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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.