20211215Motion to Dismiss.pdf

Peter J. Richardson
ISB No. 3195
Richardson Adams, PLLC
515 N. 27th Street
P.O. Box 7218
Boise, Idaho 83702
Telephone: [phone]
Fax: [phone]
peter@richardsonadams. com
Attorneys for the Industrial Customers of ldaho Power
1 - ,' 1lr ft
.,--. ii:r i5 i::ili:h0
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC.E-21-41
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR
AUTHORITY TO PROCEED WITH
RESOURCE PROCUREMENTS TO MEET
IDENTIFIED CAPACITY DEFICIENCIES tN
2023,2024, AND 2025TO ENSURE
ADEQUATE, RELIABLE, AND FAIR-PRICED
SERVICE TO tTS CUSTOMERS
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MOTION TO DISMISS OF THE
TNDUSTRIAL CUSTOMERS OF
IDAHO POWER
COMES NOW, The Industrial Customers of Idaho Power, ("ICIP") and pursuant to the
Rules of Procedure, Rule 7l IDAPA 31.01.01.56 of the Idaho Public Utilities Commission
("Commission") and hereby lodges its Motion to Dismiss ldaho Power Company's ("ldaho
Power" or the "Power Company") Application in the above captioned matter. As grounds, and
in support of its Motion, the ICIP states as follows:
I.
BACKGROUND
L Docket No. IPC-E-21-19:
On June 14,2OZl,the ICIP filed its Petition of the Industrial Customers of ldaho Power
Company for an Order to Show Cause Regarding Idaho Power's Compliance with Commission
Order No.32745. The Commission assigned the ICIP's Petition as in Docket No. IPC-E-21-19.
In the IPC-E-21 - l9 Docket, the ICIP alleged that Idaho Power is violating this Commission's
requirement that all resource acquisitions over 80 MW over a five year period comply with the
detailed competitive bidding requirements established by the Oregon Public Utility Commission
which requirements the Idaho Commission has adopted in Order No. 32745. In the ordering
paragraph in Order No. 32745 the Commission declared that, "ldaho Power is directed to comply
with RFP guidelines applicable tn its Oregon service area, should the Company commence an
RFP process for a new supply-side resource prior to the development of ldaho-specific RFP
guidelines. " Because the Oregon Commission's RFP guidelines (competitive bidding
requirements) have been adopted by the Idaho Commission, for ease of reference the applicable
guidelines will be referred to herein as the Idaho Competitive Bidding Requirements.
Specifically, in its Petition in Docket No. IPC-E-21-l9,the ICIP asserted:
The ICIP therefore submits this Petition for an Order to Show Cause requiring
Idaho Power to show cause why it should not be ordered to fully and promptly comply
with the Oregon PUC's RFP rules.
WHEREFORE, the ICIP respectfully requests: That the Commission enter an Order to
Show Cause directing Idaho Power to show cause why the Commission should not enter
an order requiring it to comply with ldaho PUC OrderNo. 32475 and the Oregon RFP
guidelines (Rule 860-089-0010, et. seq.)
ICIP Petition for an Order to Show Cause at page 4.
On July 2 of this year Idaho Power responded by asserting that it was, in fact, in full
compliance with this Commission's ldaho Competitive Bidding Requirements because it was
only seeking to acquire a resource sized less than the 80 MW threshold that triggers the Idaho
Competitive Bidding Requirements. Idaho Power also reassured this Commission that "it is
Idaho Powers full intent to comply with the fidaho Competitive Bidding Requirements.]
According to Idaho Power's Answer lodged on July 2 of this year:
2ICIP Motion to Dismiss-- IPC-E-2141
Idaho Power is aware of the direction from the tdaho Public Utilities Commission
("Commission") in Order No. 32745 from Case No. IPC-E-10-03: "Idaho Power is
directed to comply with RFP guidelines applicable in its Oregon service area, should the
Company commence an RFP process for a new supply-side resource prior to the
development of Idaho-specific RFP guidelines."
with the requirements of OAR 860-089-0010 et seq, the Resource Procurement Rules
required by the Oregon Commission, and prior the issuance of an RFP for a resource
acquisition larger than 80 MW and longer than 5 years will commence the proper
proceedings and/or procedures to either comply with the Oregon procurement rules or
seek a waiver of their applicability regarding a particular acquisition.
