20200117Answer for Reconsideration.pdf

Attomey for the ldaho Conservation League
Bf,FORE THE IDAHO PUBLIC UTILITIES COMMISSION
iIECEIVED
:ir?0 JAH l7 Pt{ 3: 33
;ln
.rssl0N
IN THE MATTER OF THE, )
APPLICATION OF IDAHO POWER )
COMPANYTOSTUDYTHECOSTS, )
BENEFITS,ANDCOMPENSATION )OFNETEXCESSENERGY )SUPPLIEDBYCUSTOMERON. )
SITE GENERATION )
IPC-E-18-15
ICL-VS Cross Petition for Reconsideration
CASE NO. IPC-E-18.15
IDAHO CONSERVATION LEAGUE
AND VOTE SOLAR
ANSWER/CROSS PETITION FOR
RECONSIDERATION
The Idaho Conservation League (lCL) and Vote Solar recommend the Commission deny
Idaho Power's request to adopt the settlement. The Commission should also deny Idaho Power's
altemative request to impose a significant program change - net hourly billing - and constrain
future study of the benefits of distributed energy. The Commission should further decline to
order parties in another docket, IPC-E-l 8- 16, to resume negotiations over an export credit rate
without a study of costs and benefits for the same reasons the Commission rejected the
settlement in this case. Finally, ICL and Vote Solar recommend the Commission apply legacy
rate treatment to the system as we proposed, Mr. Kluckhom requested, and Idaho Power agreed.
IDAPA Rule 31.01.01.332 allows the Commission to process requests for reconsideration
that "present only issues of law and not of fact or issues of fact not requiring hearings" through
written briefs. As described below, Idaho Power's Petition does notjustify changing the
Commission's prior order, much less justifu it based only on law or issues of uncontested facts.
Based on the record in this docket, the Company does not carry its burden ofproofto establish
January 17,2020
Benjamin J. Ono (lSB No. 8292)
710 N 6th Street
Boise, ID 83701
Ph: [phone] x 12
Fax: [phone]
[e-mail]
I
the settlement, or any single portion thereoi is in the public interest, a legal question firmly in
the Commission's authority to reject outright.
I. The Commission Should Deny Idaho Power's Request to Approve the Settlement
The Commission should deny Idaho Power's Petition to Reconsider. The filing rests on
IPC's incorrect assertion that Order No. 34509 "overlooks evidence in the record ofthe
collaborative, comprehensive Export Credit Rate study performed by parties at the
Commission's request, as well as substantial public notice ofthe study and settlement process."r
Contrary to the assertions made in the Petition, the Commission appropriately exercised its
authority to reject the settlement as not in the public interest, based on the overwhelming public
opposition, as well as the fact that the settlement lacked meaningful support in the record.
Moreover, there was no "comprehensive Export Credit Rate Study" performed in this docket and
Idaho Power's attempt to characterize confidential settlement negotiations- by a limited number
ofparties-- as a study, or public "workshop" process, is belied by the record in the case and
Idaho Power's own Petition.
1. The Commission Appropriately Rejected the Settlement.
ICL and Vote Solar agree with the Commission's conclusion that it "directed the parties
to 'meet in an effort to agree on the scope ofproper procedural and substantive elements of the
on-site generation docket, for approval by this Commission.' [and] that submitting a Settlement
Agreement, w'ithout first submiUing a comprehensive study, contradicts the intent of [the
Commission's] directive."2
' Idaho Power Petilion to Reconsider at page 10.
z Order 34509 aL6.
IPC-E-18-15
ICL-VS Cross Petition for Reconsideration
2 January 17 ,2020
At bottom, it is indisputable that there was no comprehensive study. That, alone, dictates
that the Commission appropriately reject the Settlement Agreement which was submitted in lieu
of, not as the result of, any such study. Idaho Power clearly does not like the fact that the
Commission is unwilling to reverse its prior requirement of a comprehensive study olcosts and
benefits and accept a Settlement Agreement without such a study. However, because the
Commission correctly requires such a study, rejecting the Settlement Agreement is the
unavoidable result. That does not constitute enor or oversight by the Commission justifying
reconsideration.l
The Commission should not abandon it based on ldaho Power's hyperbolic assertion that
a public process overseen by the Commission "will result in largely discarding thousands of
hours ofcareful analysis and deliberation."a First, nothing forecloses stakeholders from building
upon the work done before in a process that is more inclusive and respectful of public concems.
