20200117Answer to Petitions for Reconsideration.pdf

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January 17,2020
VIA HAND DELIVERY
Diane Hanian, Secretary
ldaho Public Utilities Commission
11331 W. Chinden Boulevard
Building 8, Suite 201-A
Boise, ldaho 83714
Re:Case No. IPC-E-18-15
Study of Costs, Benefits, and Compensation of Net Excess Energy Supplied
by Customer On-Site Generation
ldaho Power Company's Answer/Cross-Petition to Petitions for
Reconsideration
Dear Ms. Hanian:
Enclosed for filing in the above matter please find an original and seven (7) copies
of ldaho Power Company's Answer/Cross-Petition to Petitions for Reconsideration in the
above matter.
lf you have any questions about the enclosed documents, please do not hesitate to
contact me.
Very truly yours,
t4a*4 (*-tta*^-
LDN:kkt
Enclosures
LISA D. NOROSTROM
Lead Counsel
[e-mail]
Lisa D. Nordstrom
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY TO
STUDY THE COSTS, BENEFITS, AND
COMPENSATION OF NET EXCESS
ENERGY SUPPLIED BY CUSTOMER
ON-SITE GENERATION
RECEIYED
::J-riii t] Pil 2:22
'i : r''jr,' ;'iSSlOli
Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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CASE NO. tPC-E-18-15
IDAHO POWER COMPANY'S
ANSWER/CROSS-PETITION TO
PETITIONS FOR
RECONSIDERATION
On December 20, 20'19, the ldaho Public Utilities Commission ("Commission")
issued Order No. 34509 rejecting a Settlement Agreementl intended to resolve on-site
generation issues for residential and small general service ("R&SGS") customers. Order
No. 34509 also established the criteria under which existing customers with on-site
generation could continue to net meter under the terms in place as of December 20, 201 S.
On January 10,2020, Micah Hornback, ldaho Clean Energy Association ('ICEA),
and the ldaho Conservation League ("lCL") and Vote Solar (collectively, "the Grandfather
Extension Petitioners") filed Petitions for Reconsideration. The Grandfather Extension
1 lvlotion to Approve Settlement Agreement, Case No. IPC-E-1 8-15 (filed October 1 1 , 2019)
IDAHO POWER COMPANY'S ANSWER/CROSS-PETITION
TO PETITIONS FOR RECONSIDERATION . 1
LISA D. NORDSTROM (lSB No. 5733)
ldaho Power Company
1221 West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
lnordstrom@idahopower. com
Petitioners asked the Commission to reconsider their ruling on the finite grandfathering
period outlined in Order No. 34509. Additionally, Thomas Baskin filed a Petition for
Reconsideration on January 10, 2020, asking the Commission for
clarification/reconsideration on how a system expansion would impact a customer's
grandfathered status (collectively refened to as "Petitioners").
ldaho Power Company ("ldaho Power" or "Company"), in accordance with /daho
Code $ 61-626 and RP 331.02 and 331.05, files this Answer/Cross-Petition'? to the
petitions for reconsideration filed on January 10, 2020.3 ldaho Power will explain (1) why
the recommendation made by the Grandfather Extension Petitioners should be rejected
and how ldaho Power's recommendation proposed in its Petition for Reconsideration filed
January 10, 2020, addresses the concerns expressed by the Grandfather Extension
Petitioners, and (3) the Company's interpretation of the Commission's direction regarding
system expansions.
Acceptance of the Grandfather Extension Petitioners' proposed grandfathering
extension would inappropriately rmpose higher costs on ldaho Power's non-net metering
customers in order to provide economic certainty to solar installers and prospective solar
buyers. The Commission could provide the desired certainty referenced by the
Grandfather Extension Petitioners by adopting the recommendations made by ldaho
Power in its Petition for Reconsideration. Therefore, ldaho Power respectfully requests
the Commission reject the Petitioners' recommendations and alternatively reconsider
, RP 331.05 describes answers to petitions for reconsideration as "(pleadings that disagree with a
petition for reconsideration, but do not ask for affirmative relief from the Commission's orders)." Because
the Company requests the "afflrmative relief' described in its Petition for Reconsideralion filed January 10,
2020, ldaho Power also characterizes this pleading as a cross-petition to facilitate that result.
3 On January 16,2020, ldaho Power separately filed an Answer/Cross-Petition to Richard
Kluckhohn's Petition for Reconsideration.
