HomeMy WebLinkAbout20131220Answer.pdfGrynNs PunsLEY,*
LAW OFFICES
601 W. Bannock Stroet
PO Box2720, Boise, ldaho 8370'l
TELEPHONE: 208 3EE-1200
FACSIMILE: 206 3881300
WEBSITE: wW.givonspursl6y.com
Deborah E. Nelson
den@oivenspurslev.com
(208) 388-121 5
VA HAND DELIWRY
Jean Jewell,
Commission Secretary
Idaho Public Utilities Commission
472 W. Washington
Boise, ID 83702
December 20,2013
Gary G. Allen
Peter G. Barton
Christopher J. Bseson
Clint R. Bolind€r
Erik J. Bolinder
Preston N. Carter
Jeremy C. Chou
Wlliam C. Cole
Michael C. Creamer
Amber N. Dina
Elizabeth M. Donick
Thomas E. Dvorak
Jeffrey C. Fereday
Martin C. Hendrickson
Don E. Knickrehm
Neal A. Koskella
Dabora K. Kristsnsn
Michael P. Latren@
Franklin G. Lee
Oavid R. Lombardi
Emily L. McClure
Kennelh R. Mcclure
Kally Gr@ne Mcconnell
Alox P. McLaughlin
Melodio A. McQuade'
Chrisiopher H. Meyer
L. Edward Miller
Patrick J. Miller
Judson B. Montgomsry
D8borah E. Nalson
W. Hugh O'Riordan, LLM.
Angela M. Reed
Matt G. Smith
P. Mark Thompson
Jeffrey A. Wan
Robert B. Vvhite
Of Counsel
Kimborly D. Maloney
'Li€nsed in Virginia
Retired:
Ksnneth L. Pursley
James A. Mcclure (1924-20111
Raymond D. Givens ('1917-2008)
{r'}
lPt-E-i3-tq
RE: Idaho Wind Portners vs. Idaho Power Company
Dear Jean:
Enclosed are an original and eight (8) copies of Idaho Wind Partners I, LLC's Answer to
Idaho Power Company's Cross-Complaint in the above matter. Please conform a copy and
return it with our courier.
Please do not hesitate to contact me if you have questions or concerns.
Deborah E. Nelson
DEN/kml
Enclosures
r95l70l I
Deborah E. Nelson, ISB # 5711
Preston N. Carter, ISB # 8462
GIVENS PURSLEY LLP
601 W. Bannock St.
Post Office Box2720
Boise, Idaho 83701-2720
Telephone: 208-388- 1200
Facsimile: 208-388-1 300
11067-18 1942657 14
Attorneys for Idaho Wind Partners I, LLC
IDAHO WIND PARTNERS I, LLC,
Complainant and Petitioner,
vs.
IDAHO POWER COMPANY,
Respondent.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
Case No. IPC-E-I3-19
IDAHO WIND PARTNERS I, LLC'S
ANSWER TO IDAHO POWER
COMPANY'S CROSS.COMPLAINT
INrnonucrroN AND RpsroNsr
IDAHO WIND PARTNERS I, LLC ("IWP") answers Idaho Power Company's Cross-
Complaint pursuant to Idaho Administrative Rule 31.01.01.57. IWP filed a Complaint and
Petition for Declaratory Order ("Complaint and Petition") against Idaho Power Company
("[daho Power") on October 25,2013. The Complaint and Petition seeks interpretation and
enforcement of certain 2005-era Firm Energy Sales Agreements ("FESAs") between Idaho
Power and projects owned by IWP. Specifically, the Complaint and Petition seeks interpretation
and enforcement of the FESAs' requirement that Idaho Power purchase Surplus Energy at arate
equal to the current month's "Market Energy Cost," defined as "Eight-five percent (85%) of the
ANSWER TO CROSS-COMPLAINT - Page I
weighted average of the daily on-peak and off-peak Dow Jones Mid-Columbia Index (Dow
Jones Mid-C Index) prices for non-firm energy." Complaint and Petitionat2.
Idaho Power filed an Answer and Cross-Complaint on or about November 29,2013. The
Answer generally denies IWP's allegations that Idaho Power has failed to purchase Surplus
Energy at Market Energy Cost. The Cross-Complaint contends that the Dow Jones Mid-C Index
for non-firm energy has been discontinued and that there exists no Mid-C non-firm index other
than Platts, the replacement publisher for the Dow Jones Mid-C Index. Idaho Power seeks an
order directing IWP to accept the use of the Platts non-firm index as the replacement index for
the calculation of Market Energy Cost in the FESAs.
