20161018Settlement Comments.pdf

LISA D. NORDSTROM
Lead Counsel
[e-mail]
October 18, 2016
VIA HAND DELIVERY
Jean D. Jewell, Secretary
Idaho Public Utilities Commission
472 West Washington Street
Boise, Idaho 83702
Re: Case No. IPC-E-16-14
New Tariff Schedule 63, A Community Solar Pilot Program
Idaho Power Company's Comments
Dear Ms. Jewell:
An IDACORP company
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Enclosed for filing in the above matter are an original and seven (7) copies of Idaho
Power Company's Comments in support of the Settlement Stipulation filed in this matter on
September 26, 2016.
Very truly yours,
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Enclosures
LISA D. NORDSTROM (ISB No. 5733)
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
[e-mail]
Attorney for Idaho Power Company
RE CEIVED
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER )
COMPANY'S APPLICATION TO )
APPROVE NEW TARIFF SCHEDULE 63, )
A COMMUNITY SOLAR PILOT )
PROGRAM. )
)
----------------)
CASE NO. IPC-E-16-14
IDAHO POWER COMPANY'S
COMMENTS IN SUPPORT OF
SETTLEMENT
Idaho Power Company ("Idaho Power" or "Company"), by and through its
undersigned attorney, hereby submits to the Idaho Public Utilities Commission
("Commission") these comments in the above-captioned proceeding. The Company's
comments are organized as follows:
Section I -provides the procedural background in the case;
Section II -summarizes the Company's original filing;
Section Ill -identifies the three primary issues addressed by Commission Staff
("Staff') and intervening parties in comments filed in this case;
Section IV -details how the proposed Stipulation resolves the issues identified in
the initial comments, and the Company's rationale for agreeing to the modifications; and
IDAHO POWER COMPANY'S COMMENTS IN SUPPORT OF SETILEMENT - 1
Section V -summarizes why the proposed Stipulation is in the public interest
and should be approved.
I. BACKGROUND
On June 22, 2016, Idaho Power filed an Application requesting that the
Commission approve new tariff Schedule 63, A Community Solar Pilot Program
("Program").
On July 7, 2016, the Commission issued a Notice of Intervention Deadline in
Order No. 33552, setting forth a deadline for intervention 14 days from its issuance.
Petitions to Intervene were filed by the Idaho Conservation League ("ICL"), the Industrial
Customers of Idaho Power ("ICIP"), the Idaho Irrigation Pumpers Association ("IIPA"),
Snake River Alliance ("SRA"), Sierra Club, and the City of Boise, all of which were
granted in Order Nos. 33552, 33557, 33560, and 33562, respectively.
On August 16, 2016, the Commission issued a Notice of Modified Procedure in
Order No. 33569, setting the date of August 23, 2016, for an initial settlement
discussion and establishing a comment deadline of September 1, 2016, and a reply
comment deadline of September 14, 2016. Parties to this case convened on August 23,
2016, for the initial settlement conference. While a settlement agreement was not
reached at that time, the parties agreed to proceed with the initial September 1, 2016,
comment deadline, but also agreed to schedule a second settlement conference for
September 9, 2016. Comments were then filed by ICL on August 31, 2016, and by
Staff, ICIP, SRA, and Sierra Club on September 1, 2016.
On September 9, 2016, parties to this case (with the exception of IIPA)
reconvened for the second scheduled settlement conference that resulted in the
following settlement of issues related to the Company's application in this docket. As a
IDAHO POWER COMPANY'S COMMENTS IN SUPPORT OF SETILEMENT - 2
result of this agreement, Staff submitted a Decision Memorandum to the Commission
for the September 12, 2016, Decision Meeting, requesting to suspend the September
14, 2016, reply comment deadline, which the Commission approved in Order No.
33598. Idaho Power then filed the agreed upon Stipulation and corresponding Motion
to Approve on September 16, 2016. The Stipulation was entered into by Idaho Power,
Staff, ICL, ICIP, IIPA, SRA, Sierra Club, and the City of Boise, hereafter referred to
jointly as "Parties."
