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HomeMy WebLinkAbout20171103Partial Joinder in Motion to Dismiss.pdfRyan B. Frazier (Idaho Bar No. 6201) rfrazier@kmclaw.com Brian W. Burnett Qtro hac vice applicationfurthcoming) bburnen@kmclaw.com KIRTON McCONKIE Kirton McConkie Building 50 E. South Temple, Suite 400 P.O. Box 45120 Salt Lake city, Utah 84145-0120 Telephone: (80 I ) 328-3600 Fax: (801) 321-4893 Ittorneys for Intermounlain Wind and Solar, LLC RECEIVED ?0llHOy-3 pil t:L5 urt1?,#Pctur,frhI8r,o* BEFORB THE IDAHO PUBLIC UTILITIES COMMISSION Case No. IPC-E-17-13IN TI-IE MATTER OF IDAHO POWER COMPANY'S APPLICATION TOR AUI'HORITY TO ESTABLISH NEW SCHEDULES FOR RESIDENTIAL AND SMALL GENERAL SERVICE CUSTOMERS WI]]-I ON.SITE GENERATION INTERMOUNTAIN WIND AND SOLAR, LLC'S PARTIAL JOINDER IN MOTION TO DISMISS AND MEMORANDUM IN SUPPORT OF MOTION TO DISMISS Pursuant to Rules of Procedure 56 and 256, Intermountain Wind and Solar, LLC ("lWS") hereby submits this Partial Joinder and Memorandum in Support of Idaho Clean Energy Association's Motion to Dismiss. IWS partially.joins the Motion to Dismiss filed by Idaho Clean Energy Association ("ICEA") and the joinders filed by Auric Solar, LLC, the Idaho Conservation League, and the City of Boise. I. IDAHO POWER HAS FAILED TO COMPLY WITH ORDER NO.32846 IWS joins ICEA's argument set forth in the Motion to Dismiss that Idaho Power failed to fbllow the Idaho Public Utility Commission's (the 'oCommission") 2013 Order No. 32846 by seeking essentially the same relief it sought in 2013. In that Order, the Commission declined IN'I'ERMOUNTAIN WIND AND SOLAR, LLC'S PARTIAL JOINDER IN MOTION TO DISMISS AND MEMORANDUM IN SUPPORT OF MOTION TO DISMISS - I 48 I 7-768 I -493 I .v I Idaho Power's request to establish a new rate class and different schedule for residential and small general service customers with on-site generation outside of a general rate proceeding. Idaho Power's Application tlled in July 2017 petitions the Commission to do what it sought to do in 201 3. Proceeding in this maruler, Idaho Power has failed to follow 2013 Order No. 32846. In the interest of procedural economy, IWS will not reiterate the arguments raised by the other parties. Instead,IWS hereby generally joins in the arguments raised by ICEA in support of its Motion to Dismiss and the joinders and partial joinders submitted by Auric Solar, LLC, the Idaho Conservation League, and the City of Boise and add only the following in suppo* of the submissions: Idaho Power has not demonstrated any changed circumstances that would justif establishing a separate class for residential and small general service customers with on-site generation without following the procedure and requirements previously outlined. Foremost, Idaho Power has not shown that a separate class is needed. It has also not been shown that the current net metering pricing structure is inadequate or should be overhauled. This does not mean that the value of distributed generation should not be evaluated, but it should be addressed following a procedure that is specifically calculated to perform that evaluation and that can appropriately consider the costs and benefits associated with distributed generation. IWS's recommendation on how this should be done is set for-th below. TI.AS AN ALTBRNATTVE TO DISMISSAL, A PROCESS SHOULD BE IMPLBMBNTBD FOIT THB STUDY AND BVALUATION OF THE COSTS AND BENEFITS OF DISTRIBUTED ENERGY. Rather than dismissing this matter, IWS joins in the requests of ICEA, the City of Boise, Auric Solar, and the Idaho Conservation League that an alternative procedure should be employed in this case to assess the benefits and costs of distributed energy. There is no question INT'ERMOUN'TAIN WIND AND SOLAR, LLC'S PARTIAL JOINDER TN MOTION TO DISMISS AND MEMORANDUM IN SUPPORT OF MOTION TO DISMISS .2 48 I 7-768 I -493 I .v I that distributed energy creates certain benefits to the electrical system but simultaneously imposes certain burdens on the system. A process needs to be employed to study, understand, and explore the resulting impacts, issues, costs and benefits of solar and other energy