Since the close of business on September 13, 2013, when Platts began publishing the
Mid-C Index, Platts has not reported a single transaction volume. Because Idaho Power
calculates Market Energy Price with reference only to those prices with a reported transaction
volume, Idaho Power has paid zero dollars to IWP for all Surplus Energy delivered during that
same timeframe. If the Commission permits Idaho Power to continue its calculation of Market
Energy Cost while also imposing Platts as a replacement index, then IWP is threatened with the
prospect of no payment for Surplus Energy for the entire remaining length of their contracts.
This would result in millions of dollars in damages, in addition to the damages IWP has already
suffered.
Axswrn
IWP answers the allegations in Idaho Power's Cross-Complaint as follows. IW? denies
any allegation not specifically admitted. IWP reserves the right to supplement this Answer if
Idaho Power amends its Cross-Complaint or if new facts come to light.
In response to the first, unnumbered paragraph in the Cross-Complaint, IWP hereby
incorporates the allegations in its Complaint that correspond to the statements Idaho Power
ANSWER TO CROSS-COMPLAINT -Page2
incorporates by reference. The remaining paragraphs of this Answer correspond to the numbered
paragraphs in the Cross-Complaint.
l. IWP admits that Idaho Power sent a notice to the projects encompassed in IWP's
Complaint and that the first page of each notice is attached to the Cross-Complaint as
Attachment 1. IWP has attached the complete notices as Exhibits I through 8 to this Answer.
As to any remaining allegations, the notices speak for themselves and no further response is
required.
2. IWP admits that the relevant FESAs contain the language quoted inparagraph2
of the Cross-Complaint. As to any remaining allegations, the FESAs speak for themselves and
no further response is required.
3. IWP denies that there is no other Mid-C electric price index available for use.
Idaho Power has agreed to, and the Commission has approved, the Intercontinental Exchange
Mid-Columbia Index (ICE Mid-C Index) for use as the Market Energy Reference Price in a
FESA with a wind producer. See Order 32125 (Nov. 24,2010),IPC-E-10-24 (approving FESA
between Idaho Power and Rockland Wind Project LLC).1 In addition, upon information and
belief, utilities in the region have requested to use Powerdex indexes to calculate market-based
rates. For example, Avista has filed Tariff Advice No. ADV-13-06-E to define "Market Rate" in
Avista Schedule 62 with reference to the Powerdex Real-Time Hourly Mid-Columbia Index.
4. IWP admits that it sent Idaho Power a letter on November 25,2013, and that a
copy of the letter is attached to the Cross-Complaint as Attachment2. As to any remaining
allegations, the letter speaks for itself and no further response is required.
I Section L30 of the Rockland FESA defines Mid-Columbia Market Energy Cost,
percent (90%) of the monthly weighted average of the daily on-peak and off-peak
Columbia Index (lCE Mid-C Index) prices for firm energy."
ANSWER TO CROSS-COMPLAINT - Page 3
in relevant part, as "Ninety
lntercontinental Exchange Mid-
5. IWP admits that Idaho Power filed Tariff Advice No. 13-05 on October 24,2013,
and that through the Tariff Advice Idaho Power seeks, among other things, to amend Schedule
86 by adding "volume" before the words "weighted average." IWP denies the Tariff Advice is
mere "clarification" but, rather, believes it constitutes an amendment to Schedule 86. IWP
denies that the Tariff Advice, if accepted, could affect interpretation of the FESAs because any
amendment to Schedule 86 would operate prospectively only. As to any remaining allegations,
the Tariff Advice No. 13-05 and related documents speak for themselves and no further response
is required.
1.
granted.
ArrtnM,c,rlvE DEFENSES
Idaho Power's Cross-Complaint fails to state a claim upon which relief may be
2. The FESAs require that Idaho Power and IWP "mutually agree upon" a
replacement for the Dow Jones Mid-C Index. FESAs 1T1.12. IWP does not agree to Platts as a
replacement index if it is coupled with Idaho Power's calculation of Market Energy Cost.
However, IWP does not object to Platts as a replacement index, so long as the Commission
orders Idaho Power to calculate Market Energy Price using the monthly average of all published
daily prices, weighted by the number of on- and off-peak hours in the day.