II. SUMMARY OF ORIGINAL APPLICATION AND TESTIMONY
In its initial Application and testimony, Idaho Power requested that the
Commission authorize the implementation of a voluntary Community Solar Pilot
Program ("Program") that would allow a limited number of Idaho Power's Idaho
customers the opportunity to voluntarily subscribe to the generation output of a solar
array. Participating customers would be required to pay a one-time upfront Subscription
Fee ("Subscription Fee") and in return would receive a monthly bill credit ("Solar Energy
Credit") for their proportional output of the energy produced from the array.1 The
Company proposed to open the Program to Residential, Commercial, Industrial,
Irrigation, and Special Contract customers receiving service under Idaho Rate Schedules:
01, 05, 07, 09, 19, 24, 26, 29, and 30.2
The Company chose to offer the Program based on interest from some customers
who had expressed the desire to have a portion or all of their energy supplied from
renewable resources, specifically solar. For many customers, direct ownership and
operation of a solar resource is not desirable or feasible. Barriers include: upfront capital
1 Application, p. 1
2 Pengilly Direct Testimony, p. 3
IDAHO POWER COMPANY'S COMMENTS IN SUPPORT OF SETTLEMENT -3
costs, customers who reside in rental properties or multi-unit dwellings, as well as
customers who have aging rooftops, shading, or unsuitable rooftop orientation. The
Company's proposed Community Solar Pilot Program was designed as an alternative for
customers who fall into the various categories mentioned above.3
The Company intended for this initial offering to be treated as a pilot program to
allow the Company to learn about the complexities associated with offering community
solar programs including: customer commitment, construction, contracting,
interconnection, maintenance, and billing. The Program was designed as a new option in
response to some customers' preference for renewable energy options, serving to inform
the consideration of potential expanded offerings in the future.4
Because the Company does not currently have a load-serving need for the
proposed solar resource, the overall Program design was intended to result in Program
participants ("Participants") covering the full cost of the project (less a 15 percent
shareholder subsidy) with nominal impact to non-participating customers assuming full
Program subscription.5
The Company proposed a cost-based method of pricing whereby the Company
set the Subscription Fee for Participants to reflect the cost to construct the solar facility,
less the IDACORP shareholder contribution of 15 percent, plus interconnection costs as
well as ongoing costs such as operations and maintenance expense and property tax.
Estimated incremental costs associated with marketing the Program were incorporated
3 Larkin Direct Testimony, p. 4
4 Pengilly Direct Testimony, p. 4
5 Larkin Direct Testimony, pp. 5-6
IDAHO POWER COMPANY'S COMMENTS IN SUPPORT OF SETTLEMENT -4
into the Subscription Fee as well.6 The Subscription Fee also reflected the benefit of
the federal investment tax credits ("ITC"), thereby reducing the overall fee amount.
Under current law, the 30 percent ITC for eligible facilities will be available through 2019
and be subject to normalization, as required for public utilities by the Internal Revenue
Code. 7 Based on the costs and benefits identified above, the proposed Subscription
Fee was $740 for the equivalent of a 320-watt panel.8
In return for the $740 upfront Subscription Fee, Participants would be eligible to
receive a Solar Energy Credit on their monthly bill based on the actual energy output of
the array throughout the 25-year life of the Program. The forecast annual energy per
Subscription was approximately 638 kilowatt-hours ("kWh").9
The Company proposed a Solar Energy Credit based on Idaho Power's