Idaho Power Answer at pages 2 - 3, emphasis provided.
On July 7,2021, the ICIP replied to Idaho Power's answer pointing out that the Power
Company's RFP does, in fact, trigger the Commission's Idaho Competitive Bidding
Requirements.
Although the matter appears to be fully submitted for an Idaho Commission ruling, there
has been no activity in the IPC-E-21-19 docket since the ICIP lodged its Answer on July 7 2021.
2. Docket No. IPC-E-21-41
Only five months ago (on July 2"d) tdaho Power filed its Answer in IPC-E-21-19, in
which the Power Company reassured the Commission of its "full intent to comply" with this
Commission's Idaho Competitive Bidding Requirements. Rather than follow through on that
commitment, the Power Company initiated a new docket (IPC-E-21-41) in which it now asks the
Commission to completely "eliminat[e]... the IPUC [competitive bidding] requirement[s]." '
Noteworthy for its absence from the Power Company's latest request, is any reference to Docket
No. IPC-E-21-19 in which it commits its "full intent" comply with those requirements.
THE ICIP'S MOTION TO DISMISS
l. Duplication of Proceedings:
I Application for Authority to Proceed with Resource Procurement, Docket No. IPC-E-2I-41 at
page34.
3ICI P Motion to Dismiss - IPC-E-2 I 4 I
This docket 0PC-E-21-41) is duplicative of Docket No. IPC-E-21-19 which was initiated
by the ICIP for the purpose of requiring ldaho Power to show cause why it should not be ordered
to comply with the ldaho Commission's competitive bidding requirements. Rather that litigate
the issue in the docket established for that purpose, Idaho Power has chosen to open a new
docket, the redundancy of which wastes the Commission and the parties' time and duplicates the
process already embarked upon by the ICIP and the Commission. Idaho Power's attempt to
duplicate dockets is contrary to black letter law on the subject which provides that "[parties]
have no right to maintain two actions on the same subject in the same court, against the same
defendant at the same time." Curtis v. Citi Bank, N.A.,226F.3d 133, 138 (2d Cir. 2000). Thus,
the Commission should dismiss tdaho Power's attempt to circumvent the existing docket that is
addressing the very issues raised by Idaho Power in this 0PC-E-21-41) docket.
As explained by the U.S. District Court:
A court facing duplicative actions may: (l) stay the second action; (2) dismiss the second
action without prejudice; (3) enjoin the parties from proceeding with the second action;
or (4) consolidate the two actions.Curtit v Citihnnk N A ))aF 1d l?1 llR (?nd Cir
2000). "Of course, simple dismissal of the second suit is [a] common disposition because
plaintiffs have no right to maintain two actions on the same subject in the same court,
against the same defendant at the same time." Crrtis. 226 F.3d at 138. As to
consolidation, the Third Circuit Court of Appeals has observed:
When a court learns that two possibly duplicative actions are pending on its
docket, consolidation may well be the most administratively efficient
procedure. If the second complaint proves to contain some new matters,
consolidation unlike dismissal of the second complaint without prejudice or
staying the second action will avoid two trials on closely related matters. It on the
other hand, the second complaint proves to contain nothing new, consolidation of
the two actions will cause no harm provided that the district court carefully
insures that the plaintiff does not use the tactic of filing two substantially identical
complaints to exoand the procedural rights he would have otherwise enjgyed.
Walton v. Eaton,563 F.2d 66,71(3rd Cir. 1977).
Team Enters. LLC v. Westem Inv. Real Estate Trust.2008 U.S. Dist. LEXIS I14882. *1.2008
WL 4826132 (ED Cal. 2008), emphasis provided.
4ICIP Motion to Dismiss - IPC-E-21-41
Of course, here the Power Company is attempting to greatly expand its procedural rights by
ignoring the existing, fully submitted docket which is ripe-for-Commission'decision in Docket
No. IPC-E-21-19. Not only is it attempting to expand its procedural rights, but it is actually
taking a position in this docket that is diametrically opposed to its position in Docket No. IPC-E-
19-21 - a tactic that violates the well-established judicial doctrine of unclean hands.