PnavBR FoR RELTEF
IWP respectfully requests the Commission issue an Order:
A. Denying the relief sought by Idaho Power in the Prayer for Relief included in
Answer and Cross-Complaint and dismissing Idaho Power's Cross-Complaint in its entirety;
B. Requiring that Idaho Power calculate Market Energy Cost consistent with the
FESAs, namely by calculating the monthly average of all published daily prices, weighted by the
number of on- and off-peak hours in the day;
ANSWER TO CROSS-COMPLAINT- Page 4
C. Granting the relief sought in IWP's Complaint; and
D. Granting any other relief the Commission deems proper.
DATED this 2fth day of December 2013.
GTVENS PURSLEY LLP
Deborah E. Nelson
Attorneyfor Idaho Wind Partners I, LLC
ANSWER TO CROSS-COMPLAINT - Page 5
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that I have on this 20th day of December 2013, served the
foregoing IDAHO WIND PARTNERS I, LLC'S ANSWER TO IDAHO POWER COMPANY'S
CROSS-COMPLAINT upon all parties of record in this proceeding, by delivering an original
and seven copies upon:
Jean Jewell, Commission Secretary
Idaho Public Utilities Commission
472W. Washington
Boise, ID 83702
And by mailing a copy thereof, properly addressed with postage
Donovan E. Walker (dwalker@idahopower.com)
Julia A. Hilton (hilton@idahopower.com)
Idaho Power Company
l22l W.Idaho St.
P.O. Box 70
Boise,ID 83702
Deborah E. Nelson
ANSWER TO CROSS-COMPLAINT - Page 6
SIffi*.
An TDACORP Comoanv
October 14,2013
Tuana Gulch Wind Park LLC - Attn: Steven Eisenberg
c/o Idaho Wind Pnrtners I, LLC
c/o RP Wind lD LLC
P.O. Box 2M9,82 Elm Street
Manchester, VT 05255-
Re: Tuana Gulch Wind Park
Project Number: 31315055
NON.FIRM MID C ELECTRICITY INDEX
PLEASE BE ADVTSED: The energy sales agreement between your generation project and Idaho
Power Company provides that in some circumstances the Non-Firm Mid C electricity index energy
values are used to calculate the energy payments for your project. Historically these Non-Firm Mid C
index values have been provided by Dow Jones. Idaho Power received notice regarding its
subscription to the Dow Jones index from McGraw Hill Financial that as of close of business on
Friday, September 13, 2013, the Dow Jones index will transition to Platts. Platts now provides the
Non-Firm Mid C electricity index information that was previously provided by Dow Jones. (See
attached notice)
Should you have any questions please contact:
Randy Allphin
Energy Contracts lrader
Idaho Power Company
(208) 388-2614
E-mail: rlrI IDhin (4 iclith,rpo$ cr.cotlt
PO. 8ox 70 (81707)
1221 W. rdaho 5t
Borse, lD 837O2
EXHIBIT I
D $ S&P DOWJONESJ lttotces
|.irGlAW |llli IlllAraGlrr
s r PLATTS, ir.cRAw Hru. Frt{ANcrAL
TRANSITION OF THE
DOW JONES U.S. ETECTRICITY INDICES
Transition Highlights
fftective after the close of business on Frlday, September 13,2013, Platts, a leading global provider of energy,
petrochemicals, metals and agriculture information, and a premier source of benchmark price assessments for those
commodhy markets, will begin providing you with price data that will replace the U.S. electricity prices you currently
recerve from S&P Dow Jones lndices.
As a result, the calculatron and dissemrnatron of the Dow Jones U.5. tlectricaty lndices will transrtion to platts. The
following table highlights the changes that will take place as a resuh of this transition. The full Platts Methodology Guide
is ayailable. here.
S&P DorrJonor lndlccr Cdculatlor
Mcdrodolosv Pfatts Galculadon Mcthodology
Dates Prices published on flow date.Prices published on trade date.
Calculation
Weighted average index.
Weighted average price assessment with high
correlation to the Dow Jones U.S, Electricity
lndices.
Both firm and non-firm liquidated damages
are calculated.
Eoth firm and non-firm liquidated damages
will be calculated.
Contributors There is substantial overlap between the contributors to Platts and Dow Jones Electricity
lndices; this ensures ongoing continuity in pricing.
Distribution
r Files will be delivered via the Platts FTP feed in comma separated value (.csvl format
beginning September 13, 2013, There will be no change to file formats.
r Email delivery will continue from September 13 through October 30, 2013 in .csv format.