generation Further, the process should allow public input. IWS agrees with the Idaho Conservation League that the process should be transparent, identify the issues and elements to be considered, and should properly identify forrnulae and methodologies to appropriate value the elements that should be considered. Specifically, IWS hereby proposes that the process should include the following features: . A solar integration study similar to the one employed in Case No. IPC E-14-18 (discussed more fully below) should be conducted. However, the study should be modified as explained in the next subsection; Workshops could be conducted between Idaho Power and interested parties and the Cornmission's staff to work on a settlement to set net metering rates and the value of distributed energy; and Arr Export Credit Proceeding should be initiated and conducted as discussed more fully below. 'fhe Stipulated Process from Case No. IPC E-14-18 May Supply a Framework for a Solar lntegration Study, but the Process Should be Modified in this Instance. Many of the parties have suggested that the stipulated process conducted in Case No. IPC E- l4- I 8 (the *2014 Process") should be followed here for resolving questions of net metering costs and benefits. The 2014 Process involved a solar integratiorr study. IWS agrees that a solar integration study would be beneficial and appropriate and should be part of the process, but IWS departs from the view that the 2014 Process is ideal. Foremost, a study should not be the only component of the process followed in this matter. Further, the 2014 Process should merely provide a fi'amework that is modified to ensLlre that all interested parties have input and that the INTERMOUN'TAIN WIND AND SOLAR, I.LC'S PARTIAL JOINDER IN MOTION TO DISMISS AND MEMORANDUM IN SUI]PORT OT MOTION TO DISMISS .3 a a A. 4817-7681493 I .v I process is not irrordinately influenced by the utility seeking the separate class and the revised rates, Idaho Power. Therefore, the following changes should be made to the process. First, any study needs to be complete and comprehensive. More time should be allowed to complete the stucly than the length of time for the study conducted as part of the 2014 Process. That study was not to exceed l2 months. However, a more thorough study would likely require more time, perhaps even up to three (3) years. Accordingly, the length of time permitted for an integration study should be expanded. Second, Idaho Power, the party seeking the rate modifications and the establishment of a separate class, should not be responsible for determining how the study is to be conducted. As used in the 2014 Process study, a Technical Review Committee ("TRC") should be employed for the study. Although the 2014 Process mentions the involvement of various parties in the TRC, the 2014 provided that"Idaho Power is ultimately responsible for determining how the study is conducted, the content of the study, and any results therefrom.'n (Settlement Stipulation and Mot. to Approve Settlement Stip. (the "2014 Stipulation"), attached hereto as Exhibit "A," 11 7 (emphasis added).) Affording the utility control and responsibility for how the study is conducted gives Idaho Power too much influence over the study. A single interested party should not exert disproportionate control as that may skew the study's end results or introduce unwarranted partiality into the process. Idaho Power certainly should be involved with the study and have its proportionate say in how it is conducted, but it should not be the exclusive responsible party with only a duty to explain why it declined to follow TRC member suggestions as the 201 4 study contemplated, Instead, other interested parties should have influence on how the study is conducted and the content of such study. INTERMOUNTAIN WIND AND SOLAR, LLC'S PARTIAL JOINDER IN MOTION TO DISMISS AND MEMORANDUM TN SUPPORT OF MOTION TO DISMISS - 4 48 I 7-?68 I -493 I .v I Third, the list of items to be considered in a solar integration study listed in paragraph 8 of the Settlement Stipulation and Motion to Approve Settlement Stipulation should