2. Unclean Hands:
The ICIP's motion to dismiss is not based on just the doctrine of preventing wasteful and
duplicative proceedings. This Commission has relied on ldaho Power's endorsement of those
requirements. Idaho Power has had ample opportunity over many years to challenge or seek
amendments or'fixes' to those requirements. And as recently as this July, the Power Company
assured the Commission and the ICIP of its intent to fully comply with those requirements. The
effect of the Power Company's actions was to lead the ICIP and this Commission to rely on its
promises with the legitimate expectation of compliance.
In its answer to the ICIP Petition in Docket No. IPC-E-21-19, the Power Company
promised the Commission that it intends to fully comply with the Commission's Idaho
Competitive Bidding Requirements that were established by Commission Order No. 32745 -- see
the above quote from Idaho Power's Answer. That promise was made after the Power Company
was fully aware of its pending resource deficit in the year 2023 and well after it had issued its
RFP for up to 80 MW of new resources beginning in2}23.
Apparently, Idaho Power is having a case of buyer's remorsie. Just five months after re-
avowing its intent to fully comply with the Commission's Idaho Competitive Bidding
Requirements, Idaho Power is seeking to completely rescind those ratepayer protections. Idaho
Power was fully cognizant of its alleged impending resource deficits at the very time in July,
5ICIP Motion to Dismiss - IPC-E-2141
AFTER its RFP was issued, and when it vowed to fully comply with the Commission's
competitive bidding requirements. Rather than own up to the fact that it has promised time and
time again (discussed below) to comply with the Commission's competitive bidding
requirements, the Company simply chose to open a new docket, apparently hoping to eliminate
the very concept it has repeatedly and very recently endorsed.
Idaho Power has been consistcnt in its reassurances of its intent to fully comply with the
Commission's Idaho Competitive Bidding Requirements. As noted above, as recently as this
July in its answer in Docket No. IPC-E-21-19 the Power Company promised to fully comply
with the Commission's Idaho Competitive Bidding Requirements. But also, at the time the
Commission first adopted those requirements, it did so, in large part, based on ldaho Power's
assurances that it would have no difficulty complying the Commission's Idaho Competitive
Bidding Requirements. In its order adopting the Idaho Competitive Bidding Requirements the
Commission relied on its Staff s finding to the effect that:
Staffrecently contacted Idaho Power to inquire as to the appropriate direction for the
[competitive bidding] case and determined to file this Motion to Close Case based on two
assurances provided by Idaho Power,.. [first] The Company's Integrated Resource Plan
that is regularly filed with the Commission will update the Commission on the
Company's need for additional supply-side resources well in advance of commencement
of the RFP process. Second, Idaho Power confirms that it is bound by competitive
bidding guideline in the State of Oregon for its RFP process, and that the Company will
comply with those competitive bidding guidelines in Idaho. Finally, should Idaho Power
seek to obtain a supply-side resource in the future, the Commission and interested parties
will be notified well enough in advance of the procurement process to initiate another
proceeding, if appropriate, to establish competitive bidding guidelines for the project's
RFP process.2
2 The IPUC Staff Motion is attached as Exhibit l. See pages I - 2.
6ICIP Motion to Dismiss- IPC-E-21-41
ldaho Power's Application in this docket breaches each and every one of the "assurances" it
provided to the Staffand which were relied upon by the Commission in approving the [daho
Competitive Bidding Requirements.
Not only has ldaho Power repeatedly reassured this Commission, as recently as this last
July, that it will fully comply with its Idaho Competitive Billing Requirements, but Idaho Power
has also lauded the Oregon Commission as recently as 2017, for its "carefully crafted"
competitive bidding guidelines that "provide for a reasonable and fair process."3 Of course, it is
those "carefully crafted" and "reasonable and fair" guidelines that this Commission requires
Idaho Power to comply with when acquiring new supply-side resources.