*Email delivery w-U cease on October 31, 201j.*-._.____*-,
Reminder: as previously announced, effective after the close of business on Friday, August 30, 2013, S&P Dow Jones
lndices will no longer calculate the Oow Jones U.S. Hourly Electricity lndices.
<IHffiR.
An IDA.I.ARP CCmoJnI
0ctober 14,2013
Golden Valley Wind Park, LLC Attn: Steven Eisenberg
c/o ldaho Wind Partners l, LLC
c/o RPWind ID LLC
P.O. Box 2049 82 Elm Street
Manchester Center, VT 05255-
Rc: Colden Valley Wind Park
Project Number: 3 17 65160
NON-FIRM MID C EI,ECTRICITY INDEX
PLEASE BE ADVISED: The energy sales agreement between your generation project and ldaho
Power Company provides that in some circumstances the Non-Firn Mid C electricity index energy
values are used to calculate the energy payments for your pmject. Historically these Non-Firm Mid C
index values have been provided by Dow Jones. Idaho Power received notice regarding its
subscription to the Dow Jones index from McGraw Hill Financial that as of close of business on
Friday, September 13, 2013, the Dow Jones index will transition to Platts. Platts now provides the
Non-Firm Mid C electricity index information that was previously provided by Dow Jones. (See
attached notice)
Should you have any questions please contact:
Randy Allphin
Energy Contracts Leader
Idaho Power Company
(208) 388-26r4
E-mail: rirII nlrr lr @' idilh()D()\\ L:r.cotll
PO Box 70 (8.]707)
EXHIBIT2 l22rwrdahost
80're. lD 81702
i { s&P 00wJ0NEsJ tnorcrs
r'lcoRAll HIU tlll raolAr
. r PLATTS7 ".snr* Hu,[ FrrA*crAL
TRANSIION OF THE
DOWJONES U.S. ETECTRICIW INDICES
Transition Highlights
Effective after the close of business on Friday, September L?,20I,3., Platts, a leading global provider of energy,
petrochemicals, metals and agricuhure information, and a premier source of benchmark price assessments for those
commodity markets, witl begin providing you with price data that will replace the U,S. electricity prices you currently
receive from 5&P Dow Jones lndices.
As a resull the calculation and dissemination of the Dow Jones U.S. Electricity lndices will transition to Platts. the
following table highlights the changes that will take place as a result of this transition. The full Platts Methodology 6uide
is available here.
S&P DowJones lndces Cdculatlon
Mathodol*v Plattr Calculadon Methodology
Dates Prices published on flow date.Prices published on trade date.
Calculation
Weighted average index.
Weighted average price assessment with high
correlation to the Dow lones U.S. Electricity
lndices.
Both firm and non-firm liquidated damages
are calculated.
Both firm and non-firm liquidated damages
will be calculated.
Contributors There is substantial overlap between the contributors to Platts and Dow ,ones Electricity
lndices; this ensures ongoing continuity in pricing.
Distribution
o Files will be delivered via the Platts FTP feed in comma separated value (.csv) format
beginning September 13, 2013. There will be no change to file formats.
r Email delivery will continue from September 13 through October 30, 2013 in .csv format.
Email delivery willcease on October 31, 2013.
Reminder: as previously announced, etfective after thc close of business on Friday, August 30, 2013, S&P Dow lones
lndices wrll no longer calculate the DowJones U.S. Hourly Electricity lndices.
7Ilmt0Nrpy6p
An TDACOPp ComDan.,
October l4,20l3
Milner Dam Wind Park, LLC - Attn: Steven Eisenberg
c/o ldaho Wind Partners l, LLC
clo RPWind ID LLC
P.O. Box 2M9 82 Elm Street
Manchester Center, VT 05255-
Re: Milner Dam Wind
Pmject Nunrber: 31720194
NON.FIRM MID C ELECTRICITY INDEX
PLEASE BE ADVISED: The energy sales agreement between your generation proiect and ldaho
Power Company provides that in some circumstances the Non-Firm Mid C electricity index energy
values are used to calculate the energy payments for your project. Historically these Non-Firm Mid C
index values have been provided by Dow Jones. Idaho Power received notice regarding its
subscription to the Dow Jones index from McGraw Hill Financial that as of close of business on
Friday, September 13, 2013, the Dow Jones index will transition to Plats. Platts now provides the
Non-Firm Mid C electricity index information that was previously provided by Dow Jones. (See
attached notice)
Should you have any questions please contact:
Randy Allphin
Energy Contracts Leader
Idaho Power Company
(208) 388-2614
E-mail: rallphin@ idaltopoucr.cortt
iO 8r:r 70 (83747)
1?2 I W. ldaho St
Bors€, lO 817C2
EXHIBIT 3
'i { s&P 00WJ0NESJ txorces
HcGnAW HLL f lrlarlcl^l.
