HomeMy WebLinkAbout20070821Comments.pdfNEIL PRICE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-0314
ISB NO. 6864
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Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE FILING BY
ACIFICORP DBA ROCKY MOUNTAIN
POWER OF ITS 2007 INTEGRATED
RESOURCE PLAN (IRP)
CASE NO. PAC-07-
COMMENTS OF THE
COMMISSION STAFF
The Staff of the Idaho Public Utilities Commission, by and through its Attorney of record
Neil Price, Deputy Attorney General, submits the following comments in response to Order No.
30362, the Notice of Filing, Notice of Modified Procedure and Notice of Comment Deadline
issued on July 2 2007.
BACKGROUND
On May 30, 2007, PacifiCorp filed its 2007 Integrated Resource Plan (IRP) with the
Commission pursuant to the biennial filing requirement mandated in Order No. 22299, as
modified in Order No. 30262. PacifiCorp (dba "Rocky Mountain Power ) serves approximately
6 million retail energy customers over a service area encompassing portions of six western
states: Utah, Oregon, Wyoming, Washington, Idaho and California. Rocky Mountain Power
serves approximately 68 000 customers in southeastern Idaho. PacifiCorp filed its last IRP with
the Commission on January 1 , 2005. In 2006, the Company was acquired by Mid American
STAFF COMMENTS AUGUST 21 , 2007
Energy Holdings Company ("MEHC"), a global energy resource production company and
resource supplier.
PacifiCorp states that its purpose in preparing the IRP is to: "(1) determine future long
term resource needs and develop an informed and comprehensive assessment of the cost and risk
implications of alternatives for meeting those needs, and (2) develop a framework of future actions
to ensure PacifiCorp continues to provide reliable, least-cost service with manageable and
reasonable risk to its customers.Transmittal Letter at 1-2. PacifiCorp cites the contemporary
development of regulatory policies targeted at reducing the "carbon footprint of utilities" and the
increased emphasis on the development of renewable energy as specific challenges it is facing. Id.
Prior to submitting its IRP, the Company studied 12 separate portfolios in order to identify
a portfolio that demonstrated superior performance in terms of estimated cost, customer rate
impact, cost versus risk balance across five different CO2 cost adder levels and supply reliability.
See PacifiCorp 2007 IRP at 6, 139. Ultimately, the Company settled upon a preferred portfolio
that includes the acquisition of the following energy resources:
000 MW of renewable resources by 2013
100 MW ofload control beginning in 2010
West-side combined cycle combustion turbine ("CCCT") in 2011 (602 MW)
High-capacity-factor baseload resources to PacifiCorp s eastern system in 2012
(340 MW) and 2014 (527 MW)
Eastern system CCCT's in 2012 (548 MW) and 2016 (357 MW)
Firm market purchases to meet system needs beginning in 2010
Transmission additions/upgrades between 2010-2014 to support resources
Id. at 7.
Prior to the 2011-2012 period, PacifiCorp plans to address its projected resource deficits
through the procurement of additional renewable resources, demand side programs and market
purchases. Id. at 3. The Company has made requests for proposal ("RFP") for additional base
load resources, renewable resources and demand side resource programs benefiting the eastern
portion of its service area. Id.
Faced with the likelihood of energy deficiencies, PacifiCorp has taken recent steps toward
increasing its resource production. In June 2006, PacifiCorp converted its Currant Creek facility
from a simple cycle combustion turbine to a combined cycle combustion turbine ("CCCT"
).
Id.
61. It will add its Lake Side CCCT facility this month. Id. These additions will be offset by the
STAFF COMMENTS AUGUST 21 , 2007
expiration of two resource procurement contracts, a 400 MW agreement with TransAlta Energy
Marketing and a 575 MW BP A peaking contract, in June 2007 and August 2011 , respectively. Id.