Second, even if it did, conducting an analysis, as required by the Commission, through an open
and public process should not be sacrificed lbr expediency.
Moreover, whatever evidence Idaho Povl'er alleges the Commission's decision
"overlooks," it is indisputable that the Commission heard testimony from over 1,000 members of
the public, which formed the primary basis for the Commission's decision. Based on the entire
record in this case, including the significant public comments. there is nothing unreasonable,
unlawful, erroneous or not in conformity with the law about the Commission's decision. The
Commission is not only authorized, but entirely justified, in weighing the evidence from the
3 tDAPA 3l.ol.ol.275
4 IPC Pelition at 4.
IPC-E- 18- t 5
ICL-VS Cross Petition for Reconsideration
3 January' '17, 2020
public over any other evidence Idaho Power focuses on when determining the public interest.s
Thus, there is no basis 1o grant ldaho Power's Petition.6
Furthermore, it is telling that Idaho Power's Petition relies primarily on hundreds of
pages ofprinted, nearly unintelligible, spreadsheets. Idaho Power's one-sided calculations,
standing alone and outside a comprehensive analysis with full public participation, does nothing
to address the Commission's reasons for rejecting the settlement agreement. Contrary to Idaho
Power's argument that "Order No 34509 overlooks the evidence in the record" about the
Commission's ordered study and public notice, Idaho Power's attempt in rehearing to back-fill
the record with "the benefit ofhindsight," concedes that the record before the Commission was
inadequate.T The standard for whether the Settlement Agreement is in the public interest is not
measured by total number ofpages filed by the utility. In any event, Idaho Power filing hundreds
ofpages ofnumbers simply does not "better facilitate a comprehensive review by the
Commission and interested parties on reconsideration."s The Commission should reject Idaho
Power's Petition because it does not provide any new evidence that undercuts the Commission
proper rejection of the Settlement.e
In fact, Idaho Power's additional attachments to its rehearing request were already in the
record as Attachment 4 to the Motion to Approve Settlement ("Initial Study"), and as
5IDAPA 31.01.o1.276.
6 IDAPA 31.01.01.331.
7 IPC Petition at 10, 12 (acknowledging "that a narrative presentation and a careful roadmap
describing all the elements of the study" would have benefitted the Commission and public).
8 IPC Petition at 18.
e See In the Matter of the investigution Into Whether Ponderoso Tentce Estates lV'ater System,
lnc. is a Public lltility Subject to Regulation by the lduho Public Utilities Commission, Case No.
GNR-W-oI-01, Order No. 29123 (September 24,2002) (denying petition fbr reconsideration in
part due to the petitioner's failure to include new evidence with the petition); IPC Petition a122,
fn 57.
IPC-E- 18- l5
ICL-VS Cross Petition fbr Reconsideration
lanuary l7 ,2O204
Attachment 1 to Idaho Power's Comments in Support of the Settlement ("Export Credit Rate
Study'1.t0 The Commission already considered those documents as part of the record and
concluded, accurately, that "these files appear to be the starting point ofnegotiations between the
parties and not the comprehensive study ordered by the Commission."ll After reviewing the
entire record developed by the parties that carry the burden ofproof, the Commission concluded,
"The record does not provide the Commission with substantial and competent evidence upon
which it can base its decision."l2 Thus, neither the existence of that information in the prior
record, nor the mischaracterizations ofthem in Idaho Power's rehearing request, undermines the
Commission's basis for its initial decision to reject the settlement as failing to protect the public
interest. l3
The Commission "listened to thirteen hours of public testimony over tw'o days" and
found three common themes that support rejecting the proposed settlement,ra The overwhelming
public testimony upon which the Commission based its decision demonstrated that the public
"expected this docket to result in a study".r5 That expectation is reasonable, since the
Commission's express directive in Order 34046 was "to meet in an effort to agree on the scope
ofproper procedural and substantive elements ofthe on-site generation docket, for approval by
this Commission."r6 Contrary to Idaho Poraer's claim, the record does not show that the signing
parties "did in fact produce a comprehensive study" to support the Settlement./z The "record"
to See IPC Petition ai20 -21.
tt Ortler 34506 at}-
t2 Order 34509 at 8-
t3 IDAPA 31.01.01.275.
t4 Order 34509 at 4. (The fourth common theme addressed the legacy rate treatment ofexisting
solar customers.)
t5 Id.
t6 Order 34509 at 6.
t1 IPC Petition at 12.