"J r.|fIl,,?,,*^n,*..
TRANSITION OF THE
DOW JONES U.S. ETECTRICITY INDICES
Transition Highlights
Effective after the close of business on Friday, September 13, 2013, Platts, a leading global provider of energy,
petrochemicals, metals and agricuhure information, and a premier source of benchmark price assessments for those
commodity markets, will begin providing you with price data that will replace the U.S. electricity prices you currently
receive from S&P Dow Jones lndices.
As a result, the calculatioo and dissemination of the Dow Jones U.S. Electricity lndices will transition to Platts. The
following table highlights the changes that will take place as a result of this transition. The full Platts Methodology Guide
is avaijable -hgre.
S&P DowJonee lndlces Cdcuhtlon
Mar{pdolorv Platts Calculadon Methodoloty
Dates Prices published on flow date.Prices published on trade date.
Calculation
Weighted average index.
Weighted average price assessment with high
correlation to the Dow Jones U.S. Electricity
lndices.
Both firm and non-firm liquidated damages
are calculated.
Both firm and non-firm liquidated damages
will be calculated.
Contributors There is substantial overlap between the contributors to Platts and Dow Jones Electricity
lndices; this ensures ongoing continuity in pricing.
Distribution
r Files will be delivered via the Platts FTP feed in comma separated value (.csv) format
beginning Septomber 13, 2013. There will be no change to file formats.r Email delivery will continue from September 13 through October 30, 2013 in .csv format.
Ernail delivery will cease on October 31, 2013.
Reminder: as previously announced, effective after the close of business on Friday, AuBust 30, 2013, S&P Dow Jones
lndice: wrll no longer calculate the Oow Jones U.S. Hourly Electricity lndices.
SEHM-
A^ IDACOPP Comprn!
October 14,2013
Oregon Trail Wind Park, LLC - Attn: Sleven Eisenberg
c/o ldaho Wind Partners I, LLC
c/o RPWind ID LLC
P.O. Box 20/;9,82 Elm Street
Manchester City, VT 05255-
Re: Oregon Trail Wind Park
Project Number: 313 15075
NON-IIRM N{ID C ELECTRICITY IN.DEX
PLEASE BE ADVISED: The energy sales agreement between your generation project and Idaho
Power Company provides that in some circumstances the Non-Firm Mid C electricity index energy
values are used to calculate the energy payments for your project. Historically these Non-Firm Mid C
index values have been provided by Dow Jones. Idaho Power received notice regarding is
subscription to the Dow Jones index from McGraw Hill Financial that as of close of business on
Friday, September 13,2013, the Dow Jones index will transition to Platts. Platts now provides the
Non-Firm Mid C electricity index information that wa.s previously provided by Dow Jones. (See
attached notice)
Should you have any questions please contact:
Randy Allphin
Energy Contracts lrader
lda*ro Power Company
(208) 388-2614
E-mail : r'al I p I r i n- (tr ir-laltt,nttwcr.eonr
PO 8or 70 (81707)
EXHIBIT 4 r22r w rdaho 5t
ttorse. lD 83702
r "^ s&P 00wJ0NEs'J lr,totces
I{CGRAW tllU fnAl0nl
e r PLATTS7 Hcsnrw Hru, F*{Ar{crA[
TRANSITION OF THE
DOW JONES U.S. ELECTRICITY INDICES
Transition Highlights
Effective after the close of business on Fridan September 73,2Ot3, Platts, a leading global provider of energy,
petrochemicals, metals and agriculture information, and a premier source of benchmark price assessments for those
commodity markets, will begin providing you with price data that will replace the U,S, electricity prices you currently
receive from S&P Oow Jooes lndices.
As a result, the calculation and dissemination of the Dow Jones U.S. Electricity lndices will transition to Platts. The
following table highlights the changes that will take place as a result of this transition. The full Platts Methodology Guide
is available [er9.
S&P lrorJones lndlces Calculadm
Medmddorv Plrtts Calcuhtion irethodoloty
Dates Prices published on flow date.Prices published on trade date.
Calculatlon
Weighted average index.
Weighted averaBe price assessment with high
correlation to the Dow Jones U.S. Electricity
lndices.
