve the Settlement Agreement no later than
June 1,2015.
APPLICATION - 7
IV. COMMUNICATIONS AND SERVICE OF PLEADINGS
14. Communications and service of pleadings with reference to this
Application should be sent to the following:
Lisa D. Nordstrom
ldaho Power Company
P.O. Box 70
Boise, ldaho 83701
I nord strom@ ida hopower. com
dockets@ idahopower. com
Tim Tatum
ldaho Power Company
P.O. Box 70
Boise, ldaho 83707
ttatum@id a hopower. com
V. REQUEST FOR RELIEF
15. The Parties agree that this Settlement Agreement is in the public interest
and that all of its terms and conditions are fair, just, and reasonable. Therefore, the
Parties submit this Settlement Agreement to the Commission and recommend approval
in its entirety pursuant to RP 274-76. All terms and conditions of this Settlement
Agreement are subject to approval by the Commission, and only after such approval,
without materia! change or modification, has been received sha!! the Settlement
Agreement be valid. Therefore, ldaho Power respectfully requests that the Commission
issue its order:
(1) Approving the Settlement Agreement and authorizing the Company
to utilize the SBAR provisions relating to the PCA methodology in the manner described
in the Settlement Agreement without material change or condition; and
(2) Authorizing this proceeding to be processed expeditiously under
modified procedure in accordance with RP 201, ef seg. such that changes benefiting
customers can be included in2015-2016 PCA rates effective June 1,2015.
Respectfully submitted this 28 day of April 2015.
Attorney for ldaho Power Company
APPLICATION - 8
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 28 day of April 2015 I served a true and correct
copy of the foregoing APPLICATION upon the following named parties by the method
indicated below, and addressed to the following:
Commission Staff
Karl Klein
Deputy Attomey General
Idaho Public Utilities Commission
4T2WeslWashington
P.O. Box 83720
Boise, ldaho 83720-007 4
X Hand Delivered
U.S. Mail
Ovemight Mail
FAXX Email [e-mail]
Executive Assistant
APPLICATION - 9
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
GASE NO. IPC-E-I5-15
IDAHO POWER COMPANY
ATTACHMENT NO. 1
SETTLEMENT AGREEMENT
BETWEEN
IDAHO POWER COMPANY
AND
IDAHO PUBLIC UTILITIES COMMISSION STAFF
This settlement agreement ("Settlement Agreement" or "Agreement") to modify
computations within ldaho Power's Power Cost Adjustment (.PCA") mechanism is
entered into by Idaho Power Company ("ldaho Powe/' or "Company") and the Staff of
the ldaho Public Utilities Commission ("Staff'), hereafter referred to individually as
"Party" and jointly as "Parties."
BACKGROUND
On May 30, 2014, the ldaho Public Utilities Commission ("Commission") issued
Order No. 33049 in ldaho Power's 2014 PCA case, IPC-E-14-05, approving the
Company's determination of the 2014 PCA components. However, through comments
filed in that case, Staff expressed concem regarding a potential line-loss bias impacting
the Company's calculation of the true-up amounts. ln response to these concems, the
Commission ordered "that a separate docket be opened to allow Commission Staff, the
Company, and other interested persons to hold a workshop to further evaluate the
Company's application of the [PCA] true-up [component] and whether a defena! balance
adjustment is appropriate." Order No. 33049 at 13.
On July 1, 2014, the Commission opened Case No. IPC-E-14-16 ("PCA lnquiry
Case") through Order No. 33067, and a workshop was subsequently scheduled for July
30, 2014. Participants in the workshop included ldaho Power, Staff, the lndustrial
Customers of ldaho Power ("lClP'), the ldaho Conservation League ("lCL'), and the Snake
River Alliance ("SRq'1. !n a Decision Memorandum dated July 30, 2014, Staff reported to
SETTLEMENT AGREEMENT . 1
the Commission that the discussion had alleviated its concern regarding the Company's
calculation of the true-up component from the 2014 PCA case, and recommended that the
Commission close the docket. Staff also noted that it would continue to meet informally
with the Company and other interested persons to discuss possible refinements to the
PCA mechanism.
On August 6, 2014, the Commission issued Order No. 33089 closing the PCA
Inquiry Case. ln that Order the Commission stated: "!f the parties' informal discussions
lead them to believe the PCA's accuracy can be improved, Staff should advise us of that
fact." Order No. 33089 at 2.
