20171103Partial Joinder in Motion to Dismiss.pdf

Ryan B. Frazier (Idaho Bar No. 6201)
[e-mail]
Brian W. Burnett Qtro hac vice applicationfurthcoming)
[e-mail]
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: [phone]
Ittorneys for Intermounlain Wind and Solar, LLC
RECEIVED
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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
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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
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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
[e-mail]
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472W
Boise,
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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
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Kelsey Jae Nunez LLC
Sierra Club
920 N. Clover Dr.
Boise, ID 83703
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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
[e-mail]
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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
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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: [phone]
Facsimile: [phone]
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
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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
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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
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_FAXX Email kris.sasser@puc,idaho.gov
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_FAXX Email [e-mail]
dockets@ida hopower.com
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