Both firm and non-firm liquidated damages
are calculated.
Both firm and non-firm liquidated damages
will be calculated.
Contributors There is substantial overlap between the contributors to Platts and Dow Jones Electricity
lndices; this ensures ongoing continuity in pricing.
Distribution
r Files will be delivered via the Platts FTP feed in comma separated value (.csv) format
beginning September 13, 2013. There will be no change to file formats.
r Email delivery will continue from September 13 through October 30, 2013 in .csv format.
Email delivery will cease on October 3L, 20L3.
Reminder: as previously announced, effective after the close of business on Friday, August 30, 2013, 5&P Dow Jones
lndices will no longer calculate the Dow Jones U.S. Hourly Electricity lndices.
SIffi*.
An TDACOEF Ccmoany
October l4,2Ol3
Salmon Falls Wind Park, LLC - Attn: Steven Eisenberg
cio Idaho Wind Partners l, LLC
cln RP Wind ID LLC
P.O. Box 2tJ49,82 Elm Street
Manchester Center, VT 05255-
Re: Salmon Falls V/ind
Projcct Number; 3l 6l 8100
NON.FIRM MID C ELECTRICITY INDEX
PLEASE BE ADVISED: The energy sales agreement between your generation project and ldaho
Power Company provides that in some circumstances the Non-Firm Mid C electricity index energy
values are used to calculate the energy payments for your project. Historically these Non-Firm Mid C
index values have been provided by Dow Jones. Idaho Power received notice regarding its
subscription to the Dow Jones index from McGraw Hill Financial that as of close of business on
Friday, September 13,2013, the Dow Jones index will transition to Platts. Platts now provides the
Non-Firm Mid C electricity index informatisn that was previously provided by Dow Jones. (See
attached notice)
Should you have any questions please contact:
Randy Allphin
Energy Contracts Leader
ldaho Power Company
(208) 388-26 r4
E-mail: ntllphtn B idalropou'cr.colll
EXHIBIT 5 eo Bor 70 {83707)
ll21 W ldano 51
Bose. lO 83702
n * s&P 00WJ0NESJ lttorcrs
HcGRtW HU, f ltlAltcl^L
- r PLATTS, HcGnAwHnt Frt{ANclAL
TRANSITION OF THE
DOW JONES U.S. ETECTRICIW INDICES
Iransition Highlights
Effective after the close of business on Friday, September L3,2OL3, Platts, a leading global provider of energy,
petrochemicals, metals and agriculture information, and a premier source of benchmark price assessrnents for those
commodity markets, will begin providing you with price data that wlll replace the U.S. electricity prices you currently
receive from S&P Dow Jones lndices.
fu a result, the calculation and dissemination of the Dow Jones U.S" Electricity lndices will transition to Platts, The
following table highlights the changes that willtake place as a resuh of this transition. The full Platts Methodology Guide
is ava.1!a_ble f1e;s.
S&P tlowronec lndlces Calculdlon
Methodolorv Platts CalculaUon Methodology
Dates Prices published on flow date.Prices published on trade date.
Calculatlon
Weighted average index.
Weighted average price assessment with high
correlation to the Dow Jones U.5. Electricity
lndices.
Both firm and non-firm liquidated damages
are calculated.
Both firrn and non-firm liquidated damages
will be calculated.
Contributors There is substantial overlap between the contributors to Ptatts and Dow Jones Electricity
lndices; this ensures ongoing continuity in pricing.
Distribution
o Files wilt be delivered via the Platts FTP feed in cornma separated value (.csv) format
beginning September 13, 2013. There will be no change to file formats.
r Email delivery will continue from September 13 through October 30, 2O13 in .csv format.
Email delivery will cease on October 31, 2013.
Reminder: as previously announced, effective after the close of business on Friday, August 30, 2013, S&P Dow lones
lndices wrll no longer calculate the Dow lones U.S. Hourly Electricity lndices.
<lHm.