Following the issuance of Order No. 33089, ldaho Power and Staff continued to
hold informal discussions regarding potential modifications to the PCA to improve its
accuracy. As a result of these discussions, ldaho Power and Staff have agreed to a
number of changes to the calculation of the PCA true-up balance that Parties believe
represent an improvement to the existing methodology. Based upon these discussions,
Parties agree to the following terms:
TERMS OF THE SETTLEMENT AGREEMENT
1. Sales-Based Adiustment. Parties agree that the Load Change Adjustment
("LCA") currently utilized in the PCA deferral calculation will be replaced with the Sales
Based Adjustment ("SBA") as detailed in this Settlement Agreement. Parties agree that
the transition to the SBA will occur as of January 1,2015.
2. Sales Based Adiustment Rate ("SBAR") Determination. Parties agree that
the SBAR will be calculated in the same manner as the existing Load Change
Adjustment Rate ("LCAR"), with the only modification being the replacement of the !oad-
SETTLEMENT AGREEMENT - 2
based megawatt-hour ('MWh") denominator with the corresponding sales-based MWh
denominator. This modification is detailed in the equations below:
Calculation of Cunent LCAR
$360,747,094 + 14,822,063 MWh =
Approved LCAR 2011 Rate CaseNumerator ldaho Loads
Approved LCAR
Numerator
2011 Rate Case
ldaho Sales
$24.34/MWh
Current
LCAR
Proposed
SBAR
Calculation of Proposed SBAR
$360,747,094 + 13,498,892 MWh = $26.72lMWh
3. One-time Transitional Adiustment. Parties agree that a one-time adjustment
is necessary to eliminate double counting that would otherwise exist between calendar
month loads used in the December 2014 LCA calculation and billing month sales used in
the January and February 2015 SBA calculations. To eliminate any double counting, the
proposed adjustment identifies and removes December 2014 calendar month sales
previously used in the quantification of the December LCA from January and February
2015 billing month sales used in the SBA computations for those months. Table 1
describes the billing methodology for each rate schedule, while Table 2 describes the
corespond ing adjustment that accom pl ishes the above-stated objective :
Table 1: Billinq Methodoloqv bv Rate Schedule
Rate Schedule Nos.Billing Methodology
1,3,5,7,9 Secondary,l 5,24,40,41,42 Schedule of 23 Billing Cycles
9 Primary and Transmission, 19 Calendar Month Measurement with One
Month Billino Lao
26,29,30 Calendar Month Measurement with No Billing
Laq
SETTLEMENT AGREEMENT . 3
Rate Schedule Nos.Adjustment Methodology
1,3,5,7,9 Secondary,l 5,24,40,41,42 Energy Proration by Days in Billing Cycle'
9 Primary and Transmission, 19 Removal of January 2015 Billed Sales
26,29,30 No Adjustment Needed
Table 2: TransitionalAdiustment bv Rate Schedule
Parties agree that the adjustments listed in Table 2 must be applied to both
actual sales and test year sales to allow for a consistent sales change determination for
use in the SBA calculation.
4. ldaho Allocation of NPSE Deferral. Parties agree to modify the allocation
percentage used in the determination of the Company's ldaho jurisdictional net power
supply expense ('NPSE') deferral. The existing methodology calculates the difference
between base and actual NPSE on a system basis, then assigns this deviation to the
ldaho jurisdiction utilizing the current ldaho allocation percentage of 95 percent from the
Company's most recent case in which base NPSE was reset. Under the SBA, Parties
agree that it is more appropriate to first assign actual monthly system NPSE to the
ldaho jurisdiction according to the ldaho proportion of actual billed sales within each
month, then compare these ldaho-allocated actual expenses to approved Idaho-
allocated base NPSE to determine the deferral amount.
The equations below detail this change in methodology. The first equation
provides a general representation of the existing ldaho allocation methodology, while
lThis method applies a percentage to billing month sales that reflects the proportion of days in
each billing cycle that falls before January 1 , 2015. This is.the same method currently used to prorate
energy charges for billing cycle customers in the event of a rate or season change.
SETTLEMENT AGREEMENT - 4
the second equation provides a general representation of the proposed ldaho allocation
methodology:2
Current Jurisdictional Assiqnment of NPSE Deferral
Deferral = (Actual System NPSE - Base System NPSE) x g5%3
Proposed Jurisdictional Assionment of NPSE Deferral
Deferral = (Actual System NPSE x ldaho % of Actual Billed Sales) - ldaho Base NPSE
5. Monthlv NPSE Shapino for lnterest Calculations. To calculate monthly
interest on the accrued balance of the PCA deferral, annual base NPSE must be spread
over the 12 months of the PCA year to determine monthly deferral amounts. Under the
existing interest calculation methodology, the monthly spread of base NPSE reflects the
monthly output of the Company's NPSE modeling software, AURORAxmp ("AURORA").