Idaho Power asserts at page l5 of its Application that it "objected to the adoption of the
[Oregon] Competitive bidding guidelines, the precursor to the OPUC Resource Procurement
Rules." However just a few years ago, Idaho Power, in addition to praising the Oregon
competitive bidding guidelines, actually advocated for the Oregon Commission to convert those
guidelines to rules. According to Idaho Power:
The Commission's IOPUC] policies goveming competitive bidding have been carefully
crafted, revisited and updated by the Commission over the past thirteen years with the
active involvement of all stakeholder groups. The resulting guidelines provide for a
reasonable and fair process that does not pre-judge the outcome of the competitive
bidding process and allows for diversity in ownership.... Accordingly, Idaho Power
believes it would be appropriate for the Commission [OPUC] to confirm that the current
policies allow for diverse ownership, and to proceed to convert the guidelines to rules. ..4
Reflecting ldaho Power's desire that it adopt its competitive bidding guidelines as rules, the
Oregon Commission did, in fact, make that change. Somewhere along the line ldaho Powor's
3 See Idaho Power's Comments on StaffReporr Oregon Docket No. AR 600/UM l776,May L5,
2017. Attached as Exhibit No. 2
4 Id.
7ICIP Motion to Dismiss - IPC-E-2141
proffered 'objection' to *the adoption of the competitive bidding guidelines" was obviously
internally reversed by the Power Company.
Idaho Power itself describes the Commission's Idaho Competitive Bidding Requirements
as both "reasonable" and *fair". It has also reassured the Commission that it would have no
problem complying with those rules, and that it would be able to apprise the Commission of the
need for new resources "well in advance" of the commencement of the RFP process. In addition,
Idaho Power asserted that the Oregon Commission's Rules were "reasonable" and "carefully
crafted." Despite all of that, now that the time has arrived in which the Commission's
competitive procurement rules have been triggered for the first time ever - Idaho Power seeks
their elimination. Based on the foregoing, the Power Company's Application should be denied
and the ICIP's request for an order to show cause in Docket No. IPC-E-21-19 should be granted
forthwith - the case has been fully submitted since early July.
3. Idaho Power's Substantive Arguments Also Fail
The primary argument Idaho Power makes to support its claim that the Commission's
competitive procwement rules should be abandoned is that there is simply not enough time to
comply. Yet almost six months have already lapsed since the Power Company issued its first
RFP in June. [n addition, many additional months were certainly consumed by ldaho Power in
preparing, drafting and internally vetting the RFP before it was issued in June of this year.
At that time the Company could have initiated the tdaho Competitive Bidding
Requirements procurement process in response to the supply-side deficits it had also allegedly
identified at that time. There was, and is still, adequate time to do so. The Company could have
initiated (and may yet still initiate) the process to obtain expedited approval of its RFP and
proceeded with the Commission approved process. Instead, the Company has been sitting on his
8ICIP Motion to Dismiss - IPC-E-21-41
hands and is facing a time cnrnch of its onm qeation. This Commission should not allow itself
to be boxed-into a decision eliminating, or staying the Idalro Competitive Bidding
Requirernents.
WHEREFORE, the hdustial Customers of Idatro Power respectfully request the
Commission dismiss Idaho Power's instant Application and allow the process begrrn in Docket
No. IPC-E-19.41 to poceod.
DATED this l5s dary of 2021
J
RICHARDSON ADAMS, PLLC
9ICIP Motion to Dismiss - IPC-E-2141
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the l5th day of Decembq 2021, a true and conpct copy of the
within and foregoing MOTION TO DISMISS OF THE INDUSTRHL CUSTOMERS OF
IDAHO POWER was scrved electronically to:
Donovan E. Walker
Lead Counsel
Idaho Power Company
dwalke@ idahopower.com
dockets@i dahopower.com
Benjamin J. Otto
Idaho Cons€wation ltaguo
botto@ idahoconservation. ore
Secretary,
Idaho Public Utilities Commission
secretarv@ouc. idaho. sov
Jan Noriyuki
Secretary,
Idaho Public Utilities Commission
ian.norivuki@[.uc. idaho. sov
Tim Tatun
Vice President Regulatory Affairs
Idaho Power Company
ttatum@ idahopower. com
IdaHydro
Tom Arkoosh and Amber Dresslar
tom. [e-mail]
amber. drpsslar@arkoosh. com
[e-mail]
ICIP Motion to Dismiss - IFC-E-21-41 l0
CASE NO. IPC-E-2I41
MOTION TO DISMISS OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER
EXHIBIT I
WELDON B. STUTZMAN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, TDAHO 8372O-OO7 4
TELEPHONE: [phone] lE
E-MAIL: [e-mail].v
IDAHO STATE BAR NO. ]283
IN THE MATTER OT THE DEVELOPMENTor REQUEST ['OR PROPOSAL (RFP)
GUIDELINES FOR THE PROCUREMENT
OF SUPPLY.SIDE RESOURCES BY IDAHO
POWER COMPANY
i iU.:
?Hl JAt{ tB pf.t Z: 0lr
lUl.lii; i-u
UTI!-lTlES CC i.1i,ii;jSI0,,
STREET MAILTNC ADDRESS;
472 WEST WASHINGTON STREET
BOISE, IDAHO 83702-5983
Attorney for the Commission Staff
BEFORE THE IDAIIO PUBLIC UTILITIES COMMISSION
)
)
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)
)
)
cAsE NO. rPC-E-10-03
COMMISSION STAFF'S
MOTION TO CLOSE CASE
The Commission Staff, by its attorney of record, files this Motion to Close Case.
