20200117Answer to Petitions for Reconsideration.pdf

EDWARD J. JEWELL
DEPUTY ATTORNEY GENERAI,
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHOBARNO. I0466
IN THE MATTER OF THE PETITION OF
IDAHO POWER COMPANY TO STUDY THE
COSTS, BENEFITS, AND COMPENSATION OF
NET EXCESS ENERGY SUPPLIED BY
CUSTOMER ON-SITE GENERATION
}iECEIVEO
ll PII h: 0\
' ' ','''i!t'o*
Street Address for Express Mai[:
11331 W. CHINDEN BLVD, BLDG 8, STE, 20I.A
BOISE, IDAHO 83714
Attorney for the Commission StafT
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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cAsn, No. IPC-E-18-15
STAFF'S ANSWER TO
PETITIONS FOR
RECONSIDERATION
BACKGROUND
On May 9, 201 8, in Docket No. IPC-E- | 7- I 3, the Commission ordered Idaho Power
Company ("ldaho Pou'er" or "Company") to "initiate a docket to comprehensively study the
costs and benefits ofon-site generation on Idaho Power's system, as well as proper rates and rate
design, transitional rates, and related issues of compensation fbr net excess energy provided as a
resource to the Company." Order No. 34046 at 3 L The Commission encouraged the parties to
work through these issues together in compromise. Id. a|22.
On October 19,2018, Idaho Power petitioned the Commission to open this docket to
effectuate the Commission's directive in Order No. 34046.
On December 20,2019, the Commission rejected a proposed Settlement Agreement in
this case. Order No. 34509.
On January 8,2020, a petition for reconsideration was filed by students from Boise High
School and Boise State University. These students requested the Commission allow
grandfathering ofexisting customers until the Commission approves program changes.
STAFF ANSWER I
C)n January 9,2020, a petition for reconsideration was filed by Richard Kluckhohn. Mr.
Kluckhohn requested the Commission "grandtather the system, lbr the lilb of the system or a
reasonable time frame of not lcss than the standard warrantv period ofthe system, as opposed to
grandfathering the customer." Richard Kluckhohn's request lbr reconsideration of Order No.
34509 at 5.
On January 10, 2020, 'l'homas Baskin filed a petition for reconsideration/clarification
requesting the Commission clariff whether an expansion of his current system after December
20,2019, would result in the loss of grandfathered status for his cntire system, or whether only
the new panels would not be grandf'athered.
On January 10, 2020, Idaho Conservation League and Vote Solar flled a petition for
reconsideration requesting the Commission reconsider its decision to grandfather customers as of
thc date of Order No. 34509, and instead grandfather customers as of the date the Commission
approves a successor program.
On January 10, 2020, Idaho Clean Energy Association filed a petition for reconsideration
requesting the Commission allow customcrs to continue to sign up under Schedules 6 and 8 until
the Commission approves program changes in the future, in order to allow solar installers to
provide accurate estimates to potential customers.
On January 10,2020, Micah Homback filed a petition fbr reconsideration requesting the
Commission allow customers who sign up until the new net metering policy has been finalized
and approved to receive grandfathcred status.
In this answer to petitions for reconsideration, Stall'responds to Idaho Power's petition
fbr reconsideration, Idaho Clean Energy Association's petition tbr reconsideration, Idaho
Conservation League and Vote Solar's petition lbr reconsideration, and Thomas Baskin's
petition for reconsideration.
Staff Disagrees with the Company's Characterization of the Documcnts in the
Record and Does Not Believe the l)ocumcnts Meet the Standard Clarificd by the
Commission in Order No. 34509.
Stalf understood the Commission's directive in Order No. 34046 as directing the parlies
to study the issues and work together collaboratively in compromise. To this end. StalT and the
I
1STAFF ANSWER
STAFF ANALYSIS
parties studied the data providcd by the Company and proposed altemative methods of
calculation fbr different issues, such as how to calculate the energy and capacity values of
distributed net-metered systems. The parties also worked together to determine other important
elements of program design, such as the move to nct hourly billing, the inclusion ofa non-export
option, a transition period, parameters for thc use of smart inverters, and determining how
payments ol the Export Credit Rate would be rccovered by the Company. This was a
comprehensive data-driven collaborative study. however, the action of studying these issues did
not result in the physical product ofa study: it resulted in a Settlement Agreement.
