20170427Comments.pdf

,' : -':il';i)BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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IN THE MATTER OF THE PETITION OF
IDAHO POWER COMPANY FOR A
DECLARATORY ORDER REGARDING
PROPER CONTRACT TERMS,
CONDITIONS, AND AVOIDED COST
PRICING FOR BATTERY STORAGE
FACILITIES
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CASE NO. IPC-E-17'.01
STAFF COMMENTS
On February 27,2017,Idaho Power Company filed a petition asking the Commission
to issue a declaratory order regarding proper contract terms, conditions, and avoided cost pricing
for five battery storage facilities requesting contracts under the Public Utility Regulatory Policies
Act of 1978 (PURPA). The Commission issued a Notice of Petition and Notice of Modified
Procedure, setting deadlines for the battery storage facilities, affected utilities, Staff, and any
interested persons to file comments on the matter. Order No. 33729. The Commission granted a
joint petition to intervene by Sierra Club and Idaho Conservation League. Order No. 33743.
The battery storage facilities submitted timely comments per Order No. 33729. Commission
Staff now submit their comments.
A. Background
1. Public Uttlities Regulatory Policies Act
PURPA was passed as part of the National Energy Act of 1978. The Act's goals include
the encouragement of electric energy conservation, effrcient use of resources by electric utilities,
and equitable retail rates for electric consumers, as well as the improvement of electric service
reliability. 16 U.S.C. $ 2601 (Findings). Under the Act, the Federal Energy Regulatory
Commission (FERC) prescribes rules for PURPA's implementation. l6 U.S.C. $ 824a-3(a), (b).
State regulatory authorities such as the Idaho Public Utilities Commission implement FERC
rules, but have "discretion in determining the manner in which the rules will be implemented."
Idqho Power Company v. Idaho Pub. Util. Comm.,l55 Idaho 780,782,316 P.3d 1278,1280
(20 I 3) (citing F. E. R. C. v. Mis s is s ippi, 45 6 U .5. 7 42, 7 5 I (1982)).
PURPA requires electric utilities, unless otherwise exempted, to purchase electric energy
from qualifying facilities (QFs). l6 U.S.C. $ 824a-3; see also l8 C.F.R. 5 292.101 (defining
QFs), 292.303(a). In Idaho, the purchase rate for a utility's contract to purchase QF energy
STAFF COMMENTS APRIL 27,20T7
under PURPA must be approved by this Commission. Idaho Power,l55 Idaho at789,316 P.3d
at 1287.
Under PURPA, the purchase rate for PURPA contracts shall not exceed the "incremental
cost" to the utility, defined as the cost of energy which, but for the purchase from [the QF], such
utility would generate or purchase from another source." 16 U.S.C. $ 82aa-3(d); 18 C.F.R. $
292.101(6) (defining avoided costs). However, FERC rules require establishment of "standard
rates for purchases from [QFs] with a design capacity of 100 kilowatts or less," and allow
"standard rates for purchases from [QFs] with a design capacity of more than 100 kilowatts." I 8
C.F.R. 5 292.304(c)(1), (2). FERC rules provide that standard rates "[m]ay differentiate among
[QFs] using various technologies on the basis of the supply characteristics of the different
technologies." 1 8 C.F.R. 5 292.304(c)(3)(ii).
The Commission has established two methods of calculating avoided cost, depending on
the size of the QF project: (1) the surrogate avoided resource (SAR) methodology, and (2) the
integrated resource plan (IRP) methodology. See Order No. 32697 at7-8. The Commission uses
the SAR methodology to establish standard or "published" avoided cost rates. /d Published
rates are available for wind and solar QFs with a design capacity of up to 100 kilowatts (kW),
and for QFs of all other resource types with a design capacity of up to 10 average megawatts
(aMW). Id. The Commission established the 100 kW and l0 aMW eligibility caps for published
rates in proceedings that the Commission initiated to investigate "disaggregation" - the breaking
up of one large project "into smaller projects 'in order to obtain published avoided cost rates that
exceed a utility's actual avoided cost."' Order No.32262 at 3 (Case No. GNR-E-1 1-01).
Ultimately, the Commission addressed the disaggregation problem by setting the eligibility cap
for wind and solar QFs to access published avoided cost rates at 100 kW, the FERC-established
minimum to quali$ for published rates. Id. at 9; I 8 C.F.R. S 292.304(cX I ).
PURPA and FERC's implementing regulations are silent as to contract length;
consequently, the issue is in the discretion of the state commissions. See Afton Energt, Inc. v.