embedded energy-related costs as determined by the most recently reviewed class
cost-of-service methodology filed in Case No. IPC-E-11-08, adjusted to reflect revenue
requirement changes that were subsequently authorized by the Commission that
impacted the authorized level of energy-related cost recovery.10 In addition, the
Company proposed to update the Solar Energy Credit as needed based on changes to
its embedded energy-related costs recovered through base rates throughout the life of
the Program.11
6 Larkin Direct Testimony, pp. 6-7
7 Larkin Direct Testimony, p. 8
8 Larkin Direct Testimony, p. 10
9 Application, pp. 9-10
10 Larkin Direct Testimony, p. 12
11 Larkin Direct Testimony, p. 14
IDAHO POWER COMPANY'S COMMENTS IN SUPPORT OF SETTLEMENT - 5
The Company's proposed Solar Energy Credit was based on the premise that
providing participants with a bill credit based on embedded energy costs would reflect
the concept that Participants are choosing to subscribe to the community solar facility
for a portion of their electricity rather than receiving electricity generated from the
Company's overall system resources.12 This embedded cost methodology would
ensure that participating customers are able to offset the energy-related portion of base
rates, while still contributing to the recovery of fixed costs related to infrastructure
needed to serve all customers, as well as other non-variable costs such as customer
service and billing.13
Ill. SUMMARY OF ISSUES RAISED IN COMMENTS
Comments in response to the Company's initial proposal were filed by ICL on
August 31, 2016, and by Staff, ICIP, SRA, and Sierra Club on September 1, 2016,
Uointly referred to as "Commenting Parties"). While each set of comments was
generally supportive of the Company's effort to offer such a program, two issues were
consistently raised by the Commenting Parties: ( 1) Subscription Fee payment options 14
(i.e., lack of options in addition to the one-time upfront fee), and (2) the valuation of the
Solar Energy Credit.15 A third issue identified, by a number of parties, was the concept
12 Larkin Direct Testimony, p. 13
13 Larkin Direct Testimony, pp. 13-14
14 Staffs Initial Comments, p. 4; Sierra Club's Initial Comments, p. 4; SRA's Initial Comments, p. 2;
ICL's Initial Comments, pp. 2-3
15 Staffs Initial Comments, p. 7; ICIP's Initial Comments, pp. 4-5; Sierra Club's Initial Comments, p. 2;
SRA's Initial Comments, pp. 2-3, ICL's Initial Comments, pp. 6-11
IDAHO POWER COMPANY'S COMMENTS IN SUPPORT OF SETTLEMENT - 6
of a transmission and distribution ("T&D") deferral benefit as a result of building the
solar array close to load.16
A. Subscription Fee Payment Options
In its comments, Staff stated that the $740 upfront Subscription Fee would likely
be a significant hurdle for residential customers interested in participating.17 Staff
referenced Avista's Community Solar Program that included a relatively high upfront fee
of $1,400, which negatively impacted participation even with a payback period of 3.75
years.18 As a result, Staff recommended that Idaho Power provide 12 and 24-month
payment options in addition to the upfront option to make participation more attainable
for residential customers.19 ICL, SRA, and Sierra Club all voiced similar concerns with
the Company's proposal and believed that the $7 40 upfront Subscription Fee would be
a barrier to participation in the Program, and if left unaddressed would result in its failure
due to lack of participation.20
B. Solar Energy Credit
The Commenting Parties all provided feedback on the Company's proposed
methodology for the Solar Energy Credit that Participants would receive in return for the
Subscription Fee. Each set of comments opposed the Company's proposal to use the
embedded cost-of-service methodology for determining the Solar Energy Credit. The