IDAHO POWER COMPANY'S ANSWER/CROSS-PETITION
TO PETITIONS FOR RECONSIDERATION - 2
Order No. 34509 to adopt the recommendations made by ldaho Power in its Petition for
Reconsideration.
I. EXTENTION OF GRANDFATHER ELIGIBILITY
The Grandfather Extension Petitioners generally request the Commission
reconsider its decision to limit the grandfather eligibility period in Order No. 34909 and
extend the eligibility date for grandfathering to include all customers who install on-site
generation until the Commission has approved a successor program to replace the
existing net metering offering.
A, Idaho Power Acknowledoes Unce ai .
ln each of their petitions for reconsideration, the Grandfather Extension Petitioners
explain that, without having a successor program in place, potential R&SGS on-site
generation customers will be left with uncertaintyo and it will be difficult for installers to
provide accurate information.s ICL and Vote Solar explain that "this level of uncertainty
makes it very difficult for distributed energy system providers to give accurate information
to the public" and that "[with] no successor program in place, providers are unable to
make informed disclosures."o ICEA went as far as to say that: "Many customers and
installers might find it easiest to evaluate an investment based on existing rates even
while recognizing (and disclosing) that changes are anticipated.e ICEA described what
it thought would be the result of this uncertainty and potential misinformation when it said:
a ICL and Vote Solar's Petition for Reconsideration, pp. 1-2; ICEA Petition for Reconsideration, p
3, Hornback Petition for Reconsideration, p. 1.
s lCL and Vote Solaas Petition for Reconsideration, p. 2; Hornback Petition for Reconsideration,
p. 1; ICEA Petition for Reconsideration, pp. 2-3.
6 ICL and Vote Solaas Petition for Reconsideration, p. 2.
7 ICEA'S Petitaon for Reconsideration, p. 3
IDAHO POWER COMPANY'S ANSWER/CROSS-PETITION
TO PETITIONS FOR RECONSIDERATION . 3
''This breeds confusion and, ultimately, customer discontent both now and if changes are
proposed in the future."8
ldaho Power generally shares the same concerns as the Grandfather Extension
Petitioners; however, the Grandfather Extension Petitioners' proposed method of
addressing those concerns would inappropriately lock-in an avoidable cost shift to non-
net metering customers. The Commission could provide the desired certainty referenced
by the Grandfather Extension Petitioners by adopting the recommendations made by
ldaho Power in its Petition for Reconsideration
B. Extension of Grandfather Eliqibilitv Would Financiallv Harm Non-Participants.
ldaho Power does not believe extension of grandfather eligibility best serves the
entirety of its 465,000 R&SGS customers. lf reconsideration is granted, ldaho Power will
present evidence describing the annual and long-term financial impact to R&SGS
customers without on-site generation. lt will also present evidence supporting the more
reasonable alternatives set forth in the Company's Petition for Reconsideration.
Based on the Company's initial comprehensive study addressing on-site
generation,e the Company has projected the estimated additional cost shift if the
Commission were to adopt the Grandfather Extension Petitioners' recommendation to
extend the eligibility date for grandfathering to include all customers who install on-site
generation up until the Commission has approved a successor program to replace the
6 ICEA'S Petition for Reconsideration, p. 3.
s The Company's initial comprehensive study was based on (i) a class cost-of-service study
performed in the same manner as those performed for general rate cases, and (ii) quantification of the
revenue deficiency that exists under net metering and net hourly billing. See Motion to Approve Settlement
Agreement, Att. 1-7 to Att. 4 for the cost-of-service study. See Motion to Approve Settlement Agreement,
Att. 9 to Att. 4 for the quantification of revenue deficiency.
I DAHO POWER COMPANY'S ANSWER/CROSS.PETITION
TO PETITIONS FOR RECONSIDERATION - 4
existing net metering offering. An excerpt of the relevant portion of this study which
quantifies the existing cost shift is included in Figure 1.to
Figure 1 . 2017 Cost Shift for R&SGS On-Site Generation Customer Classes
(a)
(b)
lc) Ia -bl
Revenue Requirement
IOAHO POWER COMPANY
NET METERING HOURLY BILLING RTSULTS
TWELVE MONTHS ENDING DECEMBTR 31,2017
Net Monthlv Billine
s1,434,220
Net HourlY Bllllnr
sl,434,22O
Net Monthly Billing
s3s,3s3
Ne! tlou&!!!l!os
S3s,3s3
521,1763117
is122,s59)
917 74
(S8,177)
Based on the annual cost shift per on-site generation customer identified in the
cost-of-service study of approxrmately $415 for residential on-site generation customers
and $515 for small general service on-site generation customers, the Company estimates
an ongoing annual cost shift of $2.2 million for the initial groupll of customers
grandfathered by Order No. 34509. The Company currently collects under recovery of
fixed costs through its Fixed Cost Adjustment mechanism, passing along any cost shift to
all R&SGS customers, including non-participants.