A. ,[-1ACOPP Company
October 14,2013
Thousand Springs Wind Park, LLC - Attn Steven Eisenberg
c/o Idaho Wind Partners l, LLC
c/o RP Wind ID L.LC
P.O. Box 20/19,82 Elm Street
Manchester Center, VT 05255-
Re: Thousand Springs Wind Park
Project Nunrber: 3 l3 15055
NON.FIRM MID C EI,ECTRICITY INDEX
PLEASE BE ADVISED: The energy sales agreement between your generation project and Idaho
Power Company provides that in some circumstances the Non-Firm Mid C electricity index energy
values are used to calculate the energy payments for your proiect. Historically these Non-Firm Mid C
index values have been provided by Dow Jones. Idaho Power received notice regarding its
subscription to the Dow Jones index from McGraw Hill Financial that as of close of business on
Friday, September 13,2013, the Dow Jones index will transition to Platts. Platts now provides the
Non-Firm Mid C electricity index infbrmation that was previously provided by Dow Jones. (See
attached notice)
Should you have any questions please contact:
Randy Allphin
Energy Contracts kader
Idaho Power Company
(208) 388-2614
E-mail: t'rllphinQ' idahopowcr.cttttt
e() Box ;t0 (83/07)
l2?t W ldaho 5t.
8oira, lD 8f702
EXHIBIT 6
't A S&P OOWJONESJ rxorcrs
ilcGiAlt lllLl tlflAtlDllt
. r PLATTS7
"ran^t,
Hrtt flN,r,.crAl
TRANSITION OF THE
DOW JONES U.S. TLECTRICITY INDICES
Transition Highlights
Effective after the close of business on Friday, Scptember L3,?xJ'L}, Platts, a leading global provider of energy,
petrochemicals, metals and agriculture information, and a premier source of benchmark price assessments for those
commodity markets, will begin providing you with price data that will replace the U.5. electricity prices you currently
receive from S&P Dow Jones lndices.
As a result, the calculation and disseminatlon of the Dow Jones U.S. Electricity lndices will transition to Platts. The
following table hiBhlights the changes that will take place as a resuh of this transition. The full Platts Methodology Guide
is av.arlable-here.
S&P Do$Joms lndlccs CCculrtlon
MetAodolorv Platts f,atculadon Methodology
Dates Prices published on flow date.Prices published on trade date.
Calculation
Weighted average index.
Weighted average price assessment with high
correlation to the Dow Jones U.S. Electricity
lndices.
Both firm and non-firm liquidated damages
are calculated.
Both firm and non-firm liquidated damages
will be calculated.
Contributors There is substantial overlap between the contributors to Platts and Dow Jones Electricity
lndices; this ensures onSoing continuity in pricing.
Distribution
r Files will be delivered via the Platts FTP feed in comma separated value (.csv) format
beginning September 13, 2013. There will be no change to file formats,
r Email delivery will continue from September 13 through October 30, 2013 in .csv format.
Email delivery will cease on October 31, 2013.
Reminder: as previously announced, effective after the close of businers on Friday, August 30, 2013, S&P Dow Jones
lndices will no longer calculate the Dow lones U.S. Hourly Electricity lndices.
KIffi*.
Ar iDAC-ORF COmBanV
October 14,2013
Burley Butte Wind Park, LLC - Attn: Steven Eisenberg
c/o Idaho Wind Partners I, LLC
c/o RP Wind ID LLC
P.O. Box 20/9 82 Ehn Street
Manchester Center, VT 05255-
Re: Burley Butte Wind Park
Project Numbcr: 317 651'10
NON.flRM MID C ELECTRICITY INDEX
PLEASE BE ADVTSED: The energy sales agreement between your generation project and ldaho
Power Company provides that in some circumstances the Non-Firm Mid C electricity index energy
values are used to calculate the energy payments for your project. Historically these Non-Firm Mid C
index values have been provided by Dow Jones. Idaho Power received notice regarding its
subscription to the Dow Jones index from McGraw Hill Financial that as of close of business on
Friday, September 13,2013, the Dow Jones index will transition to Platts. Platts now provides the
Non-Firm Mid C electricity index information that was previously provided by Dow Jones. (See
attached notice)
Should you have any questions please contact:
Randy Allphin
Energy Contracts Leader
Idaho Power Company
(208) 388-2614
E-mail: ral Inlri n (t' idahr.rnorr cr.c(1tIl
EXHIBIT 7 :;,,ff Ili'Jf,
Borse. l0 81702
'! f, s&P 00WJ0NESJ norcrs
HGGRAW (ll,t Flil fCUr
c r PLATTS7 H.enrw r,tr FHTHcTAL
TRANSITION OF THE
DOW JONES U.S. ELECTRICIW INDICES
lransition Highlights
Effective after the close of business on Friday, September I.3,ZOt3., Platts, a leading global provider of energy,
petrochemicals, metals and agriculture information, and a premier source of benchmark price assessments for those
commodity markets, will begin providing you with price data that will replace the U.S. electricity prices you currently
receive from S&P Dow Jones lndlces.