16 Staffs Initial Comments, p. 9; Sierra Club's Initial Comments, p. 3; SRA's Initial Comments, p. 4
17 Staffs Initial Comments, p. 4
18 Id.
19 Id.
20 ICL's Initial Comments, p. 2; SRA's Initial Comments, p. 2; Sierra Club's Initial Comments, p. 4
IDAHO POWER COMPANY'S COMMENTS IN SUPPORT OF SETILEMENT - 7
Commenting Parties expressed concern with regard to the model's accuracy,21
complexity,22 length of time between updates,23 perceived lack of transparency,24 and
general suitability for use as a method to determine an appropriate solar credit.25
Alternatively, the Commenting Parties collectively recommended using the
Company's Demand Side Management ("DSM") Alternate Costs identified in the 2015
Integrated Resource Plan, Appendix C -Technical Report, pp. 75-77 ("DSM Alternate
Costs") in lieu of the Company's cost-of-service approach.26 The Commenting Parties'
justification for recommending the DSM Alternate Costs included transparency,27 the
non-controversial nature of these values,28 a consistent schedule for updating every two
years,29 and the resulting reduction to the payback period making it more likely that the
Program would be successful.30 The Commenting Parties also supported the use of the
DSM Alternate Costs based on the belief that they appropriately value the power
generated by the community solar array by reflecting the marginal resource the
Company would offset through production at the solar facility.31
21 Staffs Initial Comments, p. 5; ICL's Initial Comments, p. 6; Sierra Club's Initial Comments, p. 2
22 ICL's Initial Comments, p. 9
23 Staff's Initial Comments, p. 8; ICL's Initial Comments, p. 10; ICIP's Initial Comments, p. 3
24 ICL's Initial Comments, p. 9
25 Staffs Initial Comments, p. 5; ICIP's Initial Comments, p. 4
26 Staffs Initial Comments, p. 7; ICIP's Initial Comments, p. 4; Sierra Club's Initial Comments, p. 2;
ICL's Initial Comments, p. 7; SRA's Initial Comments, p. 4
27 Staff's Initial Comments, p. 8; ICL's Initial Comments, p. 9
28 Staffs Initial Comments, p. 8; ICIP's Initial Comments, p. 4
29 Staffs Initial Comments, p. 8; ICIP's Initial Comments, p. 4; ICL's Initial Comments, p. 5
30 Staff's Initial Comments, p. 9; ICIP's Initial Comments, p. 5; Sierra Club's Initial Comments, p. 3
IDAHO POWER COMPANY'S COMMENTS IN SUPPORT OF SETILEMENT -8
C. T&D Deferral Benefit
Commission Staff, Sierra Club, and SRA also discussed the concept that certain
site locations for the array may defer or reduce the use of the transmission and/or
distribution system; therefore, the benefit of such reductions should be included in the
Solar Energy Credit. 32
IV. SETTLEMENT STIPULATION
After reviewing comments filed on August 31, 2016, and September 1, 2016,
Parties (with the exception of IIPA) reconvened on September 9, 2016, to further discuss
the possibility of settlement. As a result of this meeting, Parties reached an agreement-in­
principle, which ultimately led to the filing of the signed Stipulation on September 26, 2016.
The terms of the agreement as set forth in the proposed Stipulation represent a
reasonable compromise among differing points of view. Concessions were made by each
of the Parties to strike an appropriate balance between the interests of the Company, its
customers, and the Settlement signators.
The proposed Stipulation modifies the Company's original request, as detailed in
the June 22, 2016, Application, by providing: (1) the Subscription Fee, originally
proposed at $740, will be lowered to $562 as a result of three adjustments which are
discussed in more detail below, and (2) the Company will offer a 24-month option to
residential customers who wish to pay for their Subscription Fee over time rather than
upfront, as well as a "Bill Me Later'' option that will provide for additional forms of upfront
payment.
31 SRA's Initial Comments, p. 4; ICL's Initial Comments, p. 7
32 Staff's Initial Comments, p. 9; Sierra Club's Initial Comments, p. 3; SRA's Initial Comments, p. 4
IDAHO POWER COMPANY'S COMMENTS IN SUPPORT OF SETTLEMENT - 9
A. Subscription Fee
Originally proposed to be $740, the Subscription Fee will be lowered to $562 to
reflect three modifications: (1) a reduction reflecting the present value of the
incremental difference between the DSM Alternate Costs and projected embedded
energy costs, (2) a reduction reflecting the present value of the projected deferral of
T&D investments for the 25-year life of the project, and (3) a reduction reflecting the
removal of the cost of the smart inverter from the Subscription Fee calculation. Each of
these adjustments ( collectively the "Rate Base Amounts") and the underlying rationale
is described in detail below.
1. Recognition of DSM Alternate Costs
As detailed in Section Ill above, the Commenting Parties collectively
recommended that the Solar Energy Credit should reflect the DSM Alternate Costs.