This case to develop guidelines for ldaho Power's procurement of supply-side rcsources grew
out of a generic docket, Case No. GNR-E-08-03. Petitioners representing industrial and
irrigation companies initiated that generic case asking the Commission to open an investigation
to establish competitive bidding guidelines for the Request for Proposal (RFP) process used
when supply-side resources are acquired by ldaho Power, PacifiCorp, and Avista. The
Commission subsequently issued Order No, 30999 limiting the case to ldaho Power after Avista
and PacifiCorp notified the Commission that their process in ldaho would conform to RFP
requirements they are obligated to in other states. Order No. 30999, p. 5. Thereafter, Idaho
Power hled a draft set of RFP guidelines and Commission Staff hosted a public workshop in the
case on February 25,2010. No ftrther action was taken in the case.
Staff recently contacted ldaho Power to inquire as to the appropriate direction tbr the
case and determined to frle this ttvlotion to Close Case based on two assurances provided by
COMIVIISSION STAFF'S
MOTION I'O CL,OSE C]ASE
Idaho Power in a letter to Staff dated January 2,2013. The Company states in its letter that it
does not currently anticipate the need to issue an RFP for a supply-side resource in the near
future. The Company's Integrated Resource Plan that is regularly filed with the Commission
will update the Commission on the Company's need for additional supply-side resources well in
advance of commencement of the RFP process. Second, Idaho Power confirms that it is bound
by competitive bidding guidelines in the State of Oregon tbr its RFP process, and that the
Company will comply with those competitive bidding guidelines in ldaho. Finally, should Idaho
Power seek to obtain a supply-side resource in the future, the Commission and interested parties
will be notified well enough in advance of the procurement process to initiate another
proceeding, if appropriate, to establish competitive bidding guidelines tbr the project's RFP
process. A copy of the January 2,2013,letter is attachod to this Motion,
Based on the current status of ldaho Power's plans, or lack thereof, to obtain a
supply-side resource in the near future, the Company's assurance that it will comply with the
competitive guidelines in place for the Company in Oregon, Staff files this Motion requesting the
Commission close Case No, IPC-E-I0-03.
Respectfully submitted this lSth day of January 2013.
Weldon B. Stutzman
Deputy Attorney General
N:IPC E-10{l-ws Motion
COIVIIVIISSION S.f AFF' S
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January 2,2013
Mr. Weldon StuEman
Legal Division
ldaho Public Wlities Commission
P O Box 83720
Boise, lD 83720-0074
Re: IPC-E-10-03 - ln the Matter of the Development of Request for Proposal
(RFP) GuUelines br the Procurement of Supply€ide Resources by ldaho
Power Company
Dear Mr. StuEman:
At the request of the ldaho Public Utilities Commission Staff ("Staff), ldaho
Power Company ('ldaho Power' or "Company') submits this letter in order to facilitate
the closure of ldaho Public Utility Commission ("|PUC" or uCommission') Case No. IPG
E-10-03, an investigation into the desirability of establlshing competitive bidding
guidelines forthe procurement of supply-side resources.
ldaho Power does not cunently anticipate the need to issue a RFP for a supply-
side resource in the near frlture. ln ttre interim, through the ongoing planning process
for ldaho Powe/s lntegrated Resource Plan, the Company wlll continue to update the
Commission and Staff on the cunent status of the Company's need for additional
supply-side resources.