IPC-E-18-15
ICL-VS Cross Petition for Reconsideration
5 .Tanuary 17. 2020
Idaho Power points to was the same evidence the Commission considered and determined to be
only "the starting point ofnegotiations between the parties and not the comprehensive study
ordered by the Commission" and, because ofthe manner it is presented and lack ofcontext, to be
insullicient to allow the Commission or public to evaluate it.r8
The settlement process was unquestionably not "transparenf' as the Commission
required.re The settlement talks were not only limited to a handful of interest groups in a closed
process in which all participants were bound by confidentiality.20 That is, appropriately, the
nature ol settlement negotiations. But it is not a public and open process and cannot substitute for
the procedures this Commission has clearly required. For example, Idaho Power participated in
an open, transparent process to reformulate the Demand Response programs that lead to a
settlement that has stood the test of time.2/ The future process for customer generation in this
docket can fbllow a similar process going forward.
To the extent Idaho Power's Petition actually reflects its misunderstanding of the
Commission's prior directive, the Commission should combine its denial of the Petition for
Rehearing with instruction that Commission Staff will lead the public process and reiterate Order
34509's requirement that the Commission approve each step in the process moving forward. The
Commission has authority to "notif) the parties ofprocedures to be followed to decide the issues
for which settlement was rejected by the Commission."22 ICL and Vote Solar support the
Commission's clear articulation ofthe "criteria for a credible and fair study" on page 9 -10 of
Order 34509.
tB order 3 4 5 09 at 8-9 .
te order 34509 at 6.
20 IDAPA 31.01.01.272.
2t Order 32732, 32776, IPC-E-12-29
22 IDAPA 31.01.01.276.
IPC-E-18-15
ICL-VS Cross Petition for Reconsideration
6 lanuary 17 ,2020
2. ldaho Power Did Not Perform and Did Not File a Comprehensive Study as Requircd by
the Commission.
Idaho Power's Petition attempts to avoid the simple truth that nothing in the record
constitutes the comprehensive study ordered by the Commission."23 The evidence the Petition
cites was already considered and conectly determined to be an "lnitial Study" performed by
Idaho Power, not a neutral analysis overseen by the Commission and based on full public
participation. Indeed, as Idaho Power explains, the other parties adopted a wholly different
methodology which calculated a very different export credit rate.2a
Idaho Pow.er's purported "Export Rate Credit Study" included as Attachment I to IPC's
Comments in support of the Settlement also not the study the Commission required. It is neither
a study nor the result ofa public process. While the Settlement negotiations began u'ith an
eamest process to outline components for a comprehensive study, as evidence by the lirst Staff
Status Report, that study never happened. While the machinations resulting in the Settlement
Agreement are confidential, the public record reflects the disagreement betq'een parties to the
assumptions about costs and benefits underlying the Agreement. As we noted in our Reply Brief,
"lCL and Vote Solar do not agree that the Export Credit Rate and underlying methodology as
described in the proposed Settlement Agreement provide a fair valuation of the avoided costs
associated with distributed energy exports. At most this value represents a number that a portion
ofparties could agree to in order to reach settlement and it should not be interpreted by the
Commission as establishing anything other than a compromise amenable to signing parties."25 A
Settlement Agreement that produces a number that a portion of parties were willing to accept is
23 Order 34509 at8.
24 IPC Petition at l4 - 15.
25 ICL-Vote Solar Reply Brief on Existing Customers al 5.
IPC-E-l8- ls 'l
ICL-VS Cross Petition for Reconsideration
Januarl,' 17, 2020
not the same as a comprehensive study through a public process. Thus, the Commission was
correct to review the record in this case and conclude the purported study was inadequate to
ensure the Settlement was in the public interest.
The only new thing Idaho Power provides in their Petition is to print out a paper copy of
the "several large Exce[ files containing formula calculations" that constitute the negotiated
export credit rate.26 The Commission can safely reject ldaho Power's request because it ignores
the Commission's finding: "Though this information is in the decision-making record, the
manner in w'hich it is presented and the lack of context prohibit the Commission, or the public,
from evaluating it in any meaningful manner."27
3. If the Commission Does Not Deny Idaho Power's Requests Outright, Then the
Commission Rules Require A Full Evidentiary Proceeding.