not be an exhaustive list of topics for inquiry. (See 2014 Stipulation, Ex, "A,"'118.) The list is a sta(ing point for the study. However, the TRC should be allowed to expand the list of iterns to be considered as the'fRC reviews and develops what needs to be studied. As the study is conducted, it may become apparent that other issues may need to be evaluated or existing topics expanded. B. An Export Credit Proceeding Should be an Integral Part of the Process. Finally, an Export Credit Proceeding should be initiated to determine the compensation rate for exported power from customer generation systems. in the Export Credit Proceeding, the Commission will determine a just and reasonable rate for export credits for customer generated electricity. Idaho Power would facilitate a workshop with the Parties and other stakeholders soon after the Export Credit Proceeding is initiated to discuss the type and scope of data expected to be considered in determining the appropriate export rate. In order to accommodate data collection, allNEM Customers randomly selected must participate in any load research study. Participation in a load research study may include installation of meters at the point of delivery and on the customer generation system. No costs will be assessed to the custorners included in a load research study. The Export Credit Proceeding would culminate in and conclude with a hearing. The hearing would be no later than three (3) years after the proceeding is initiated, The parties should be allowed to present evidence at a hearing in an Export Credit Proceeding addressing reasonably quantifiable costs or benefits or other considerations they deem relevant. The Party INTERMOLINTAIN WIND AND SOLAR, LLC'S PARTIAL JOINDER IN MOTION TO DISMISS AND MEMORANDUM IN SUPPORT OF MOTION TO DISMISS .5 4817-7681-4931.v1 asserting any position would bear the burden of proving its assertions. Based on the evidence presented, the Comrnission would then be able to determine the compensation rate for exported power from customer generation systems. CONCLUSION IWS supports and hereby joins the arguments raised in the ICEA's Motion to Dismiss and the joinders filed by Auric Solar, the City of Boise, and the Idaho Conservation League. I-lowever, rather than dismissing this action outright, the Commission should employ an alternative approach to address the costs and benefits of distributed energy in ldaho. IWS hereby respectfully requests that the Commission follow the process recommended herein. DATED this 3rd day of November,20l7. Respectfully submitted, KIRTON (lSB No Brian W. Burnett (pro forthcoming) INTERMOUN]'AIN WIND AND SOLAR, LLC'S PARTIAL JOINDI]R IN MO'TION'fO DISMISS AND MEMORANDUM IN SUPPORT OF MOTION TO DISMISS .6 48 I 7-768 l -493 l.v I CBRTIFICATE OIT SERVICE I hereby cerlify that on the 3rd day of November, 2017, I caused a true and correct copy of the foregoing INTERMOLINTAIN WIND AND SOLAR, LLC'S PARTIAL JOINDER iN MOTION TO DISMISS AND MEMORANDUM IN SUPPORT OF MOTION TO DISMISS to be served upon the {bllowing by the method indicated: Diane Hanian Idaho Public Uw ID 742) f imothy Il, Taturn Connienschenbrenner (n7a2) Ilolss,83707-0070 Suite 900 tom C. Tom Arkoosh Arkoosh Law Offices 802 W Bannock Street, Suite 900 Boise,ID David H. Arkoosh Law Office of David Arkoosh ( ) U.S. Mail( ) I{and Delivered(X) FedEx( ) Facsimile( ) EmailiE-filer ()()tl(x) U.S. Mail Hand Delivered FedEx FacsimileEmail/E-filer ( ) U.S. MailI ) Hand Delivercd( ) FedExI i Facsirnile(X) Email/E-filer ti LI U.S. Mail Hand Delivered FedExFacsimile Email/E-filer 1 II(x) t] LI U.S. Mail Hand Delivered FedEx Facsimile EmaillE-filer U.S. Mail Hand Delivered FedEx Facsimile Email/E-filer P.O. Box 2817 Boise. ID 83701 d av i d (rDarkoosh I aw. com INTERMOIJNTAIN WIND AND SOLAR, LLC'S PARTIAL JOINDER IN MOTION TO DISMISS AND MEMORANDUM IN SUPPORT OF MOTION TO DISMISS .7 48 I 7-768 l -493 I .v I 83707-0074 Idaho lrrigation Pumpers Association, Inc. Eric L. Ol-sen ECHO HAWK & OLSEN, PLLC 505 l'}ershinp Avc.