Idaho Power,l0T Idaho 781,785-86,693P.2d427,431-32 (198a); Idaho Power,155 Idaho at
782,316 P.3d at 1280. Since PURPA was first implemented in Idaho, this Commission has
periodically modified the maximum length for PURPA contracts. See Order No. 29029. In
2015, the term for individually-negotiated contracts (those not subject to published rates) was
reducedfrom20yearstotwoyears. OrderNos.33357,33419. Thecontracttermforpublished
2STAFF COMMENTS APRIL 27,2017
rate contracts remains at 20 years. See Order No. 33253 (clarifying that the proceedings
concerned the contract term for QFs exceeding the published rate eligibility cap).
2. Commission Jurisdiction and Legal Standardfor Declaratory Orders
The Commission has jurisdiction to issue declaratory orders under Title 61 of the Idaho
Code and the Idaho Uniform Declaratory Judgments Act of 1933,Idaho Code $$ l0-1201 et seq.
See Utah Power & Light v. Idaho Pub. Util. Comm'n,ll2Idaho 10,12,730P.2d930,932
(1986). The Idaho Supreme Court has said that a declaratory judgment'omust clarify and settle
the legal relations at issue, and afford leave from uncertainty and controversy which gave rise to
theproceeding." Haruisv. CassiaCounty,l06Idaho 513,517,681 P.2d 988,992 (1984)
(citation omitted). To enter a declaratory judgment, there must be "an actual or justiciable
controversy" that is "real and substantial," and "definite and concrete, touching the legal
relations of parties having adverse legal interests." Id. at516 (citation omitted).
B. Idaho Power's Petition
Idaho Power states that it received requests for PURPA contracts from five battery
storage facilities (self-certified as QFs)r asserting they are entitled to published avoided cost
rates and 2}-year terms. Petition at2. The five facilities are Franklin Energy Storage One, Two,
Three, and Four, LLCs, and Black Mesa LLC. Id. at 4. The Black Mesa QF is owned by
Redwood Energy, LLC. See Redwood Comments.
Idaho Power asserts that, together, the five QFs request contracts for a total of 148 MW
of energy storage. Petition at 7. Idaho Power indicates it notified legal counsel for the four
Franklin QFs that the proposed projects did not appear to qualify for published rates and 2O-year
contract terms. Id. at 4-5. According to the Company, the Franklin QFs then "purport[ed] to
address deficiencies in its applications and demand[ed] that Idaho Power proffer 20-year,
published avoided cost rates." Id. at 5. Idaho Power does not describe any such communication
with Black Mesa. Idaho Power maintains that none of the storage facilities are eligible for
I Petition at 4. Franklin and Black Mesa submiffed a FERC Form 556 for each of the proposed projects, self-
certifring that the projects are QFs under 18 C.F.R. $ 292.207(a). See Attachments l-5 to Petition.
JSTAFF COMMENTS APRIL 27,2017
published rates and 2}-year contracts, and that it notified Franklin and Black Mesa2 accordingly.
Id,
Idaho Power recognizes that "QF status is within the exclusive jurisdiction [ofl and
properly before FERC," thus for purposes of its petition here, the Company does not challenge
the QF-status of Franklin and Black Mesa. Id. at 6. Idaho Power seeks a declaratory ruling that,
for the Franklin and Black Mesa QFs, and other battery storage facilities with nameplate
capacities exceeding 100 kW, the proper avoided cost rate is calculated using the IRP
methodology, and the proper contract term is two years. Id. at 13. The Company also seeks the
Commission's ruling that battery storage facilities with a maximum nameplate capacity of 100
kW are eligible for published avoided cost rates and 20-year contract terms. Id. at 14.
Idaho Power notes that "the generation source that energizes all of the Proposed Battery
Storage Facilities is solar generation." Id. at 7 (citing Attachments l-5). Further, the Company
asserts "the output profile submitted for each of the Proposed Battery Storage Facilities matches
the shape and timing of the generation profile of a solar generator." Id. According to the
Company, the potential benefits of an economically viable utility-scale energy storage facility3
cannot be recognized if QFs "are confrgured in such a manner as to come under published rates,"
as proposed by Franklin and Black Mesa. Id. at8. The Company argues that, to realize the
potential benefits of energy storage, "operational control and dispatchability of the facility [must]
be with the utility charged with serving load," whereas the Franklin and Black Mesa QFs are
structured to "pass[ ] through as many kW hours as possible...to maximize rcvenue." Id.