Idaho Power asserts that the record is sulficient for the Commission to approve their
request for reconsideration on written briefs alone. but states that the process could altematively
be conducted with an evidentiary hearing or through public comment.28 To the extent the
Commission does not deny Idaho Po*,er's request for reconsideration as recommended by ICL
and Vote Solar, IDAPA 31.01.01.332 requires an evidentiary hearing to resolve the factual
dispute about the record and effective public notice upon which Idaho Power's Petition relies.
However, the time and eftbrt that would involve would be better spent, and the public interest
better served, by starting the process to develop the comprehensive and public analysis of the
costs and benefits of customer generation than by reploughing old ground on the merits ofthe
Settlement Agreement.
26 IPC Petition at 17. ln 41.
7' Order 34509 at8-9.
'18 IPC Pelition at 21.
rPC-E- l8- 15
ICL-VS Cross Petition for Reconsideration
8 .lanuan' I 7. 2020
II. The Commission Should Deny Idaho Power's Attempts to Impose Net-Metering
Program Design Changes and Constrain the Development ofa Credible and Fair Study.
As an alternative to reversing itselfand approving the Settlement Agreement,Idaho
Power asks the Commission to sever and impose a single term of the settlement --changing the
net metering program to a net hourly billing program- to constrain future public input in the
further study the Commission twice ordered.2e Not only is severing a compromise settlement
improper, but Idaho Power's basis for arguing for it relies on its old saw of making unsupported
assertions of"cost shifts." The Commission has repeatedly declined to accept those allegations
due to lack ofevidence.3o An unsupported, and incorect, assertion does not become true because
it is repeated. The Commission should, yet again, reject the unsupported and false assertion and,
once again, remind Idaho Power they must "provide the Commission with substantial and
competent evidence upon which it can base its decision."3r Order No 34509 states "[i]t is critical
for the Commission to have a credible and fair studv in front of it before it can make a well-
reasoned decision on the Company's net-metering program design."32 Idaho Power's Petition is
the opposite ofa credible and fair study and should be denied.
The Commission can reject as hyperbole ldaho Power's statements that the
Commission's process "will result in largely discarding thousands ofhours ofcareful analysis
and deliberation.'r3 Nothing lorecloses stakeholders from building upon the work done before
through a new process that is more inclusive and respectful ofpublic concerns. ICL and Vote
Solar lake seriously the Commission's directive "the Company, Commission Staff and all other
2e IPC Petition at 4,26 - 33.
10 See ICL-Vote Solar Reply Brief on Existing Customers aI2-6
3t Order 34509 ^t 8.
32 Order 34509 at,9.
33 IPC Petition at 4,26.
IPC-E-18-15
ICL-VS Cross Petition for Reconsideration
9 January 17 ,2020
stakeholders to the case would do well to listen to and understand the public sentiment regarding
the importance of distributed on-site generation to Idaho Power's customers."ra We look fort'ard
to using our expertise in public engagement to achieve this reasonable outcome.
Along with seeking to constrain future study, Idaho Power asks the Commission to direct
them to file a recommendation, in this docket, to implement net hourly billing.ss As the public
testimony in the case makes clear, the move from monthly to hourly billing would constitute a
major change to the existing net metering program and is contentious and confusing. To support
this request IPC claims that "it is well established that moving from net monthly billing to net
hourly billing is an important step toward reducing inequitable cost shifting."36 While IPC
includes several citations in an attempt to support this claim, all are based on a wishful reading of
the record. To begin with, it is factually incorrect that anything regarding net hourly billing is
"well established." While the Commission Staff raised a conceptual proposal similar to net
hourly billing in Docket No IPC-E- I 7- 13, the Commission never evaluated such a program and
did not order any such program.3T Idaho Power's other citations in support of this slatement are
either unrelated to net hourly billing altogethed8 or are from the current docket, which the
Commission found insufficient to establish any changes to the net metering program.
In addition to the assertion that net hourly billing is "well established" Idaho Power
continues to make reference to claims of"cost shifting" *'hen such a finding has never been
made by this Commission. This issue similarly arose in Idaho Power Company's Opening Brief
34 order 34509 at 10.
35 IPC Petition a127.
36 IPC Pelition at28.
31 Order 34016 at 17.
38 See IPC Petition at28, fn 7l (citation to Order 34046 at 16 where the Commission states "we
appreciate the parties' arguments about cost-shifting, but the analysis is incomplete.")
January 17,2020IPC-E-18-15 10
ICL-VS Cross Potition for Rcconsidcration
III. The Commission Should Deny Idaho Porver's Request to Issue an ()rder in a Separate
Docket.