The Commission clarilied its directive fiom Order No. 34046 in Order No. 34509. and
clearly stated that it expccted a comprehensive study to be produced by the parlies. Having read
Order No. 34509, Staff understands the importance of a comprehensivc study by which the
Commission can evaluate any I'uture progrirm changc proposals. and supports the process laid out
by the Commission to ensure that the study is credible and fair.
Staff disagrees with thc Company's characterization ofthc documents in the record. The
"Initial Study" refered to by the Company is a nrix of workpapers and Company position
statements. The Company did analyze the data and put forward a strawman proposal, as the
Company describes, which was included in Attachment 4 to the Motion to Approve Settlement
Agreement. Attachment 4 to the Motion to Approve Settlement Agreement is labeled
"WORKPAPERS (PROVIDED ON CD)." The Motion to Approve Settlement Agreement,
which was jointly submitted by Staff and the Company, referred to this information as applying
to Commission Rule of Procedure l2l, *'hich prescribes the form and contents of an application
to change rates, to the extent that rule was applicable to the Company's Application. The
Commission acknowledged this infbrmation was in thc rccord in Order No. 34509 and correctly
assessed, "'l'hese files appear to be the starting point of negotiations between the partics and not
the comprehensive study ordered by the Commission. Though this information is in the
decision-making record, the manner in which it is presented and the lack of context prohibit the
Commission, or the public, from evaluating it in any'meaningful manner." Order No. 34509 at
8-9.
The Company states it submitted the Final Export Credit Rate Study with its Comments
in Support of Settlement Agreement submitted to the Commission on November 6, 2019.
Petition at I 7. This is the first Staff has heard ol' there being a linal study conducted in this
-)STAI--I-ANSWER
docket, and disagrees with the Company's characterization ofthese documents as a study. These
documents desoribe the methodology agreed to by the parties in the Settlement Agreement to
calculate the value of exported energy and the capacity value of distributed gencration. Stalf
believes a valid study would include a discussion of altcmatives considered and greater
explanation for why the method selectcd perlbrms better than the other alternatives, as well as
what metrics are used to determine what better performance means. Additionally, even if these
documcnts could be accurately characterized as a study, they are by no means a comprehensive
study of the Company's net metering program. The Commission made it clear in Order No.
34509 that it expected a comprehensive study to be conducted and filed with the Commission in
order to evaluate any future proposals to change the net metering program design. Thc
Company's belaled oharacterization olthcsc documents as a flnal study, even if accepted. would
not meet the Clommission's standard of a comprehensive study.
II. Thc Company's Claim it Engaged in a Robust Public Notification Process is False.
The Company asks the Commission to find on reconsideration that thc public was on
adequate notice that signilicant net-metering program changes would result from IPC-E-18-15,
and not simply a study of the issues. Additionally, the Company goes on to asseft that
grandf-athering existing customers effectively mooted the notice issue because existing customers
will continue to quality tbr the program they signed up fbr. and new customers are on notice that
program fundamentals are likely to change. Stafl disagrees with both claims.
The Company states that it "engaged in a robust public notification process, providing
ample notice to the public that this docket could result in alterations to the net metering service."
Idaho Power's Petition fbr Reconsideration at 23. The Clompany then states that Attachment 2 to
its petition for reconsideration and/or clarification "contains a long list of such communications
to the public by the Company, StafL the Commission, and others." Id. The only documents in
Attachment 2 issued by the Company are a letter to then-existing Schedule 6 and Schedule 8
customers, and a letter to solar installers. Both letters statc, "Our Oct. l9 filing begins the next
phase of collaboratively studying the beneflts, costs, rate design and propcr compensation
structure for on-site generation customcrs, as directed by the IPUC." Id. All.2 at 4, 5. Both
letters reference "working toward a solution." The lctters did not include a case number,
direction to case documents on the Commission's website. the Commission's contact
4S I'N I-F ANSWER
inlbrmation, or direction to the Commission's customer comment form. The Company's single
attempt at notifying customers did not clearly indicate that rates might change as a result olthis
docket.