As a result, the calculation and dissemination of the Dow lones U.S. Electricity lndices will transition to Platts, The
following table highlights the changes that will take place as a resuh of this transition. The full Platts Methodology Guide
is aya.rlable_here.
S&P llow loncs lndices Calculatlon
Medroddocv PlatB C..lculatlon Methodoloty
Dates Prices published on flow date.Prices published on trade date.
Calculadon
Weighted average index.
Weighted average price assessment with high
correlation to the Dow Jones U.S. Electricity
lndices.
Both firm and non-firm liquidated damages
are calculated.
Both firm and non-firm liquidated damages
will be calculated.
Contributors There is substantial overlap between the contributors to Platts and Dow Jones Electricity
lndices; this ensures ongoing continuity in pricing.
Distribution
. Files will be delivered via the Platts FTP feed in comma separated value (.csv) format
beginning September 13, 2013. There will be no change to file formats.
r Email delivery will continue from September 13 through October 30, 2013 in .csv format.
Email deliverv will cease on October 31, 2013.
Reminder: as previously announced, effective after the close of business on Friday, August 30, 2013, 5&P Dow Jones
lndices will no longer calculate the Dow Jones U.S. Hourly Electricity lndices.
fiTffiM-
$r ItIACOPP CCrnDAny
October 14,2013
Pilgrim Stage Station Wind Pa*, LLC - Attn: Steven Eisenberg
clo ldaho Wind Partners l, LLC
c/o RP Wind ID LLC
P.O. Box 2M9,82 Elm Street
Manchester Center, YT 05255-
Re: Pilgrim Stage Station Wind Park
Project Number: 31315045
NON.FIRM MID C ELECTRICITY INDEX
PLEASE BE ADVISED: The energy sales agreement between your generation project and Idaho
Power Company provides that in some circumstances the Non-Firm Mid C electricity index energy
values are used to calculate the energy payments for your project. Historically these Non-Firm Mid C
index values have been provided by Dow Jones. Idaho Power received notice regarding its
subscription to the Dow Jones index from McGraw Hill Financial that as of close of business on
Friday, September 13,2013, the Dow Jones index will transition to Platts. Platts now provides the
Non-Firm Mjd C elecricity index information that was previously provided by Dow Jones. (See
attached notice)
Should you have any questions please contact:
Randy Allphin
Energy Contracts Leader
Idaho Power Company
(208) 388-2614
E-mail : rdlhiti n-g:idithsplnI!]-cltr]r
F.0 Bor ?C (8J707)
1?? ! W. ldsho 5t
So,!e. l0 8170,
EXHIBIT 8
s a s&P 00wJ0NESJ ttrorces
HcGiAW t0!i, flN ilCl t,
a r PLATTS7 t{.snrw xrLr, FrttAt crtl
TRANSITION OF THE
DOW JONES U.S. ELECTRICITY INDICES
Transition Highlights
Effective after the close of business on Friday, September 13, 2013, Platts, a leading global provider of energy,
petrochemicals, metals and agriculture information, and a premier source of benchmark price assessments for those
commodity markets, will begin providing you with price datb that will replace the U,S. electricity prices you currently
receive from S&P Dow Joncs lndices.
As a result, the calculation and dissemination of the Dow Jones U.S. Electricity lndices will transition to Platts. The
following table highlights the changes that will take place as a result of this transition. The full Platts Methodology Guide
is ayatl-a-bleierc.
S&P Don Joncs lndlces Galculgtlon
Metffiloev Platts Calculadon Methodology
Dates Prices published on flow date.Prices published on trade date.
Calculatlon
Weaghted average index.
Weighted average price assessment with high
correlation to the Dow Jones U,S. Electricity
lndices.
Both firm and non-firm liquidated damages
are calculated.
Both firm and non-firm liquidated damages
will be calculated.
Contributors There is substantial overlap between the contributors to Platts and Dow Jones Electricity
lndices; this ensures ongoing continuity in pricing.
OBtribution
o Files will be delivered via the Platts FTP feed in comma separated value (.csv) format
beginning September 13, 2013. There will be no change to file formats.
o Email delivery will continue from September 13 through October 30, 2013 in .csv format.
Emall delivery will cease on October 31, 2013.
Reminder: as previously announced, effective after the close of business on Friday, August 30, 2013, 5&P Dow Jones
Indices will no longer calculate the Dow Jones U.S. Hourly Electricity lndices.