Glven that it could easily take one or two years for interested parties to complete
the study on the costs and benefits of distributed on-site generation to the Company's
system, it is not reasonable or in the best interest of ldaho Power's other customers to
extend the grandfathered eligibility date until the Commission approves a successor
offering. To estimate the additional cost shift associated with the new on-site generation
customers if the Commission were to extend the eligibility date, the Company forecasted
10 Motion to Approve Settlement Agreement, Att. 9 to Att. 4
11 The initial group consists of 5,010 customers as of December 20, 2019, and 309 applications for
which ldaho Power has received documentation of financial commitment through the afternoon of January
15,2020. The fanal number of grandfathered customers will not be known until after the date of this filing,
but the Company had received an additional approximately 250 applications for which it has not yet received
documentation of financial commitment.
IDAHO POWER COIVIPANY'S ANSWER/CROSS-PETITION
TO PETITIONS FOR RECONSIDERATION . 5
Resid entia I On-S ite Generation
(s4s0,934)cost-shift
Small Gen. On'Site Generation
st7,678
R&SGS on-site generation customer g rowth for 2020 and 2021 in a manner consistent
with a forecast test period used in rate change filings. The projected R&SGS customer
counts for grandfathered customers are 8,209, and 13,628 in 2020 and 2021,
respectively. These customers represent an additional ongoing annual cost shift of
approximately $1 .2 million and $3.4 million if the Commission were to extend the eligibility
date until the end of 2O2O or 2021 , respectively. The results of the Company's estimated
ongoing cost shift using historical growth rates are depicted in Table 1.
Table 1. Estimated Annual Cost Shift Usins Historical G rowth Rates
S8.om
S7.om
5b.um
Ss.om
54.0m
S3.om
5t.um
S1.0m
So.om
52.2m
51.2m
52.2m
$3.qm
S2.2m
2020 Projection 202l Projection
r Annual Cost-shift - Additional Each Year Delay
IDAHO POWER COMPANY'S ANSWER/CROSS.PETITION
TO PETITIONS FOR RECONSIDERATION . 6
Moreover, if the Commission were to set an open-ended date in the future for
customers to be grandfathered, it would surely cause a "run on the bank" scenario where
application rates increase significantly in anticipation of imminent less favorable terms.
Assuming a "run on the bank" occurred, using historical grov,rth rates would be an overly
conservative estimate; NV Energy experienced net-metering customer groMh of 68
percent over a five-month period after signaling future changes to its net metering
lnitialGroup
Annualcost-shift
program in Nevada.12 lt would not be unreasonable to assume the adoption rate would
increase by 50 percent more than ldaho Power's existing customer growth forecast. The
Company estimates the additional ongoing annual cost shift under the "run on the bank"
scenario with customer growth 50 percent greater than its own forecast to be $1 .8 million
and $5.2 million if the Commission were to extend the eligibility date until the end ot 2020
or 2021, respectively. The results of the Company's estimated cost shift using the "run
on the bank" scenario is depicted in Table 2.
Table 2. Estimated Annual Cost Shift Usinq "Run-On-Bank" Growth Rate
S8.om
S5.2 m
S7.0m
S6.om
55.{Jm
S1.8m
S4.0m
53.0m
S2.0m
S2.2m S2.2m S2.2m
S 1.om
So.om
2020 Projection 2021 Projedion
t Annual Cost-shift "Run on the bank" - Additional Each Year Delay
ldaho Power recognizes the Commission's desire to minimize cost shifting to non-
participants by limiting grandfathered participants to those customers with existing
systems or binding financial commitments to install them on the service date of Order No.