The Company believes that Franklin and Black Mesa are using their QFs to "circumvent
the Commission's rules and requirements in its implementation of PURPA for the state of
Idaho." Id. The Company asserts the Franklin and Black Mesa QFs are o'nothing more than a
pass through of the solar generation [that will energize their batteries], in what appears to be a
blatant attempt to manipulate the 100 kW published rate eligibility cap and two-year contract
limitation for solar generators." Id. at9.
2 Although Redwood Energy submitted Comments on behalf of Black Mesa as its corporate owner, "Black Mesa
Energy, LLC" submitted its Schedule 73 PURPA contract request form to Idaho Power on its own behalf.
Attachment 5 to Petition, at 4.
3 The Company states that the potential benefits of economically viable, utility-scale energy storage facilities include
"provid[ing] ancillary grid services such as reserve capacity, surge capacity, load-balancing, or voltage support;
firming [ ] variable generation; or time-shifting generation to match load." Petition at 8.
4STAFF COMMENTS APRIL 27,2017
Idaho Power characterizes the five requests for PURPA contracts as a "large amount of
proposed MWs in a very short time . . . similar to the previous wind and solar development,"
addressed by the Commission in Order Nos. 32262 and32176. Id. at 10-12. The Company thus
argues it is appropriate and necessary for the Commission to grant its requested declaratory relief
"extend[ing] the 100 kW published rate eligibility cap to battery storage projects . . . to protect
customers from this manipulation of the rules." Id. at 13.
C. Franklin Enerry Storage Comments
Franklin opposes Idaho Power's petition. According to Franklin, a declaratory order is
unwarranted because the Company o'has failed to identiff any adverse legal relations or issues."
Franklin Comments at l. Franklin asserts there is no "legal controversy" because the
Commission's orders and policy rulings are "clear [and] unequivocal" in supporting Franklin's
entitlement to published avoided cost rates for up to 20 years. Id. at l-2,ll-12.
Franklin points to the Commission's Order No. 32697, which provides, "We find that a
l0 aMW eligibility cap for access to published avoided cost rates for resources other than wind
and solar is appropriate to continue to encourage renewable development while maintaining
ratepayer indifference;' Id. at 7 (quoting Order No. 32697 at 14 (emphasis by Franklin)). Also,
Franklin quotes the Commission's decision to "maintain the eligibility cap at l0 aMW for QF
projects other than wind and solar (including but not limited to biomass, small hydro,
cogeneration, geothermal, and waste-to-energy)." Id. at l0 (quoting Order No. 32697 at 9
(emphasis by Franklin)). Franklin contends this language, making the list of "other" projects
non-inclusive, clearly demonstrates the Commission "considered" energy storage as a QF for
which the 10 aMW eligibility cap should apply. Id. at 10.
Franklin argues that, because the Commission's Order No. 32697 is clear, there "are no
adverse legal interests." Id. at 11. Thus, Franklin asserts, Idaho Power's request is not for a
declaratory order, but is a request for the Commission to reconsider or revise order No. 32697.
Id. at2,4. For such relief, Franklin contends, it and any potentially affected parties must receive
notice and the opportunity to present evidence and cross-examine witnesses. Id. at3-4. Franklin
also argues that the Commission's decision in such a proceeding must be prospective only, and
thus not apply to its legally enforceable contracts with Idaho Power for the four proposed battery
storage QFs. /d at4-5.
5STAFF COMMENTS APRIL 27,2017
In addition, Franklin challenges - and asks the Commission to disregard - a number of
factual assertions in Idaho Power's petition. Franklin contends that, contrary to the Company's
claims, the Franklin QFs (1) "contemplated" energy sources in addition to solar; (2)have offered
to be dispatchable, and "will have the ability to shift load pursuant to dispatch signals from Idaho
Power"; (3) and will have the ability - "to varying degrees" - to provide ancillary grid services
(such as reserve capacity, surge capacity, load-balancing, or voltage support), firming of variable
generation, and time-shifting generation to match load. Id, at 14 (emphasis original). According
to Franklin, Idaho Power never asked about Franklin's ability to provide oomany, if not all" of
these services in its QF output. /d. Further, Franklin disputes that its QFs will be a mere "pass
through" of solar power, arguing that they would instead "utilize renewable energy as input into
the battery storage system . . . [that would then be] used to provide a non-intermittent,
dispatchable product." Id. at 15.