- Ste. 100 P.O. Box 6l'19 Pocatello. Idaho 83205 elo6)echrihawk.corn Anthony Yankel 12100 take Avenue, Unit 2505 Lakewood. Ohio 44107 tonv@uankel.net L] [.J U.S. Mail Hand Delivered FedEx FacsimileEmail/E-filer U.S. Mail Hand Delivered liedEx FacsimileEmail/E-filer U.S. Mail Hand Delivered FedEx Facsirnile Email/E-filer 472W Boise, ( ) U.S. Mail( ) Fland DeliveredI 1 pedpxt 1 Facsimile(X) Email/E-filer Beniamin J. Otto 7 l 0t { 6tn Street Boise. ID 83701 botto@idahoconservati on, org Robe( C. Luce Abieail R. Germaine Bois"c Citv Attorncv's Office 150 N. Cinitol Blvil. P.O. Box 500 Boise. lD 83701-0500 aserniai nc@ci tyo fboise. org t] LI [,J U.S. Mail Hand Delivered IredEx Facsimile EmailiE-filer uT 84119 tl LI U.S. Mail Hand Delivered FedEx Facsimile EmaillE-filer ( ) U.S. Mail( 1l-Iand DeliveredI 1 Fedex( ) Facsimile(X) Email/E-filer Kelsey Jae Nunez LLC Sierra Club 920 N. Clover Dr. Boise, ID 83703 kc I sevdDke I sevi aenunez.corn [.J U.S. Mail Hand Delivered FedEx Facsimile Email/E-filer INTERMOUN'I'AIN WIND AND SOLAR, LI-C'S PARTIAL JOINDER IN MOTION TO DISMISS AND MEMORANDUM IN SUPPORT OF MOTION TO DISMISS .8 4817-7681-4931.v1 Costello Zack Waterrnan Idaho Sierra CIub 503 W. Franklin St. Boise. ID 83702 zack. waterrnan(?idahosiertacl ub,orq MichaelHeckler m ichael.p.heckler@srnai Lcorrl David Bender Earthiustice3gl6Nakoma Rd. Madisorr, WI 5371I d bender@earthj ustice.org Briana Kober Vote Solar 360 22no St.. Suite 730 Oakland. CA 94612 briana@votesolar.conr ( ) U.S. Mail( ) I-land DeliveredI ) FedExI l Facsimile(X) Email/E-filer U.S. Mail Fland Delivered FedEx Facsimile Email/E-f-rler U.S. MaiI Hand Delivered FedEx FacsimileEmail/E-filer LJ.S. Mail Fland Delivered FedEx Facsimile EmaillE-filer U.S. Mail Hand Del FedEx Faesimile ivered Email/E-filer U.S. Mail Hand Delivered FedEx Facsimile EmaillE-tller U.S. Mail Hand Delivered FedEx Facsimile Email/E-filer U.S. Mail Hand Delivered FedEx FacsirnileEmaillE-filer t] Li ()tl Ir] ti [*J Srrake River Alliance wwi lson@snakeriveral liance.ore NW Errersy Coalitiondieqo@nfi'energy.org Michael Heckler m ichael.p.heckler@.gmai l,com John R. Hammond. Jr Fisher Pusch. LLP' P.O. Box 1308 Boise. tD 83701 irh@tisherpusch.com [,J [,J [.J t]() t.l \I U$.^rh}^,,.,r. \ qlJ.t"O)AD U INTERMOUNTAIN WIND AND SOLAR, LLC'S PARTIAL JOINDER IN MOTION TO DISMISS AND MEMORANDUM IN SUPPORT OF MOTION TO DISMISS - 9 48 I 7-768 I -493 Lv I EXHIBIT A DONOVAN E. WALKER (lSB No, 5921) ldaho Power Company 1221 West ldaho Street (83702) P.O. Box 70 Boise, ldaho 83707 Telephone: (208) 388-5104 Facsimile: (208) 388-6936 d:virikqrG), deLqp o-lvgr-laul Attorney for ldaho Power Company BEFORE THE IDAHO PUBLIC UTILITIES COI\IIMISSION IN THE I\XATTER OF IDAHO POWER COI\4PANY'S APPLICATION TO IMPLEMENT SOLAR INTEGRATION RATES AND CHARGES. CASE NO. IPC.E-14-18 SETTLEMENT STIPULATION AND MOTION TO APPROVE SETTLEMENT STI PU LATION This settlement stipulation ("Settlement Stipulation") is entered into between ldaho Power Company ("ldaho Power" or "Company"); ldaho Public Utilities Commission Staff ("Staff"), the ldaho Conservation League ("lCL"), the Sierra Club, and the Snake River Alliance ("SRA'), hereafter jointly referred to as "Parties." The Parties hereby agree as follows. I. INTRODUCTION AND MOTION 1. The terms and conditions of this Settlement Stipulation are set forth herein. The Parties agree that this Settlement Stipulation represents a fair, jr.rst, and reasonable compromise of the dispute(s) between the Parties and that this Settlement Stipulation is in the public interest. The Parties maintain that the Settlement Stipulation as a whole and its acceptance by the ldaho Public Utilities Commission ("Commission") represent a reasonable resolution of all issues between the Parties identified herein. IPC-E-14-18 1 Joint Settlement and lVlotion Therefore, the Parties hereby respectfully move the Commission, in accordance with RP 56 and RP 274-76, for an Order approving the Settlement Stipulation executed between the Parties and all of its terms and conditions without material change or condition. II. BACKGROUND 2. On July 1,2014,ldaho Power filed an Application with the Commission requesting Commission approval of ldaho Power's proposed implementation of solar