Without citing any legal authority, and disregarding the Commission's reasoning here,
Idaho Power asks for an Order directing further settlement talks in a separate case. IPC-E-19-
3e ICL-Vote Solar Reply Brief on Existing Customers at pages 2 - 6.
40 IDAPA. 3 1.0 1.0 t. 3 32.
IPC-E- 18- t 5
ICL-VS Cross Petition for Reconsideration
1l January 17,2020
on Treatment of Existing Customers in this docket, which we responded to in detail in our Reply
Briefand will not reiterate here.3e It appears that Idaho Power's strategy on this issue is one of
simple repetition ofbaseless claims with the hope that through the mere process ofattrition, the
Commission will someday rule in their favor u'ithout their carrying the burden of producing any
credible factual analysis to support their claim.
Idaho Power's Petition to Reconsider muddies the water by misrepresenting prior
Commission orders, relying on evidence already found insufficient, and putting forward a
confusing, ill-conceived proposal. Instead ofdoubling down on a failed process and inadequate
record, ICL and Vote Solar recommend the Commission deny IPC's request.
Ifthe Commission does wish to address Idaho Power's request, which is based on lactual
assertions that have not been proven, the Commission must adopt a full evidentiary proceeding
including access to discovery, prepared testimony, and a technical hearing.ao Further, because of
the enormous public interest in this issue. the Commission should also implement a lull public
comment process. This route will inevitably take substantial time and resources away from
addressing the actual issue here, developing a credible and fair study to support the
Commission's consideration ofthe net metering program design. Instead ofcontinuing to litigate
over a failed record, we recommend the Commission deny Idaho Power's request.
15.4I The Commission should reject this over-reach based on due process concems. In fact, the
Commission may find that the closed-door process in IPC-E-19-15 suffers from the same flaws
the Commission correctly identified here. As Idaho Power explains, the 19-15 case attempts to
rely on essentially the same information and analysis to develop an Export Credit Rate.42 But the
Commission has already found the record here, which is more fully developed, inadequate to
assess the reasonableness ofthis approach to net metering program redesign. Ordering parties to
continue to negotiate around a failed process is an absurd request that will only cause further
bifurcation and delay. Further, it was Idaho Porver who chose to create the separate but
inevitably related dockets. ICL and Vote Solar argued in l9-15 to combine the issues and address
all customers in one proceeding.as The Commission decided differently and we respect that
decision.aa Idaho Power now makes a seeming collateral attack on that Order by asking the
Commission to take action in this docket that will impact that docket. The Commission should
reject this request.
IV. The Commission Should Adopt Legacy Net Metering Program Access by the Location.
ICL and Vote Solar recommend the Commission approve ldaho Power's request to apply
legacy rate treatment "by the system location rather than the customer."as We agree with the
Company that applying legacy treatment to a system is the predominate regulatory practice in
other states because it is logical. simple, and protects the economic value ofthe system.46
a\ IPC Petition at 5,31.
42 IPC Petition at 31.
al ICL-Vote Solar Procedural Comments at 2-3 in IPC-E-19-15.
aa Order 34335.
as IPC Answer/Cross Petilion lo Richard Kluckhorn's PetitionJbr Reconsideration at page 5
46 Id .tl 3-4.
IPC-D-18-15
ICL-VS Cross Petition fbr Reconsideration
t2 lanuary 17 .2020
Further, applying legacy treatment to the system avoids the complexity ofdefining a "customer"
raised in Idaho Power's Petition for Clarification.
Idaho Power proposes four criteria to further clarify this treatment.aT These criteria are
largely consistent with ICL and Vote Solar's own recommendations made in our Brief on
Existing Customers in this docket and are supported by ICL and Vote Solar. The first criteria
would link legacy program eligibility to the premises, not the customer, consistent with ICL and
Vote Solar's recommendation in our prior brief.aE The second criteria would forfeit legacy
program access in the event that the system is removed, moved, or offline for more than 6
months. To this criteria, ICL and Vote Solar have no objection. The third criteria allows for
immaterial increases to system size and is consistent with ICL and Vote Solar's recommendation
in our prior brief.ae Finally, under the fourth criteria, Idaho Power requests the Commission
establish end date ofDecember 20, 2045 for atl legacy rate treatment.so On this topic, ICL and
Vote Solar support either the Commission's original ruling providing for indefinite legacl'
program access, or an end date ofnot less than 20 years lrom the NEM Program Enrollment
Deadline.5l
ICL and Vote Solar agree these are appropriate and useful clarifications. We support the
Commission adopting these along with the request in our Petition for Reconsideration to allow
customers to enroll and remain in the existing net metering program until the Commission
approves a successor tariff.