Staff also notes that this letter only went to the active and pending 2,994 Schedule 6 and
Schedule 8 customers, and therefore excluded all prospective net-metering customcrs and all
other customers who might have been interested in the issue. The Company has substantial
means to reach its customers including social media, email, bill stuffers, its monthly newsletter,
local television, radio, billboards, bus stop benches, the sides of buses, and other means. Staff
does not agree that letters sent to existing net-metering customers and solar installers lvith
references of a study supports the Company's claim that it "engaged in a robust public
noti lication process."
For lurther support of its claim that the public was on adequate notice that lundamental
changes to the Company's nct-mctcring program were forthcoming, the Company points to 8l
public comments received by the Commission regarding the case in the year between the
Company filing its Application and the liling of the Settlement Agreement. The Company states
this demonstrates "the public not just heard but underslood such changes were possible." Idaho
Power Petition for Reconsideration at 23 (emphasis in original). By the Company's count,
approximately 750% of commenters made statements regarding possible program changcs that
might result lrom the docket. Id. Thus the Company is relying on statements from
approximately .1lYo of all residential customers to support its slatement that the public was
adequately aware that changes to the net-metering program were being considered.
Notably, the Company does not refer to the hundreds of customers who testificd thcy did
not know this case existed, or did not realize that it would result in progrzrm changes, until they
rcceived the Company's lctter notitying them of the Settlement Agreement in late Ootober 2019.
A handf'ul ol customers testified that they knew the case existed and were activcly seeking
infbrmation about it and its possible impacts, but no meaningtul intbrmation about the
discussions or opportunity to directly engage existcd because the settlement negotiations were
confidential.
The Company goes on to claim that grandfathering existing customers effectively moots
the opposition to the Settlement Agreement raised in public comments. Stafl believes the
Company's claim inappropriately assumes that incorporating public feedback into the design and
)STAFIT ANSWITR
review of a comprehensive study would not change the results ol the study. Staf'f also believes
the Company's statement is a mischaracterization of the public testimony because customers
consistently stated that not only did they want to be grandf-athcrcd, but the Commission should
reject the Settlement Agrecmcnt bccause the public was under the impression a study was being
conducted. Staff strongly supports the Commission's directive to engage the public in the design
and review of a comprehensive study that witl be the basis of future proposals to change the
Company's net metering program.
III. Staff Strongly Disagrccs with the Company's Proposed Process Going Forward.
The Company asks the Commission to reconsider the process it prescribed to gain public
input and conduct a credible and fair study. ''ldaho Power respectfully requests . . the
Commission reconsider the extensive procedures it has prescribed lbr oonducting an entirely new
comprehensive study from scratch." Petition at 26. l'hc Company states that the procedure
prescribed by the Commission will send the parties back to the drawing board and discard
thousands of hours of analysis. /r/. In place of conducting a credible and fair comprehensive
study with extensive public input, the Company seeks immcdiate implemcntation of net hourly
billing and a bifurcated study only on thc method to calculate the exported value of energy. This
proposed process disregards the role of public input and would implement a key element of net
metering program design without the benefit of a comprehensive study, contrary to the
Commission's expressed concems in Order No. 34509.
Staff believes the Company's recommendation to implement net hourly billing before the
conclusion of the study ordered by the Commission inappropriately presupposes the outcome of
the study. It appears as though the Company believes the outcome of thc study will not be
changed by public input and additional study by the parties. Staff does not believe the
Commission ordered the public process as a mere lbrmality to bc chcckcd ofT the list prior to
approval of a predetermined net metering program. Staff believes the process ordered by the
Commission is designed to provide more robust analysis, input fiom a wider spectrum ol
perspectives, and result in a program design that more fairly balances thc interests of the
Company and its customers. Additionally, the move to net hourly billing from net monthly
billing u,as perhaps the single most signiticant program change affecting the economio value of'
STATF ANSWER 6
distributed generation systems to net-metering customers in the Settlement Agreemcnt and
theretbre should not be made in isolation without full consideration.