integration rates and charges as set forth in the proposed Schedule 87, Variable Generation lntegration Charges, as indicated by the 2014 Solar lntegration Study Report ("Solar Study") filed with the Application. On July 23, 2014, the Commission issued a Notice of Application and Notice of lntervention Deadline. Order No. 33079. lCL, the Sierra Club, and SRA petitioned for intervention which was granted, Order No. 33090; Order No. 33097, 3. On September 24, 2014, the Commission issued a Notice of Scheduling and Notice of Technical Hearing, Order No, 33137, setting forth deadlines fortestimony and setting the Technical Hearing for November 13,2014. On November 6,2014, the Commission approved the Parties' request to suspend the procedural schedule by striking the rebuttal testimony filing deadline and Technical Hearing, The Parties agreed to meet for settlement discussions and that if settlement discussions were unsuccessful to re-establish mutually agreeable dates for the submission of rebuttal testimony and a Technical Hearing. Order No. 33173. 4, The Padies met on November 17, 2A14, for settlement discussions and reached agreement resolving the issues in this case and between the Parties, Based upon the settlement discussions, as a compromise of the respective positions of the |PC-E-14-18 2 Joint Settlement and l/otion padies, and for other consideration as set forth below, the Parties agree to the following terms III. TERMS OF THE SETTLEMENT STIPULATION 5. lmplementation of Schedule 87. Variable Generation lntegration Charses - The Parties agree to Commission approval and implementation of Schedule 87, Variable Generation lntegration Charges, including the rates and charges as proposed and filed by ldaho Power in this proceeding to implement solar integration charges. 6. lnitiation of a. Second Solar lntegration Sturdy * The Parties acknowledge that there are disagreements with respect to the methodology used in the 2014 Solar Study. The Parties agree that ldaho Power will initiate a second solar integration study in January 2A15. This second solar integration study should be completed as expeditiously as possible with the goal of not exceeding 12 months. Upon completion of the second solar integration study ldaho Power will file the same with the Commission seeking to update Schedule 87 with the results of said study. 7 Conduct of the Second Solar I nteo ratio n Studv - The Parties agree that the second solar integration study should utilize a Technical Review Committee ('TRC') that generally adheres to the Principles for Technical Review Committee lnvolvement in Sludies of Wind lntegration into Electric Power Sysfems authored by the National Renewable Energy Laboratory and the Utility Wind lntegration Group. The TRC should include members with expeftise in solar generation, variable energy integration, and electrical grid operations. The Parties also anticipate participation in the second solar integration study from the ldaho Public Utilities Commission Staff, the Public Utility Commission of Oregon Staff, the appropriate personnel from ldaho Power, and a techrrical expert designated by each of the Parties herein. The Parties agree that the IPC-E-14-18 3 Joint Settlement and [t/otion TRC will assist in developing the scope of the second solar integration study and provide advice on the best available methods to analyze solar integration needs, strategies, and costs on ldaho Power's system. The Parties agree and acknowledge that ldaho Power is ultimately responsible for determining how the study is conducted, the content of the study, and any results therefrom. lf ldaho Power declines TRC member suggestions for the conduct of the study, ldaho Power shall provide explanation and basis for the same in writing as part of the study process. B Consideration of lssues in the Second Solar I nteoration Studv The Parties agree that ldaho Power, together with the TRC, will consider whether the second solar integration study should include the following * and if so, what would be the appropriate methodology to be used in connection with the following: . Alternative water-year types (e.9., low-type and high-type), range of water years or normalized water year . lntra-hour trading opportunities . Shortening the hour-ahead forecast lead time from 45 minutes to 30 minutes . Clustered solar build-out scenarios Other solar plant technologies (e,g., tracking systems or varied fixed-panel orientation) Correlation between solar, wind, and load variability, uncertainty, and forecasting error, lmproved forecasting methods Energy imbalance markets, or other market structures Voltage/freq uency regulation lncreased transmission capacity, changes in operation of hydroelectric facilities, addition of demand-side technologies IPC-E-14-18 Joint Settlement and Motion a a a a 4 Gas price forecast(s) Modeling of sub-hourly scheduling of load and generation ldentification of the existence of low occurrence events that contribute to proportionately higher integration costs and possible remedies, including operational or contractual solutions to mitigate these events and reduce integration costs and charges. 9. The Parties submit this Settlement Stipulation to the Commission and recornmend approval in its entirety pursuant to RP 274-76. The Parties shall support this Settlement Stipulation before the Commission and shall not appeal a Commission order approving the Settlement Stipulation or an issue resolved by the Settlement Stipulation. lf this Settlement Stipulation is challenged by anyone who is not a Party, then each Party reserves the right to file testimony, cross-examine witnesses, and put on such case as they deem appropriate to respond fully to the issues presented, including the right to raise issues that are incorporated in the settlements embodied in this Settlement Stipr.rlation. Notwithstanding this reservation of rights, the Parties agree that they will continue to support the Commission's adoption of the terms of this Settlement Stipulation. 10. lf the Commission or any reviewing body on appeal re.iects any part or all of this Settlement Stipulation or imposes any additional material condltions on approval of this Settlement Stipulation, then each Party reserves the right, upon written notice to the Commission and the other Party to this proceeding within fourteen (14) days of the date of such action by the Commission, to withdraw from this Settlement Stipulation. ln such case, no Party shall be bound or prejudiced by the terms of this Settlement Stipulation and each Party shall be entitled to seek reconsideration of the Commission's IPC-E-14-18 Joint Settlement and Motion a a 5 order, file testimony as it chooses, cross-examine witnesses, and do all other things necessary to put on such case as it deems appropriate. ln such case, the Parties immediately will request the prompt reconvening of a prehearing conference for purposes of establishing a procedural schedule for the completion of IPUC Case No. IPC-E-13-25, and the Pailies agree to cooperate in development of a schedule that concludes the proceeding on the earliest possible date, taking into account the needs of the Parties in participating in hearings and preparing briefs. 11. The Parties agree that this Settlement Stipulation is in the public interest and that all of its terms and conditions are fair, just, and reasonable. 12. No Party shall be bound, benefited, or prejudiced by any position asserted in the negotiation of this Settlement Stipulation, except to the extent expressly stated herein, nor shall this Settlement Stipulation be construed as a waiver of rights unless such rights are expressly waived herein. Except as othenvise expressly provided for herein, execution of this Settlement Stipulation shall not be deemed to constitute an acknowledgment by any Pafty of the validity or invalidity of any particular method, theory, or principle of regulation or cost recovery, including the methodology employed for the 2014 solar integration study upon which the rates and charges contained in Schedule 87 are based, No Party shall be deemed to have agreed that any method, theory, or principle of regulation or cost recovery employed in arriving at this Settlement Stipulation is appropriate for resolving any issues in any other proceeding in the future. No findings of fact or conclusions of law other than those stated herein shall be deemed to be implicit in this Settlement Stipulation. This Settlement Stipr,rlation sets forth the complete understanding of the Parties, and this Settlernent Stipulation includes no other promises, understandings, representations, arrangements or agreements pertaining to IPC-E-14-18 6 Joint Settlement and lvlotion the subject matter of this Settlement Stipulation, or any other subject matter, not expressly contained herein. 