Finally, Franklin asserts that it has complied with all of the requirements of the
Company's Tariff Schedule 73, which outlines PURPA contracting procedures, and that as such
it has established legally enforceable obligations and is entitled to published rates and2}-year
contracts. Id. at 17.
D. Redwood Energy Comments for Black Mesa
Redwood Energy, LLC, which owns the Black Mesa QF, submitted brief comments on
Black Mesa's behall asserting that it qualifies for published rates "because it is a QF [with]
output of less than l0 [aMW] but is not a wind or solar QF that would be restricted to 100 kW."
Redwood Comments. Redwood contends that the Black Mesa QF "has fundamentally different
characteristics than a wind or solar project without energy storage." Id. According to Redwood,
battery storage "makes output both more predictable and more coincident with system load, thus
a higher Net Qualifying Capacity." Id. Redwood asserts that "[e]nergy storage will reduce
Idaho Power's requirements for Resource Flexibility, thus avoiding a cost that would be bome
but for" the Black Mesa QF project. 1d Redwood further asserts, "This is a dispatchable system
that will offer ancillary grid services such as voltage support, load shifting, reserve capacity,
load-balancing, [and] firming of variable generation or time-shifting to match load." Id.
6STAFF COMMENTS APRIL 27,2017
E. Staff Comments
The Commission must first address whether there is a legal dispute for which relief can
be granted by declaratory order. See Harris, 106 Idaho at 516. If the Commission finds there is
a legal dispute, it must then determine how to resolve it. In determining an appropriate
resolution, the Commission must consider whether the relief requested by the petitioner, or some
other relief, is appropriate.
L A declaratory order is appropriate to resolve the legal dispute about the terms of Idaho
Power's contract or obligation to purchase powerfrom the Franklin and Black Mesa QFs.
Staffbelieves there is a legal dispute that can be properly addressed by a declaratory
order. The battery storage QFs sought to enter PURPA contracts with Idaho Power, and the
parties disagree on the contractual terms, including the length of contract and the applicable
avoided cost rate. Thus the parties have a dispute as to the legal relationship that should exist
between them. Further, as discussed below, the dispute is one the Commission can resolve.
Based on the FERC's and this Commission's past orders, and information in the QFs'
applications for PURPA contracts, Staff does not believe that Idaho Power is legally obligated to
purchase energy from the Franklin and Black Mesa QFs at published avoided cost rates and20-
year terms. Accordingly, Staff believes there is an actual, substantial, concrete legal dispute
between Idaho Power, and Franklin and Black Mesa that the Commission can resolve. See
Harris,106 Idaho at 516-17.
2. Using FERC's analysis as guidance, bottery storagefacilities should be evaluated by their
energy source
Franklin and Black Mesa contend they are clearly entitled to published avoided cost rates
because this Commission set the published rate eligibility cap for "wind and solar QFs" at 100
kW (Order No.32262), and provided that the cap "for other QFs" was 10 aMW (Order No.
32176). Franklin and Black Mesa argue that battery storage QFs are not wind and solar QFs,
therefore they are "other QFs." Staff disagrees with this overly simplistic analysis. The issue of
how to evaluate a battery storage facility under PURPA was addressed by FERC in an order
cited by Franklin, Luz Development and Finance Corporation, 51 FERC P 61,078 (1990).
In Luz, the developer of a proposed electro-chemical battery storage facility applied to
FERC for certification as a qualifying small power production facility under PURPA. Luz,5l
7STAFF COMMENTS APRIL 27,2017
FERC P 61,078 at 61,168. The developer argued that its battery storage system's ability to "shift
inexpensive off-peak energy for later use to meet peak demands [would] meet the . . . public
policy goals of PURPA," therefore it should not be subject to the rules limiting the facility's
energy input from fossil fuels to 25Yo. Id. at 61,169-70. FERC rejected the developer's
argument, stating that "the primary energy source requirements must be applied to energy
storage facilities in the same manner they are applied to conventional small power production
facilities." Id. at 61,17 l.
Addressing the developer's arguments about the operational characteristics of its battery
storage system, FERC noted
Contrary to Luz's assertion, the primary energy source of the battery
system is not the electro-chemical reaction. Rather, it is the electric
energy which is utilized to initiate that reaction, for without that energy.
the storaee facility could not store or produce the electric energy which is
to be delivered at some later time.