However, the Company believes that the embedded cost of energy rate is an important
aspect of the original proposal because it aligns with actual energy-related costs
included in base rates and acts as a hedge against future energy-related price changes
for the 25-year term of the Program. In the spirit of settlement and to resolve this issue,
the Parties agreed to reduce the Subscription Fee by the present value of the
incremental difference between the DSM Alternate Costs and projected embedded
energy costs over the life of the Program.
The Company believes this adjustment represents a reasonable compromise
between holding non-participating customers harmless while providing reasonable
compensation to Participants for their subscribed portion of the solar generation. While
the Company initially proposed to allow Participants to offset the embedded energy
IDAHO POWER COMPANY'S COMMENTS IN SUPPORT OF SETTLEMENT -10
costs currently authorized for recovery through rates, the Stipulation effectively
compensates Participants at a proxy for the marginal cost of energy, as determined by
the DSM Alternate Cost methodology. This methodology is intended to recognize Idaho
Power's economic dispatch of its resources by assuming that the generation provided
by the solar facility will offset system costs based on the marginal resource in each
hour, rather than at the average cost of all resources. The Company believes this
methodology is appropriate for use in this pilot as it reflects a reasonable assumption of
costs that may actually be offset by the generation of the solar facility.
Reducing the upfront cost, which was seen by the Commenting Parties as a
significant barrier to participation, may also allow for increased participation in the
Program. By providing the financial benefit associated with the difference between
embedded energy costs and DSM Alternate Costs as a reduction in the upfront
Subscription Fee, the stipulated methodology provides reasonable compensation to
Participants while simultaneously addressing a primary concern of the Commenting
Parties in this case.
Another key advantage to the stipulated compensation methodology is retaining
the direct link between the per-kWh Solar Energy Credit and the level of energy-related
costs embedded in all customers' rates. This link is important to Participants as it
serves as a hedge to changes in electricity prices, i.e., when energy costs increase the
Solar Energy Credit increases, with the opposite occurring when costs decrease. For
non-participants, the connection between the Solar Energy Credit and retail rates is also
important, as it ensures that over time Participants will be credited at a rate
commensurate with what all customers pay through retail rates, thereby limiting the
IDAHO POWER COMPANY'S COMMENTS IN SUPPORT OF SETTLEMENT -11
potential for cost shifting between Participants and the Company's general body of
customers.
2. T&D Deferral Adjustment
The second adjustment represents the present value of the projected deferral of
T&D investments for the 25-year life of the project, as determined by the Company's
recently completed study that was presented to the Energy Efficiency Advisory Group
on August 30, 2016. This is an acceptable adjustment because regardless of the
location of the subscribers, the community solar plant generation output would be
consumed locally on the interconnected distribution feeder.33 This adjustment utilizes
the Company's analysis as the basis for estimating what costs, if any, are potentially
avoided at the transmission and distribution level, and addresses the concerns voiced in
initial comments regarding the absence of a T&D deferral in the Company's initial
calculations. Given the modest level of the stipulated adjustment (a $4,622 net impact
to the overall cost of the project) and the use of Idaho Power's study as the basis for
this adjustment, the Company believes the stipulated T&D deferral appropriately
recognizes the potential T&D benefits offered by a solar facility without unduly
compensating Participants at the expense of non-participating customers.
3. Smart Inverter Cost Removal
The third adjustment represents the removal of the cost of the smart inverter
from the total project cost used to determine the Subscription Fee. Idaho Power agreed
to this adjustment as it intends for this initial offering to be treated as a pilot and expects
to gain experience controlling the smart inverter to the benefit of all customers. As
detailed in the direct testimony of Company witness Dave Angell, the Company
33 Idaho Power's Response to ICL's Request No. 14
IDAHO POWER COMPANY'S COMMENTS IN SUPPORT OF SETTLEMENT -12
specified the installation of a four quadrant remotely configurable inverter, also known
as a smart inverter. By gaining experience in advance of the potential integration of
additional solar facilities on the distribution system, the Company will possess the
knowledge necessary to avoid the voltage management issues that other electric
utilities have experienced due to increased solar adoption. The result of controlling the
inverter and gaining this knowledge and experience will ultimately benefit all
customers. 34
4. Rate Base Recovery and Customer Impact
The Parties agreed that Idaho Power should be allowed to include in rate base
and collect 100 percent of the revenue requirement associated with the Rate Base
Amounts, as detailed in Attachment 3 to the Stipulation. The Rate Base Amounts
reflect a quantification of the various benefits that the community solar array will bring to
the system to the benefit of all customers. If approved, the annual revenue requirement
amounts, as detailed in Attachment 3 to the Stipulation, will be included as part of the
Company's Power Cost Adjustment ("PCA") filing in April of each year until the
Company resets its base rates in a future general rate case proceeding. Once the Rate
Base Amounts associated with the Program have been incorporated into the
Company's overall rate base through a general rate proceeding, the Company will
remove associated amounts from its PCA rates and no longer include the related
revenue requirement in subsequent PCA filings.