12 On July 31,2015, when NV Energy originally proposed to change nelmetering compensation,
there were 10,540 interconnected solar systems. OnJanuary 1, 2016, whenthe new rates came into effect,
there were 17,655 interconnected systems. https://www.qreentechmedia.com/articles/read/nevada-net-
meterinqiecision
IDAHO POWER COMPANY'S ANSWER/CROSS.PETITION
TO PETITIONS FOR RECONSIDERATION - 7
lnitialGroup
Annual Cost sh ift
34509.13 As described below, ldaho Power believes the solutions proposed in the
Company's Petition for Reconsideration reasonably balance concerns about cost shifting
to non-participants with certainty for future participants.
G. Recommendations in ldaho Power's Reconsideration Petition Provide
Reasonable Solutions.
ln its Petition for Reconsideration, ldaho Power requested the Commission
approve the Settlement Agreement on reconsideration, or alternatively, (1) immediately
implement net hourly billing for new Schedule 6 and Schedule 8 customers with no
immediate change to the compensation value, which ensures a neutral financial impact
to those customers during this interim period, and (2) initiate a public process to explore
the appropriate value to be assigned to hourly exported energy from all non-
grandfathered on-site generators (i.e,, Export Credit Rate) in the future.to Either solution
has four benefits:
1. Establish a Clear Distinction Between Classes of Customers
lf the Commission reconsidered the Settlement Agreement or alternatively
immediately implemented net hourly billing (with no immediate change to the
compensation value for non-g randfathered Schedule 6 and Schedule 8 customers), the
Commission would more clearly create the distinction it explained in its orderls by
implementing the new net hourly offering for on-site generation customers who do not
meet the eligibility criteria for grandfathering.
r3 Order No. 34509, pp. 14-15
14 ldaho Power's Petition for Reconsaderation, p. 27
15 Order No. 34509, p. 10 ("After the issuance of this Order, however, we believe it will no longer
be reasonable for a customer to assume the net-metering program fundamentals will remain the same over
the expected payback period of their investment").
IDAHO POWER COMPANY'S ANSWER/CROSS-PETITION
TO PETITIONS FOR RECONSIDERATION .8
2. Enhance Bill Clarity for Customers and lnstallers
lf the Commission reconsidered the Settlement Agreement or alternatively
immediately implemented net hourly billing (with no immediate change to the
compensation value for non-grandfathered Schedule 6 and Schedule 8 customers),
customers would begin to clearly understand the fundamentals of net hourly billing.
Perhaps more importantly, customers will have the energy amounts (net hourly
consumption and net hourly excess generation) printed on their bills that enable them to
estimate the potential impacts of the future Export Credit Rate that will be determined in
the upcoming study.15
3. lnstallers Will Have Accurate lnformation to Share with Customers
lf the Commission reconsidered the Seftlement Agreement or alternatively
immediately implemented net hourly billing with no immediate change to the
compensation value for non-grandfathered Schedule 6 and Schedule 8 customers,
installers would be able to provide accurate information to the public and have an accurate
and consistent source for the numbers and assumptions they use to make payback
calculations. ICEA expressed the importance of accurate and consistent numbers when
it said: "An accurate and consistent source for the numbers and assumptions used to
make payback calculations is important for purposes of solar installers' compliance with
the statute, and to ensure that customer receive information that is as consistent and
accurate as possible."l7
16 ldaho Power's Petition for Reconsideration, p. 27.
17 ICEA's Petition for Reconsideration, p. 2.
IDAHO POWER COI\4PANY'S ANSWER/CROSS.PETITION
TO PETITIONS FOR RECONSIDERATION - 9
ln ldaho Power's Petition for Reconsideration, the Company explained that the
alternative recommendation to immediately implement net hourly billing with no
immediate change to the compensation value for non-grandfathered on-site generation
customers, would have no financial impact to customers. The Company explained how
it would implement net hourly billing with no financial impact to customers,
The Company will base both the energy consumption rate and
the Export Credit Rate at the same retail rate, which will result
in a neutral financial impact to customers. That is, the
Company will immediately begin netting on an hourly basis,
but because for the time being the energy consumption and
crediting rates will be the same amount, the ultimate amount
charged or credited to the new Schedule 6 and Schedule 8
customers during this period will be the same as it would have
been under a monthly netting billing construct.ls
The Settlement Agreement likewise contained provisions that transitioned on-site
generation customers to the new Export Credit Rate over eight years that, if approved on
reconsideration, would not result in a gradual rate reduction toward the lower Export
Credit Rate until January 1,2022.1e
II. SYSTEM EXPANSION GRANDFATHER ELIGIBILITY
As part of the Commission's specifics on grandfathering, the Commission stated,
"we are grandfathering the customer at the meter site at the originally installed nameplate
capacity of the system."r0 ldaho Power interprets this language from the Commission to
18 ldaho Power's Petition for Reconsideration, pp.27-28.