Id. (emphasis added). In other words, FERC highlighted the battery storage facility's
dependence on its energy source as critical to its ability to produce or store energy. Therefore,
FERC found that in order for the battery storage facility to be a QF, it must meet the
requirements that "the energy input to the facility itself is biomass, waste, a renewable resource,
a geothermal resource, or any combination thereof' (or demonstrate that no more than2iYo of
the energy input is from fossil fuels, and that such uses are consistent with PURPA
requirements). Id. at6l,172. FERC found that the facility's claimed contributions toward
PURPA policy goals did not exempt it from otherwise complying with PURPA rules governing
its energy source. 1d
Staff agrees that the energy source of a battery system is not an electro-chemical reaction.
Staff also believes, consistent with FERC's analysis in Luz, that a battery storage facility can be a
QF only if its energy source complies with PURPA and PURPA regulations. Thus it is
appropriate to look to the Franklin and Black Mesa QFs' energy sources in determining their
eligibility for published rates. Although the Franklin and Black Mesa QFs are not solar QFs,
their energy sources - as currently proposed - are solar. Franklin contends that "the projects
[have] contemplated energy sources in addition to, or in place of solar." Franklin Comments at
14. But the mere contemplation of an altemate source is insufficient to obligate a utility to
8STAFF COMMENTS APRIL 27,2017
purchase power from a battery storage QF with rates and contract terms based on that
hypothetical source.
Franklin asserts that it has established a legally enforceable obligation (LEO) based on its
purported completion of the information requested in the Company's Tariff Schedule 73, and
that it is entitled to published rates and 2O-year terms for its projects. Absent a fully-negotiated
contract, a PURPA QF can establish a LEO when the QF "makes a binding commitment to sell
power to an electric utility." Order No. 3297 4 at 1 ; 18 C.F.R. 5 292.304(d). "FERC has given
each state the authority to decide when a LEO arises in that state." Idaho Power,l55 Idaho at
787, quoting Power Resource Group, Inc. v. Public Utility Comm'n of Texas, 422 F.3d231,239
(5th Cir. 2005). In 2013, the Idaho Supreme Court affirmed this Commission's determination
that a LEO "requires a showing that there would have been a contract but for the actions of the
utility." Idaho Power,155 Idaho at787. The Court in that case affirmed this Commission's
finding thata LEO was not established, based on a determination that the utility "did not impede
[the QF's] ability to enter into" PURPA contracts. .Id.
Here, given Franklin's acknowledgment that its non-solar alternative energy sources are
"contemplated," or currently theoretical, Staff believes it is appropriate to find that Idaho Power
did not impede the formation of a PURPA contract for a non-solar QF. The attachments to Idaho
Power's petition, and the comments from Franklin and Black Mesa all indicate that the proposed
configurations for the Franklin and Black Mesa QFs identify solar as the energy source.
Applying the above analysis, Staff believes the Franklin and Black Mesa QFs, as battery storage
facilities, are entitled to contract terms based on their proposed energy source - solar. Because
the Franklin and Black Mesa QFs exceed the 100 kW published rate cap for solar QFs, they
would be entitled to two-year terms and negotiated avoided cost rates calculated under the IRP
methodology.
3. FERC's analysis is consistent with this Commission's orders, which focus on addressing
disaggregation
In arguing for its simplistic reading of the Commission's orders - that battery storage is
an "other source" eligible for published rates at the l0 aMW cap - Franklin argues that clear and
unambiguous statutory language'ospeaks for itself'and needs "no further interpretation."
Franklin Comments at 6, citing Koon v. Bottolfsen, 66ldaho 771, 189 P.2d 345 Q9aQ; Hm,vorth
v. Bernsten, 38 Idaho 539,200 P.2d 1007 (1948). However, Franklin ignores that the "objective
9STAFF COMMENTS APRIL 27,20T7
of statutory interpretation is to 'derive the intent of the legislative body that adopted the act' . . .
and 'provisions should not be read in isolation, but must be interpreted in the context of the
entire document."' Hayes v. City of Plummer,l59Idaho 168, 170, 357 P.3d 1276,1278 (2015),
quoting Farber v. Idaho State Ins. Fund, 147 ldaho 307,310, 208 P.3d 289, 292 (2009).
Applying these doctrines of statutory interpretation to the Commission's orders, one must
consider the Commission's intent, as demonstrated by the context of the entire order or orders,
rather than a single sentence.
The Commission established Idaho's published rate eligibility caps in 2011, through
proceedings conducted in Case No. GNR-E-11-01. Significantly, the Commission initiated Case
No. GNR-E-I l-01 to investigate its concern "that large QF projects were disaggregating into
smaller QF projects in order to be eligible for published avoided cost rates that may not be just
and reasonable to the utility customers or in the public interest." Order No.32262 at 4. The
generating sources of the projects about which the Commission was concerned were wind and
solar. Id. atl.