The Company believes the stipulated rate base methodology appropriately aligns
cost recovery of the Program with the group of customers that stands to benefit from
each component. Under this method, Participants will fund the majority of the Program
34 Angell Direct Testimony, p. 13
IDAHO POWER COMPANY'S COMMENTS IN SUPPORT OF SETILEMENT -13
cost through the Subscription Fee, with the exception of the three Rate Base Amounts
detailed above. Recovery of the Rate Base Amounts from all of the Company's
customers is appropriate because each of these items represents a benefit provided to
the Company's overall electrical system; the use of the DSM Alternate Costs is intended
to capture the energy-related costs avoided through the solar production, the T&D
deferral adjustment is intended to capture the potential deferral of investment in the
T&D system, and the removal of the smart inverter cost from the Subscription Fee
recognizes that the knowledge and experience the Company will gain in using this
equipment will benefit all customers. Through the stipulated methodology, the recovery
of the three Rate Base Amounts from all customers is appropriate as the level of
recovery is commensurate with the system benefits expected to be provided by the
solar facility.
B. Monthly Fee Option
The Company originally proposed that customers would be required to pay a
one-time upfront Subscription Fee to participate in the Program. The Company felt that
the financial risk for non-participants and the Company would be too great under a
monthly payment option if panels went unsubscribed throughout the life of the Program.
Under a monthly payment option, if customers were to drop out of the Program
prematurely, the remaining unpaid portion of the subscription would be borne by the
Company and/or non-participating customers.35 Under the Company's original
proposal, this risk does not exist.
35 Larkin Direct Testimony, p. 11
IDAHO POWER COMPANY'S COMMENTS IN SUPPORT OF SETTLEMENT-14
In response to the Commenting Parties' concerns regarding the lack of Subscription
Fee payment options, the Company will now offer residential participants a 24-month fee
option in addition to the upfront payment option detailed in its initial filing. The Company
will also offer a "Bill Me Later" option that will allow Participants to pay the upfront
Subscription Fee within 30 days of signing up through various payment options, further
expanding the methods by which potential Participants can provide payment. In
recognition of the costs associated with the offering of a monthly option, the Parties agreed
that the 24-month fee option will include a carrying charge,36 as well as an administration
charge to reflect the costs of administering this monthly option, such as billing and other
required customer service functions. In addition, the Parties agreed that if Participants
elect to utilize the 24-month fee option and fail to complete all 24 payments or request an
eligible subscription transfer, Idaho Power will utilize a waitlist if customer interest has
exceeded the amount of available subscriptions. If the waitlist is exhausted and
outstanding subscriptions still exist, an as-yet to be identified third-party will cover the
unpaid amounts to Idaho Power in exchange for the corresponding subscription(s). If
the Company's waitlist is exhausted and no third-party agrees to indemnify Idaho
Power, the Parties agree that Idaho Power should be authorized to recover 100 percent
of the unpaid subscription amounts in the next year's PCA. In this event, ownership of
the associated subscriptions would remain with Idaho Power and the net power cost
benefits would automatically flow through the PCA to the benefit of all customers.
36 The carrying charge is set at the Company's current Allowance for Funds Used During
Construction (AFUDC) rate. Settlement Stipulation, p. 5.