1e l\4otion to Approve Settlement Agreement, Attachment 1, Section lV.G., Transition Period, p. 4
20 Order No. 34509, p. 15.
IDAHO POWER COIvIPANY,S ANSWER/CROSS.PETITION
TO PETITIONS FOR RECONSIDERATION - 1O
4. No lmmediate lmpact to Customers
mean that, if the customer installs any expansion to their system, said customer would
forfeit their grandfathered status for their entire system.
Mr. Baskin filed a Petition for Reconsideration asking the Commission to clarify its
intent on how a system expansion would impact a customer's grandfathered status. Mr.
Baskin suggests in his Petition that he believes ldaho Power's interpretation of the
Commission's directive on this issue is incorrect. Mr. Baskin suggests a different
interpretation, that "some simple rule could be established to define what percentage of
my power generation should be subject to the grandfathered export credit rate."21
ldaho Power requests the Commission deny Mr. Baskin's request to grandfather
material expansions of the originally installed system nameplate capacity. Mr. Baskin's
suggestion that the Company could define a percentage of the generation to be
grandfathered is not practical, or even possible with a single metered point of delivery.
Such a calculation would require combining two different billing constructs such as net
monthly billing and net hourly billing - which use different measured billing determinants
over different time periods - and would require costly, customized change(s) to ldaho
Power's billing system.
As an alternative, to accommodate minor system changes resulting from
replacement of system components, ldaho Power would not be opposed if the
Commission were to reconsider its directive on system expansions such that "the
customer may not increase the capacity of the system by more than a total of 10 percent
21 Thomas Baskin's Petition for Reconsideration, p. 2
IDAHO POWER COMPANY'S ANSWER/CROSS-PETITION
TO PETITIONS FOR RECONSIDERATION - 11
or 1 kW, whichever is greater" in order to retain their grandfathered status. This is
consistent with a ruling made by the California Public Utility Commission:
Renewable generation systems eligible for the 20-year
transition period adopted in this decision that are modified or
repaired shall remain eligible for the remainder of their original
transition period, as long as the modifications or repairs do not
increase the system's generation by more than the greater of
10 percent of the system's capacity at the time the customer
completes all application requirements to receive permission
to operate (marking the beginning of the system's specific 20-
year transition period) or'1 kilowatt, not to exceed a total
generation capacity of 1 megawatt, and are sized to meet but
not exceed the customer's annual onsite load.22
Arizona Public Service similarly implemented the same criteria to limit expansion of
grandfathered systems: "Over the term of the grandfathering period, a Customer may not
increase the capacity of their grandfathered solar generation unit by more than a total of
1Oo/o ot 1 kW, whichever is greatsr."r.
ilt. coNcLUSroN
ldaho Power believes the recommendations made by the Petitioners in their
Petitions to extend the eligibility date for grandfathering is not in the best interest of all
R&SGS customers. ldaho Power believes the recommendations made in ldaho Power's
Petition for Reconsideration better address the concerns expressed by the Petitioners
while creating a clear distinction between grandfathered and non-grandfathered
customers. Consequently, and pursuant to the reasons set forth above and in evidence
22 California Public Utilities Commission, Order lnstituting Rulemaking Regarding Policies,
Procedures and Rules for the California Solar lnitiative, the Self-Generation lncentive Program and Other
Distributed Generation lssues, R.12-11-005, Decision 14-03-041, p. 39 (issued April 4, 20'14).
23 Arizona Public Service Company, Rate Rider Legacy EPR-6 (frozen), A.C.C. No. 5959 (effective
August 17, 2017).
IDAHO POWER COMPANY'S ANSWER/CROSS-PETITION
TO PETITIONS FOR RECONSIDERATION - 12
in the record, ldaho Power respectfully requests the Commission deny the Grandfather
Extension Petitioners' request for reconsideration and instead reconsider Order No.
34509 on the recommendations made by ldaho Power in its Petition for Reconsideration.
ldaho Power also respectfully requests the Commission affirm the Company's
interpretation of "nameplate capacity" as it relates to system expansions for the evaluation
of a customers grandfathered status.
Respectfully submitted this 17th day of January 2020.