In its Final Order in Case No. GNR-E-I l-01, the Commission stated its intent to
"allow[ ] small wind and solar QFs to avail themselves of published rates," but prevent large
wind and solar QFs from disaggregating to get the more favorable rates that fail to accurately
reflect a utility's avoided cost. Order No. 32262 at l. The Commission found, "[i]f we allow the
current trend to continue, customers may be forced to pay for resources at an inflated rate and,
potentially, before the energy is actually needed to serve its customers." Id. at 8. "[W]e
emphasize that PURPA and our published rate structure were never intended to promote large
scale wind and solar development to the detriment of utility customers." Id. at8.
Although the Commission considered establishing criteriaa to prevent disaggregation, the
Commission concluded that it "would be met by attempts to circumvent such criteria," noting,
"[t]he economic incentive [to circumvent criteria] is obvious." Id. Ultimately, the Commission
affirmed the "100 kW eligibility cap for wind and sola"r QFs to access . . . published avoided cost
rates." Id. at9.
4 The parties in that proceeding suggested considering "criteria such as ownership, shared facilities, shared
agreements, common control, and shared debt and/or equity" to assess whether a group of projects was truly a
number of separate small projects, or actually "a single large project disaggregated into several smaller projects to
obtain published avoided cost rates." Order No. 32262 at7.
STAFF COMMENTS l0 APRIL 27,2017
Given the Commission's evident concern about disaggregation, it follows that the
Commission would be similarly concerned by an effort to subvert the 100 kW eligibility cap for
solar QFs in this case. A battery storage QF that would not exist except for its energy source
should not be able to evade an eligibility cap that would otherwise be applied to its energy
source. FERC recognized that a battery storage QF - by virtue of being a battery storage facility
- is not exempt from PURPA rules governing its energy source. Luz,5l FERC P 61,078. Here,
Franklin and Black Mesa - battery storage QFs currently intending to use solar as their energy
source - should not be exempt from this Commission's eligibility cap which was intended to
prevent disaggregation of large solar projects. Accordingly, Staff believes Franklin and Black
Mesa, as configured at the time of Idaho Power's petition, are not eligible for published avoided
cost rates and20-year contracts.
4. Staff recommendation
In sum, Staff recommends that the Commission issue a declaratory order providing that
the applicable published rate eligibility cap for the Franklin and Black Mesa Battery Storage QFs
is determined based on their energy sources. According to Franklin's and Black Mesa's
applications for PURPA contracts that they submitted to Idaho Power, the Franklin and Black
Mesa QFs are currently configured to use solar as their energy source. Thus the applicable
eligibility cap for published rates is 100 kW. Because the Franklin and Black Mesa QFs exceed
the 100 kW cap, they are entitled to PURPA contracts with two-year terms and negotiated
avoided cost rates calculated using the IRP methodology. Staff believes the declaratory order
should be narrowly tailored to address the legal dispute between Idaho Power and the Franklin
and Black Mesa QFs. However, given the broader implications of issues raised in this matter,
Staff recommends that the Commission initiate a general investigation into the appropriate
contract terms for battery storage QFs.
Respectfully submitted this 71'y day of Apr il2017.
uang
Camille Christen
Deputy Attorneys General
Umisc/Comments/ipce I 7. I djh
STAFF COMMENTS 11 APRIL 27,2017
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 27TH DAY OF APzuL 2017,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN
CASE NO. IPC-E.L7-OI, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO
THE FOLLOWING:
DONOVAN WALKER
LEAD COUNSEL
IDAHO POWER COMPANY
PO BOX 70
BOrSE ID 83707-0070
E-mail : [e-mail]
dockets@idahopower. com
BRIAN LYNCH
BLACK MESA ENERGY LLC
PO BOX 2731
PALOS VERDES CA9O274
E-mail: [e-mail]
DAVID BENDER
EARTHJUSTICE
3916 NAKOMA ROAD
MADISON WI 537I I
E-mail: [e-mail]
PETER J RICHARDSON
RICHARDSON ADAMS PLLC
5I5 N 27TH STREET
BOISE ID 83702
E-mail : [e-mail]
BEN OTTO
ENERGY ASSOCIATE
ID CONSERVATION LEAGUE
PO BOX 844
BOISE ID 83701
E-mail: [e-mail]
CERTIFICATE OF SERVICE