Irurthermore, Staff does not believe the Company's proposal would streamline the
process because addilional justification for the change to net hourly billing would be necessary,
which would require additional process on one isolaled part of the net metering program. The
Commission already stated the record does not support approval ofthe Settlement Agreement, so
it is not clear how the record could support approval ol'one aspect of the Settlement Agreement
that has less evidentiary support than other aspccts ol. the Settlement Agreement, without
substantial further process.
'l'he infbrmation on the record the Company points to in support ol the Settlement
Agreemcnt, which it has retroactively labeled a Final Export Credit Rate Study. describes the
methodology the parties agrecd to use to value exported energy and capacity from distributed
net-metering systems. Yet under the Clompany's proposal fbr a streamlined process, only the
value of exported energy and capacity would be subject to the public process outlined by the
Commission in Order No. 34509. This makes no logical sense. The aspect of the Settlement
Agreement with the most evidentiary support is the valuation of exported energy. The only
aspect of the process going forward the Company wants to continue to study is the valuation of
exported energy. There is a disconncct between the Company's statements that there is
sufficient evidence on the record to approve the Settlement Agreemcnt and the Company's offer
to continuc to study the value ofexported encrgy going lbrward.
Staff believes the parties would not be starting fiom scratch undcr the proposed process
articulated by the Commission in Order No. 34509. Through the last year of study and
settlement negotiations, the parties have gained a deeper understanding of the issues, and more
knowledge about the elements ofnet metering program design. 1'his knowledge and experience
will not be lost and will be very useful in the next phase olnet metering program study. Stalf
believes the parties can build on the work done, share their knowledge and experience with the
public, receive valuable lbedback and input from the public, and continne to refine and hone
policy proposals. Having rcad Order No. 34509, StatT views the process initiated in Order No.
34046 and refined in Order No. 34509 as an iterative process that entails phases of study, review,
incorporation of feedback, and potential redesign until the interests of the Company and its
customers are balanced fairly. StalT sees the IPC-E-18-15 dockel as Phase I ofthe collaborative
7S'IAFF ANSWER
process. Staff sees thc process laid out in Order No. 34509 as Phase II of the collaborative
process. When the Commission determines a credible and fair study has been complcted that is
adequately comprehensive, then the parties will move to Phase III, which Staff anticipates will
be proposals tbr program change.
Staff believes the Settlement Agreement provides an excellent point of reference lbr
future study. Staff believes the Settlement Agreement can be used as a well-honed strawman
proposal of what one program design could look like. The Company. the parlies, and intcrested
net-metering customers can lrack what implementation olthe Settlement Agreement would havc
done and compare it to the continued effects ol'Schedule 6 and Schedule 8 as they still exist.
'Ihis will provide a valuable point of ref'erence fbr future study and consideration, and should
relieve some ofthe Company's constcmation about starting from square one.
The Commission should reject the Company's proposed process, and adhere to the
process the Commission laid out in Order No. 34509.
IV. Interim Customers Do Face Some Unccrtainty from thc Commission's Order,
The Company, Idaho Conservation League and Vote Solar, and thc ldaho Clean Energy
Association, as well as other pctitioners, made proposals regarding the treatmcnt ol'interim
customers, and noted the level of uncertainty faccd by prospectivc net-metering customers. Any
customer who was considering installing a net-metering system, but did not make a binding
financial commitment do so on or before December 20.2019. must now make an investment
decision knowing that the net-metering program structure is likely to change, but with no insight
into how the program struclure is likely to change. Additionally, the Residential Solar Energy
Disclosure Act ("RSEDA") requires solar retailers to provide potential customers with written
estimates of the "estimated proj ected savings over thc life ol'the solar agreement and the
estimated projected savings over any longer period not to exceed thc anticipated useful lifb of the
system. ." Idaho C'ode $ 48-1805(2). However, il the solar retailer does not have thc
information required to be disclosed in the RSIIDA. the solar retailer "may make a good faith
estimate of that inlonnation in the disclosure statcment if the solar retailer clearly indicates that
the inlbrmation is an estimate and provides the basis fbr the estimate." ldaho Code $ 48-1808.