LISA D. NORDST M
IDAHO POWER COMPANY'S ANSWER/CROSS-PETITION
TO PETITIONS FOR RECONSIDERATION - 13
Attorney for ldaho Power Company
I HEREBY CERTIFY that on the 17th day of January 2020 I served a true and
correct copy of IDAHO POWER COMPANY'S ANSWER/CROSS-PETITION TO
PETITIONS FOR RECONSIDERATION upon the following named parties by the method
indicated below, and addressed to the following:
Commission Staff
Edward Jewell
Deputy Attorney General
ldaho Public Utilities Commission
472 West Washington Street (83702)
P.O. Box 83720
Boise, ldaho 837 20-007 4
ldaHydro
C. Tom Arkoosh
ARKOOSH LAW OFFICES
802 West Bannock Street, Suite LP 103
P.O. Box 2900
Boise, ldaho 83701
ldaho Conservation League and NW
Energy Coalition
Benjamin J. Otto
ldaho Conservation League
710 North 6th Street
Boise, ldaho 83702
NW Energy Coalition
F. Diego Rivas
NW Energy Coalition
1101 8th Avenue
Helena, Montana 59601
ldaho lrrigation Pumpers Association, lnc.
Eric L. Olsen
ECHO HAWK & OLSEN, PLLC
505 Pershing Avenue, Suite 100
P.O. Box 61 19
Pocatello, ldaho 83205
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IDAHO POWER COMPANY'S ANSWER/CROSS.PETITION
TO PETITIONS FOR RECONSIDERATION - 14
CERTIFICATE OF SERVICE
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[e-mail]
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Anthony Yankel
12700 Lake Avenue, Unit 2505
Lakewood, Ohio 44107
Vote Solar
Briana Kobor
Vote Solar
358 South 700 East, Suite 8206
Salt Lake City, Utah 84102
David Bender
Earthjustice
3916 Nakoma Road
Madison, Wisconsin 5371 1
Al Luna
Nick Thorpe
1625 Massachusetts Avenue, NW, Suite 702
Washington, DC 20036
City of Boise
Abigail R. Germaine
Deputy City Attorney
Boise City Attorney's Office
150 North Capitol Boulevard
P.O. Box 500
Boise, ldaho 83701-0500
ldaho Clean Energy Association
Preston N. Carter
GIVENS PURSLEY LLP
601 West Bannock Street
Boise, ldaho 83702
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IDAHO POWER COMPANY'S ANSWER/CROSS-PETITION
TO PETITIONS FOR RECONSIDERATION - 15
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[e-mail]
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Zack Waterman
Michael Heckler
ldaho Sierra Club
503 West Franklin Street
Boise, ldaho 83702
PacifiCorp d/b/a Rocky Mountain Power
Yvonne R. Hogle
Rocky Mountain Power
1407 West North Temple, Suite 320
Salt Lake City, Utah 84116
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Ted Weston
Rocky Mountain Power
1407 West North Temple, Suite 330
Salt Lake City, Utah 84116
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lndustrial Customers of ldaho Power
Peter J. Richardson
RICHARDSON ADAMS, PLLC
515 North 27th Street (83702)
P.O. Box 7218
Boise, ldaho 83707
Dr. Don Reading
6070 Hill Road
Boise, ldaho 83703
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IDAHO POWER COMPANY'S ANSWER/CROSS-PETITION
TO PETITIONS FOR RECONSIDERATION - 16
ldaho Sierra Club
Kelsey Jae Nunez
KELSEY JAE NUNEZ LLC
920 North Clover Drive
Boise, ldaho 83703
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michael.p. [e-mail]
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Micron Technology, lnc.
Austin Rueschhoff
Thorvald A. Nelson
Holland & Hart, LLP
555 Seventeenth Street, Suite 3200
Denver, Colorado 80202
Jim Swier
Micron Technology, lnc.
8000 South Federal Way
Boise, ldaho 83707
lndividual
Russell Schiermeier
29393 Davis Road
Bruneau, ldaho 83604
lndividual
Micah Hornback
209 East 34th Street
Garden City, ldaho 83714
lndividual
Thomas Baskin
3688 N. Willowbar Way
Garden City, ldaho 83714
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4-*^tr--tlrUl
kimGrlyTowell6laec-uti\€Assistint
IDAHO POWER COMPANY'S ANSWER/CROSS-PETITION
TO PETITIONS FOR RECONSIDERATION - 17
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tnelson@holland hart. com
aclee@holland hart. com
g lq a rqa n o-ama ri@ ho lla nd ha rt. com
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