13. The obligations of the Parties are subject to the Commission's approval of this Settlement Stipulation in accordance with its terms and conditions and upon such approval being upheld on appeal, if any, by a court of competent jurisdiction. All terms and conditions of this Settlement Stipulation are subject to approval by the Commission, and only after such approval, without material change or modification, has been received shall the Settlement Stipulation be valid, 14. This Settlement Stipulation may be executed in counterparts and each signed counterpart shall constitute an original document. IV. PROCEDURE 15. Pursuant to RP 274, the Commission has discretion to determine the manner with which it considers a proposed settlement, ln this matter, the Parties have reached agreement on a final resolution to this case. This Settlement Stipulation is reasonable and in the public interest. The Parties request that the Commission approve the Settlemerrt Stipulation without further proceedings. 16, ln the alternative, should the Commission determine that further proceedings are required to consider the Settlement Stipulation, pursuant to RP 201, the Parlies believe the public interest does not require a hearing to consider the issues presented by this Motion and request it be processed as expeditiously as possible by Modified Procedure, without waiving the right to a hearing on the previously disputed matters in this proceeding should the Commission reject the settlement. rPC-E-14-18 Joint Settlement and lvlotion 7 V. REQUESTED RELIEF NOW, THEREFORE, the Parties respectfully request that the Commission enter its Order approving the Settlement Stipulation without material change or condition, and without fu rther proceed ings. DATED this _ day of -- 2015 ldaho Power Company Commission Staff By By Donovan E. Walker Attorney for ldaho Power Company Sierra Club By Dean J. Miller Attorney for Sierra Club Snake River Alliance By Kelsey Jae Nunez Attorney for Snake River Alliance IPC*E-14-18 Joint Settlement and lVotion Kristine A. Sasser Attorney for IPUC Staff ldaho Conservation League Benjamin J. Otto Attorney for ldaho Conservation League By B CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the _ day of 2015 I served a true and correct copy of the Settlement Stipulation and Motion upon the following named parties by the method indicated below, and addressed to the following: Commission Staff Kristine A. Sasser Deputy Attorney General ldaho Public Utilities Commission 472 West Washington (83702) P,O. Box 83720 Boise, ldaho 83724-007 4 ldaho Power Donovan E. Walker Regulatory Dockets ldaho Power Company 1221 West ldaho Street Boise, lD 83707 ldaho Conservation League Benjamin J. Otto ldaho Conservation League 710 N, 6th St Boise, lD 83701 Sierra Club Dean J Miller McDevitt & Miller LLP 420 W. Bannock St. Boise, lD 83702 lVatt Vespa Sierra Club 85 Second St., 2nd Floor San Francisco, CA 94105 Snake River Alliance Kelsey J. Nunez Ken Miller Snake River Alliance PO Box 1731 Boise, lD 83701 IPC-E-14-18 Joint Settlement and l/otion _Hand Delivered _U.S. lVlail _Overnight Mail _FAXX Email kris.sasser@puc,idaho.gov _Hand Delivered_U.S. [/ail _Overnight Mail _FAXX Email dwalker@idahopower.com dockets@ida hopower.com _Hand Delivered _U.S. fvlail _Overnight tilail _FAXX Email botto@idahoconservation.org _Hand Delivered _u,s, t\4ail _Overnight Mail _FAX X .. Email joe@mcdevitt-miller.com matt, vespa@sierraclub.org _Hand Delivered _U,S, Mail _Overnight lVIail _FAXX Email knunez@snakeriveralliance.org km iller@snakerivera lliance. org I