Staff believes that Order No. 34509 and the RSEDA can be hamronized, and solar retailers can
make informed good faith estimates. Neverlheless, Stall acknowledges that the uncertainty may
IJSTAFF ANSWER
unintentionally create more room fbr unscrupulous actors to proffer misguided estimates, while
making it more difficult for scrupulous actors to provide accurate estimates.
The Idaho Conservation League and ldaho Clean Energy Association, among others,
asked the Commission to allow customers to be grandfathered until such time as the Commission
implements program changes. If the Commission would like to reduce uncertainty during the
interim, a statement fiom the Commission that it will apply future program changes
prospectively. to new customers only, would resolve much of the uncertainty complained of by
the parties.
As previously stated, Stafl'believes the Company's proposal to immediately implement
net hourly billing is ill-conceived and not supported by inlbnnation on the record. But, in line
with the Commission's directive to incorporate public l'eedback, one option to address the
unccrtainty expressed by petitioners could be lor the Commission to state that interim customers
(those customers who make a binding financial commitment to install a net-metering system
atler December 20, 2019, and betbre the next programmatic changes are authorized or
implemented) would be eligible to receive net monthly billing fbr the warrantied life of their
system. This differs from the Cornpany's proposal to immediately implcment net hourly billing
bccause net monthly bilting is thc status quo, and would not be a program change. Solar retailers
and potential net-metering customers have easy access to monthly billing data, and familiarity
with the characteristics olnet monthly metering. Other aspects ofthe program, such as the value
fbr excess energy, would be subject to change whcn the Commission implements an updated net
metering program. This could result in a fair balance between some certainty tbr prospective
customers upon which they can make a large financial investment, and would prevent an
overwhelming surge of customcrs signing up for nct-metering in the interim period.
Additionally, this could undercut thc ability of'unscrupulous solar retailers lrom presenting
overly optimistic potential retums that would never be realized while allowing solar retailers
operating in good faith to make reasonable fbrecasts.
V. Clarification or Reconsideration on Grandfathering may bc Appropriate.
In its petition, the Company requests clarification on the specifics of grandfathering in
order to prevent unforeseeable or unstoppable life events tiom eliminating the grandfathered
status of a customer. Staff believes that grandfathering the system, as opposed to the customer,
9STAFF ANSWE,R
would remove many of the uncertainties identified by the Company. The Company, in a cross-
petition, stated it does not oppose grandtathering by system location for 25 years rather than by
customer indefinitely, and that this would be consistent with the practice in other states. Idaho
Power Company's Answer/Cross-Petition to Richard Kluckhohn's Requcst for Reconsideration
at 5. Additionally, to address the issues raised in thc pctition lor clarification or reconsideration
submitted by Thomas Baskin, the Commission could reconsider whether to allow expansion of
grandfathered systems within certain parameters, or clarify the extent to which the Commission
allows repair and replacemcnt ofsystem components.
In the alternative to grandtathering the system to relieve future confusion and complaints.
the Commission could clarifo exemptions to losing grandlathered status based on difficutt life
events. The loss of grandiathered status duc to unlbreseen or unavoidable life events would
create situations of unfaimess and would likely result in numerous complaints to the
Commission throughout the years. Stalf agrees that in the case of the death of a spouse, the
surriving spouse should be able to continue to receive thc grandfathered status, regardless of
which spouse's name was on the bill. Staffalso believes this logic should extend to unmarried
couples living together, regardless of which partner's namc was on the bill. Staffalso belicvcs it
should cxtend to incidents of mental or physical incapacity, in addition to death. These are but a
feu'examples of the difficulty oladministering grandlhthered status by customer, and StatTnotes
that these diffrculties would arise for a customer during precarious, uncertain, and trying times in
their lives when the custorners have morc pressing concerns to deal with. Staff believes it may
be possible to include language that provides for possible exoeptions based on situations that are
unduly unlair, but trying to predict all possible exceptions to the rule seems difficult at best, and
would still require casc by case determination well into the iuture.