IDAHO POWER COMPANY'S COMMENTS IN SUPPORT OF SETILEMENT -15
The addition of these payment options is intended to address the concerns
voiced by the Commenting Parties regarding the ability to generate sufficient customer
participation. The additional options provided under the stipulated methodology strike a
balance between lowering hurdles for Participants while limiting the risk to the Company
and non-participating customers associated with unsubscribed amounts. The Company
believes that the risk mitigation terms contained in the Stipulation appropriately address
the Company's concerns in offering a monthly payment option, and limit the potential for
unsubscribed costs to flow through to the Company or its customers.
V. SETTLEMENT IS FAIR, JUST, AND REASONABLE
AND IN THE PUBLIC INTEREST
The Company believes that the proposed Stipulation is a reasonable resolution
of the issues and is in the public interest. The Program is the direct result of some
customers expressing their desire for additional choices when it comes to renewable
energy. By offering access to community solar on a pilot basis, the Company hopes to
expand the renewable energy options available to those customers that are interested
in supporting solar energy. The issues identified by the Parties and resolved through
the Stipulation make the Program more attractive and more economical to potential
Participants while maintaining a Program structure that minimizes the potential impact
to non-participating customers and Company shareholders.
The Company would like to acknowledge its appreciation for the willingness by
the Commission Staff and other parties to consider and discuss the merits of the
Company's Application and to reach mutually agreeable terms for the pilot Program.
IDAHO POWER COMPANY'S COMMENTS IN SUPPORT OF SETTLEMENT -16
For all of the reasons presented in these comments, Idaho Power urges the
Commission to adopt the Stipulation submitted in this proceeding as filed, without
modification, and to issue an order authorizing the terms of the Stipulation. The
Company respectfully requests that the Commission issue an order in a timeframe that
will allow the Company to launch its marketing campaign prior to the holiday season.
DATED at Boise, Idaho, this 18th day of October 2016.
~R '!fi:~~ LISA. NORDSTR
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S COMMENTS IN SUPPORT OF SETILEMENT -17
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 18th day of October 2016 I served a true and
correct copy of IDAHO POWER COMPANY'S COMMENTS IN SUPPORT OF
SETTLEMENT upon the following named parties by the method indicated below, and
addressed to the following:
Commission Staff
Daphne Huang
Deputy Attorney General
Idaho Public Utilities Commission
472 West Washington (83702)
P.O. Box 83720
Boise, Idaho 83720-0074
Idaho Conservation League
Benjamin J. Otto
Idaho Conservation League
710 North Sixth Street
Boise, Idaho 83702
Industrial Customers of Idaho Power
Peter J. Richardson
Gregory M. Adams
RICHARDSON ADAMS, PLLC
515 North 27th Street (83702)
P.O. Box 7218
Boise, Idaho 83707
Dr. Don Reading
6070 Hill Road
Boise, Idaho 83703
Idaho Irrigation Pumpers Association, Inc.
Eric L. Olsen
ECHO HAWK & OLSEN, PLLC
505 Pershing Avenue, Suite 100
P.O. Box 6119
Pocatello, Idaho 83205
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IDAHO POWER COMPANY'S COMMENTS IN SUPPORT OF SETTLEMENT -18
Anthony Yankel
12700 Blake Avenue, Unit 2505
Lakewood, Ohio 44107
Snake River Alliance
Ken Miller, Energy Program Director
Snake River Alliance
223 North Sixth Street, Suite 317
P.O. Box 1731
Boise, Idaho 83701
Sierra Club
Zack Waterman
Director, Idaho Sierra Club
503 West Franklin Street
Boise, Idaho 83702
Michael Heckler
3606 North Prospect Way
Garden City, Idaho 83714
City of Boise City
Elizabeth A. Koeckeritz
Deputy City Attorney
Boise City Attorney's Office
150 North Capitol Boulevard
P.O. Box 500
Boise, Idaho 83701-0500
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IDAHO POWER COMPANY'S COMMENTS IN SUPPORT OF SETTLEMENT -19