As a result of discussions in this case, Parties agree that it is more appropriate to
calculate monthly interest utilizing a monthly base NPSE spread that reflects the
proportion of approved base rate revenue collection in each month as determined in the
most recent case in which base NPSE was reset.a
Parties agree that the proposed modification to the monthly shaping of base
NPSE for interest calculations will become effective as of January 1,20'15. Therefore,
the deferral amount included in the Company's 2015 PCA filing (Case No. !PC-E-1 5-14)
should be adjusted to include interest calculations for the first nine months of the 2014-
2015 PCA year (Apri! through December 2014) that reflect the AURORA shaping
'These equations are intended to illustrate the proposed changes to the ldaho allocation of the
NPSE deferral. For the sake of simplicity, these equations do not reflect the sharing provisions applied to
certain NPSE accounts.
sAllocation percentage from the Company's most recent general rate case, Case No. IPC-E-11-
08.
the current revenue shape reflects final approved base revenues from Case No. IPC-E-1 1-08.
SETTLEMENT AGREEMENT - 5
methodology, while interest calculations for the final three months of the PCA year
(January through March 2015) should reflect the base revenue shaping methodology.
Parties agree that ldaho Power will discontinue the interest calculation report utilizing
the AURORA shape with the commencement of the 2015 PCA year beginning April 1,
2015.
6. Onqoinq Proration Requirement. Parties agree that proration adjustments
will be required whenever the SBAR is recalculated to apply the appropriate SBAR to
sales that occur before and after the rate change effective date. Parties agree that the
proration methodology detailed in Section 3 above will appropriately identify and
separate billing month sales that occurred before and after the rate effective date in the
event of a change to the SBAR.
7. The Parties submit this Settlement Agreement to the Commission and
recommend approval in its entirety pursuant to RP 274-76. The Parties shall support
this Settlement Agreement before the Commission and shall not appeal a Commission
order approving the Settlement Agreement or an issue resolved by the Settlement
Agreement. If this Settlement Agreement is challenged by anyone who is not a party,
then each Party reserves 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 Settlement Agreement. Notwithstanding this reservation of rights, the Parties agree
that they will continue to support the Commission's adoption of the terms of this
Settlement Agreement.
SETTLEMENT AGREEMENT - 6
8. lf the Commission or any reviewing body on appeal rejects any part or all
of this Settlement Agreement or imposes any additional material conditions on approval
of this Settlement Agreement, then each Party reserves the right, 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 Settlement Agreement. ln such
case, no Party shall be bound or prejudiced by the terms of this Settlement Agreement
and each Party shall be entitled to seek reconsideration of the Commission's order, file
testimony as it chooses, cross-examine witnesses, and do all other things necessary to
put on such case as it deems appropriate. ln such case, the Parties immediately will
request the prompt reconvening of a prehearing conference for purposes of establishing
a procedural schedule for the completion of the matter.
9. The Parties agree that this Settlement Agreement represents a fair, just,
and reasonable compromise of the PCA computation dispute(s) between the Parties,
and that this Settlement Agreement is in the public interest. The Parties maintain that
the Settlement Agreement as a whole and its acceptance by the Commission represent
a reasonable resolution of all issues between the Parties identified herein.
10. No Party shall be bound, benefited, or prejudiced by any position asserted
in the negotiation of this Settlement Agreement, except to the extent expressly stated
herein, nor shal! this Settlement Agreement be construed as a waiver of rights unless
such rights are expressly waived herein. Except as otherwise expressly provided for
herein, execution of this Settlement Agreement shall not be deemed to constitute an
acknowledgment by any Party of the validity or invalidity of any particular method,
theory, or principle of regulation or cost recovery. No findings of fact or conclusions of
law other than those stated herein shall be deemed to be implicit in this Settlement
SETTLEMENT AGREEMENT - 7
Agreement. This Settlement Agreement sets forth the complete understanding of the
Parties, and this Settlement Agreement includes no other promises, understandings,
representations, arrangements, or agreements pertaining to the subject matter of this
Settlement Agreement, or any other subject matter, not expressly contained herein.
11. The obligations of the Parties are subject to the Commission's approval of
this Settlement Agreement in accordance with its terms and conditions and upon such
approval being upheld on appeal, if any, by a court of competent jurisdiction. All terms
and conditions of this Settlement Agreement are subject to approval by the
Commission, and only after such approval, without material change or modification, has
been received shall the Settlement Agreement be valid.
12. This Settlement Agreement may be executed in counterparts and each
signed counterpart shall constitute an original document.
DATED this z 8 flday of April 2015.
ldaho Power Company Commission Staff
,, /4 /%-
Karl Klein
Attorney for Commission Staff
SETTLEMENT AGREEMENT - 8