Stalf disagrees with the Company's assertion that Order No. 34509 provides notice to all
customer classes that the compensalion structure may change. 'l'his docket deals specifically
$,'ith Schedule 6 and Schedulc 8, which are for residential and small general sen'ice net-metering
customers respectively. The Company llled IPC-E-I7-13 to separate these customer classes
from Schedule 84, which prior to Order No. 34046, containcd all net-metering customer classes.
Because this case pertains only to residential and small general service customers, StafT believes
Order No. 34509 should only apply to these customer classes. Additionally. the Company cites
to the Commission's iustification in Order No. 34509 to grandl'ather customers, which includes
STAFF ANSWER t0
relerence to the RSEDA.
for residential customers
It is worth pointing out that this Act dictates disclosure requirements
The Act defines a "consumer" as "a person who,lbr rrrimariiy
nersonal. fhmilv,or houselrold DurDoscs [plurchases a residential solar energy system . . ."
(emphasis added). Idaho C-ode $ 48-1802(1). 1'hus, neither the Commission's Order, nor the
RSEDA provides notice to customers outside of Schedules 1, 6, 7, or 8 (residential and small
general service schedules).
The Company also asks for claritication that grandfathered customers in Schedule 6 and
8 will be subjcct to rate structures and consumption rates thal may be implemented after a "future
rate proceeding." Staff notes that the language in the order explicitly states that proposals fbr
these changes should "be made only in a general rate case," u,hich does not necessarily align
with the Company's more vague description ofqualitying dockets as a "tuture rate proceeding."
Vl. Impacts on IPC-E-I9-15: Application to Study Measuremont Inten'al for On-Site
Generation Undcr Schedule 84
Staff recommends the Commission direct the Company to u'ithdraw its Application in
IPC-E-19-15. That case was conducted in a manner almost idcntical to IPC-E-I8-15. which the
Commission tirund to not sufficiently include public pa(icipation and required the completion of
a credible and leir comprehensive study. Staff believes it would be reasonable lbr the
Commission to direct partics in IPC-E-19-15 to prepare a comprehensive study using the same
procedures and the same criteria established by Order No. 34509 fbr residential and small
general service customers.
Respectfutly submitted this tTtt- day of .Ianuary 2020.
Fldu,ard.T.
Dcputy Atto General
tJ m isc/Commcnts,'ipcc I 8. I 5 ej recons ideralion .esponst
L(
STAFF ANSWER ll
CERTIFICATE OF SERVICE
I HEREBY CER'IIFY THAT I HAVE THIS ITTH DAY OF JANUARY 2020,
SERVED THE FOREGOING STAFF'S ANSWER TO PETITIONS FOR
RECONSIDERATION, IN CASE NO, IPC.H,-I8.15, BY MAILING A COPY THERI]OII,
POSTAGE PREPAID. TO THE FOLLOWIN(}:
LISN D NORDSTRONI
II)AHO POWER COMPANY
PO BOX 70
BOISE rD 83707-U)70
E-MA IL : lnordstronrr'zrii dahoporver.cor.r.r
ERIC L OLSEN
ECHO HAWK & OLSEN PLLC
PO BOX 6l l9
POCA'TEI,LO ID 83205
E-MAIL: [e-mail]
Ta-vsl.rali-t)ec o harryk. c orn
C TOM ARKOOSH
ARKOOSH LAW OFFICES
PO BOX 2900
BOISE ID 83701
E-MAIL: tom.arkoosh ark
tavlor'.pestcll rkoosh.com
YVONNE R HOGI,I,
ROCKY MOUNI'AIN POWTR
1407 WN TEMPLE S'I'D 320
SAL'I' LAKF CITY I]'I' 84I I6
E-MAIL: Yvonne.hosle
'IIM TATT]M
CONNIE ASCHENBRENNER
IDAHO POWER COMPANY
PO BOX 70
IlorsE rD 83707-0070
E-MAIL: ttatunlaa)idahopower.con'r
caschenbrcnnc-r? idahopo* cr.corl
EI,E,CTRONI(] ONI,Y
[e-mail]
TE,D WESTON
ROCKY MOUNTAIN POWER
1407 WN TEMPLE STE 330
SAL'I'LAKE CITY UT 84I I6
E-MAIL: ted.westoryiiipqc!!jcerp.cenlh.