ldaho Power also conforms to the Competitive Bidding Guidelines in the state of
Oregon. The Company continues its inrrolvement in Phase ll of Oregon Public utility
Commission Case No. UM 1182, a competitive bidding investigation intended to provide
further refirement to the comparison of relevant risks associated r rith resour@
acquisitions. Depending on the outome of that case, the Company may rcvise its
cunent practices and procedures in order to be compliant with future requirernents of
the Oregon guidelines.
ln light of the fact that ldaho Power does not anticipate a need to issue a RFP br
a supply-side resource in the near future and the Company's planned compliance with
the Competitive Bidding Guidelines in Oregon, ldaho Power supports the Staffs posltion
that IPUC Case No. IPC-E-10-03 should be closed. Prircr to the Company issuing a
RFP for a supply-side resource, the Commission or the Staff may initiate another
proceeding to review the Company's practices and procedures, and may choose to
I 22 I W ldaho 5t. (83702)
P-O. Box 70
Boise. lD 81707
Mr. Strtanan
January 2,2013
Page 2 of 2
establish competitlrro blddirg guHellnee fur the prccuernont of zupplytHe rwures in
the $ate of ldaho, if d€orn€d neosssary.
SlnoerolydrW
LDN:evp
CASE NO. IPC-E-2141
MOTION TO DISMISS OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER
EXHIBIT 2
MRG
McDOti/ELL RACKNER CIBSON PC
May 15,2017
VIA ELECTRONIC MAIL
PUC Filing Center
Public Utility Commission of Oregon
PO Box 1088
Salem, OR 97308-1088
Re: AR 600/UM 1776 - Comments on Staff Report
Attention Filing Center:
ldaho Power Company (ldaho Power or Company) appreciates this opportunity to
provide cornments in response to the proposal made by Staff of the Public Utility Gommission of
Oregon (Commission) in its May 8, 2017 memorandum regarding the scope of UM 1776 and AR
600. ln that memorandum, Staff has proposed that the Commission decline to open the scope
of these dockets to all issues raised by the parties, and has recommended instead that the
Commission restrict the scope of these dockets to the investigation of certain specific categories
of issues.
The Commission's policies governing competitive bidding have been carefully crafted,
revrsited and updated by the Commission over the past thirteen years with the active
involvement of all stakeholder groups. The resulting guidelines provide for a reasonable and
fair process that does not pre-judge the outcome of the competitive bidding process and that
allows for diversity in ownership Therefore, ldaho Power believes that the current rules fulfill the
goals for competitive bidding articulated by the Legislature and by this Commission and that
changes are not required Moreover, the Commission last adopted substantive changes to the
rules in Order 14-149, and there have been no requests for proposals issued under these new
rules Therefore, arguments that the current rules are insufficient or produce skewed results are
not credible Accordingly, ldaho Power believes it would be appropriate for the Commisston to
confirm that the current policies allow for diverse ownership, and to proceed to convert the
current guidelines to rules, as required by SB 1547.
That said, ldaho Power acknowledges that the Cornmission may wish to take this
opportunity to review specific and discrete aspects of the Commission's cornpetitive bidding
policies to determine whether limited changes may be appropriate For this reason, ldaho
Power does not oppose Staff's recommendation. However, ldaho Power cautions the
Lrse RRcruen
Direct [phone]
lisa@mrg-law com
,rraLr' 5LJl 5'l; 3?12 ia;r 5rl I : l5 39:B 'a,,^i'rl ryr'? -larv,-om
413,jvli ttij. A,re Sr.rrte 4r_)() r Pr>rtlanr:1 rlr4qr;1r,)72r)5-26r)5
PUC Filing Center
May 15,2017
Page 2
Commiasion against revisiling recently-litigatsd issues or signiftcantly revising the current rules,
when the parties have not yet had the opportunrty to observe their application.
ldaho Povusr disagrees with the arguments made by the Northwest and lntermountain
Power Producers Goalition (NPPC) in their comments filed on May 10, 2017. PacifiCorp d/t/a
Pacilic Porrer filed a comprahensive rebuttal of NPPC's argumenb on May 12,2A17, ldaho
Power egrees
reiec{ NPPC's
trith the points made in PacifiCorp's comments, and urges he Commission to
and proposals.
o**yours,
Lisa Rackner