41 Id ctt 5.
48 ICL antl Vote Solar BrieJ on Existing Customers at page 10.
4e Id.
so IPC Answer/Cross Petition to Kluckhorn at page 5.
st ICL and Vote Solar Brief on Existing Customers al page 10.
IPC-E-18-15 13
ICL-VS Cross Petition for Reconsideration
January 17 .2020
Conclusion
For the reasons stated above, ICL and Vote Solar recommend the Commission:
a Deny Idaho Power's Petition to Reconsider seeking to impose the settlement
terms despite overwhelming public opposition and an inadequate record.
Deny Idaho Power's request to impose a major change to the net metering
program design because ofthe lack ofa factual record and mischaracterization of
prior Commission orders.
Deny Idaho Power's attempt to constrain future study ofdistributed energy and
instead reaffirm the open transparent process outlines in Order 34509.
Apply legacy rate treat to the system instead ofthe customer because it is the
predominate regulatory approach to this issue, simple, and fair to distributed
energy system owners.
a
Respectfully submitted this l7'h day ofJanuary 2020.
Benjamin J. Otto
Idaho Conservation League
Local Council - Vote Solar
IPC-E-18- 15
ICL-VS Cross Petition for Reconsideration
lr+
a-
January 17, 2020
CERTIFICATE OF SERVICE
I hereby certifu that on this l Tth day of January 2020 I delivered true and correct copies of
the foregoing ANSWER/CROSS PETITION TO RECONSIDER to the following via the method
of service noted:E;*-
Electronic Mail Onll
Benjamin J. Otto
Roclty Mounlain Poher
Yvonne R. Hogle
Ted Weston
Yvonne.hogle@pacifi corp,com
Ted.weston@paci fi corp.com
Vote Solar
Briana Kobor, Vote Solar
[e-mail]
David Bender, Earthjustice
dbender@earthj ustice.org
Al Luna, Earthjustice
aluna@earthj ustice.org
City of Boise
Abigail R. Germaine
Deputy City Attomey
Boise Ciry's Attorney's Office
[e-mail]
IPUC
Ed Jewell
Deputy Attorney General
Idaho Public Utilities Commission
Edward j ewell @puc. idaho. gov
Iclaho Power
Lisa D. Nordstrom
Timothy E. Tatum
Connie Aschenbrenner
[e-mail]
[e-mail]
[e-mail]
[e-mail]
Idaho Irrigation Pumpers Association
Eric L. Olsen
Echo Hawk & Olsen PLLC
[e-mail]
Anthony Yankle
[e-mail]
IDAHYDRO
C. Tom Arkoosh
Arkoosh La*, Oftices
[e-mail]
[e-mail]
IPC-E- l8- l5
ICL and Vote Solar Certificate of Service
Hand Delivery Mail:
Diane Hanian
Commission Secretary (Original and seven copies provided)
ldaho Public Utilities Commission
1 133 I W. Chinden Blvd
Building 8, Suite 201-A.
Boise, ID 93714
Nick Thorpe, Earthjustice
nthorpe@earthj ustice.org
ldaho Sierra Club
Kelsey Jae Nunez
Kelsey Jae Nunez LLC
Kelsey@kelseyj arnunez.com
January 17 ,2020
Zack Waterman, Sierra Club
Mike Heckler, Sierra Club
Zack.w aterman@si enacl ub.org
[e-mail]
Idaho Cleon Energr Association
Preston N. Carter
Givens Pursley LLP
[e-mail]
Industrial Customers o.f ldaho Power
Peter J. Richardson
Richardson Adams, PLLC
[e-mail]
Dr. Don Reading
dread i n g (a)m i n d spri n g. c o m
Micron Technologt, lnc.
Austin RueschhofT
Thorvald A. Nelson
Holland & Hart, LLP
darueschhoff@hollardhart. com
[e-mail]
[e-mail]
gi gargano-amari @hollandhart.com
Jim Swier. Micron
[e-mail]
Individtnl
Russell Schiermeier
[e-mail]
Individual
Richard E. Kluckhorn
2564W. Parkstone Drive
Meridian, Idaho 83646
IPC-E-18-15
ICL and Vote Solar Certificate of Service
January 17 ,2020