nacilicom.com
ELE,CTRONIC SERVICE, ONLY
AL LTINA
aluna(acarthiusticc.ors
NICK'IHORPIT
DAVID BENDER
EARTHJUSTICE
39I6 NAKOMA RD
MADISON WI 537I I
E-MAIL: dbender(Zrlrearth iustice.ersnthttrPefn-]eafth justice.trrq
CERTIFICATE OF SERVI(-E
BENJAMIN J OTTO
ID CONSERVA'|ION LI]AGUE
710 N 6'I'H STREET
BOISE ID 83702
D-MAIL : botlo(g)idahoconservation.org
ANTHONY YANKEI,
I27OO LAKE AVE
UNIT 2505
LAKEWOOD OH 44I07
[,-MAIL: tony@yq*sl.-!91
BRIANA KOBOR
VOTE SOLAR
358 S 7OO E STE 8206
SALT LAKE CITY UT 84I02
E-MAIL: brianaG)votesolar.ors
ABIGAIL R GERMAINE
BOISE CITY ATTORNEY'S OFFICE
PO BOX 500
BOISE ID 83701-0500
E-MAII-:rmaine cl ,olboise.o
KELSEY JAE NUNEZ
IDAHO SIERRA CI-UB
920 CLOVER DR
BOISE ID 83703
E-MAIL : kelsey(Okelseviaenunez.con'r
.IIM SWIER
MICRON TECHNOLOGY INC
8OOO S FEDERAL WAY
BOISE ID 83707
E-MAIL: i swier(a)nricron.com
DR DON RLADING
6070 IIILL ROAI)
BOISE ID 83703
E-MAIL: tlrcadineiAmindsprins.conr
CL,RI'II-'IC]A'I'F] oI.' SERVICE
F DIEGO RIVAS
NW ENERGY COALITION
1I01 8I'H AVE
IIELENA MT 5960I
E-MAIL: diego(ir)nwenergr-.org
PETER J RICHARDSON
RICHARDSON ADAMS PLLC
515 N 27TH STREET
PO BOX 7218
BOISE ID 83702
E-MAIL: [e-mail]
PRESTON N CARTER
GIVENS PURSLEY LLP
60I WBANNOCKSTREET
BOISE ID 83702
E-MAIL: [e-mail]
ZACK WATERMAN
MIKE HECKLER
IDAHO SIERRA CI,UB
503 W FRANKLIN ST
BOISE ID 83702
E-MAIL : [e-mail]
michacl.p.hecker@smai l.com
AUSTIN RUESCHHOFF
THORVALD A NELSON
HOLLAND & HART LLP
555 7TH ST STE 32OO
DENVER CO 80202
E-MAIL: darueschhof'[e-mail]
tnelson2?hollandhart.com
RUSSELL SCHIERMEIER
29393 DAVIS ROAD
BRIINEAU ID 83604
E-MAIL : buyhay6r)smai l.corn
RICHARD E. KLUCKHOHN
2564 W. PARKSTONE DR.
MERIDIAN ID 83646
E-MAIL: kluckhohnfa)smail.com
ZOE ZIEGLER
BOISE HIGH SCHOOL
E-MAIL : zmzistilive.con.r
CHEYON SHEEN
BOISE STATE LTNIVERSITY
E-MAIL: cheyonsheenfa)u.boisestate.edu
THOMAS BASKIN
3688 N. WILLOWBAR WAY
GARDEN CITY ID 837I4
E-MAIL: [e-mail]
MICAH HORNBACK
209 E 34TH STREET
GARDEN CITY ID 837I4
E-MAIL: micah.hombacktrlgrnail.cat:t
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