PacifiCorp estimates that customer loads will grow at an average rate of 2.4% annually
from 2007 to 2016. Id. at 4 (Figure 1.1) and Errata to 2007 IRP. PacifiCorp s eastern system
(Idaho, Utah and Wyoming) continues to display a significantly higher rate of energy growth than
its western system, with an annual average energy growth rate of 3.2% and 1.2% respectively.
The annual growth for the Idaho service area over that same 10- year period is estimated to be
1.3%. Id. at3 (Table 1.1).
The Company currently forecasts a summer peak resource deficit beginning in 2008 to
2010 depending on whether a 12% or 15% planning reserve margin is used. Id. In 2009, the
Company will become energy deficient on an annual basis, using a 12% planning reserve margin.
Id. Beginning in 2010, its system will operate at a 791 MW deficiency, again based upon a 12%
planning reserve margin. Id. The energy resource deficit will increase to 2 400 MW by the year
2012 and 3 000 MW by 2016. Id.
The following briefly summarizes the modeling and risk analysis conducted by the
Company, along with certain influences on the process:
1. IRP Modeling
PacifiCorp employed two distinct modeling tools during its portfolio analysis: 1) Capacity
Expansion Module (CEM); and 2) Planning and Risk (PaR) Module. !d. at 5. The two analytical
models assisted the Company in arriving at the "least-cost optimization (of) resource options" and
developing "risk-adjusted portfolio performance measures.!d. The Company s modeling
approach consisted of "resource screening, risk analysis portfolio development and detailed
production cost and stochastic risk analysis.Id.
In order to predict the most desirable resource options, PacifiCorp used the CEM to
develop and analyze sixteen separate "alternative future scenarios" involving a mixture of several
variables, including potential CO2 regulatory costs, natural gas prices, wholesale electricity prices
retail load growth and the scope of renewable portfolio standards. !d. at 6 139. The Company
views the preferred resource portfolio as one that manifests itself under a "reasonably wide range
of potential future" scenarios. Id. Once those resource option portfolios were effectively
identified, the PaR Module was then used to simulate the potential risk and cost of each through a
random sampling process of the following variables: loads, commodity natural gas prices
wholesale power prices, hydro energy availability and thermal unit availability. Id.
STAFF COMMENTS AUGUST 21 , 2007
2. CO2 Emissions
PacifiCorp s IRP also addressed the potential costs/effects of CO2 emission compliance.
Id. at 6. According to the Company, the costs associated with CO2 emission compliance are not
normally amenable to statistical analysis. Id. Thus, rather than attempting to ascertain a specific
cost, the Company elected to treat the potential emission costs as "a scenario risk" in its overall
IRP analysis. Id. The initial risk/analysis portfolios were analyzed under five different CO2 cost
adder levels - $O/ton, $8/ton, $15/ton, $38/ton, and $61/ton (adjusted for projected 2008 dollars)-
in order to determine which portfolio was most prevalent across a "reasonably wide range of
potential futures.Id.
3. Integrated Environmental Issues
Continue to study and address contemporary environmental issues. The Company asserts
that it has and will continue to assume a leadership role in discussions with stakeholders involving
global climate change issues; and continue to investigate the development of carbon reduction
technology, specifically clean coal, sequestration and nuclear power.
4. Diversification
Diversification of base load and intermediate load resources. The Company reiterated its
desire to add approximately 1 700 MW of base load resources, a mix of thermal resources and
market purchases, to its eastern system between 2012 and 2014. Further, it will seek to acquire an
additional 200 to 1 300 MW of thermal and market purchase resources to benefit its western
system between 2010 and 2014.
5. Transmission
Address existing problems affecting transmission of resources to customers. The
Company plans an expansion of its transmission system and an upgrade in its transmission
infrastructure and flexible resources, such as natural gas, in order to meet the anticipated customer
loads found in the preferred portfolio. Transmission is included as a resource option for modeling
purposes in the 2007 IRP, with upgrades included in the preferred portfolio.
STAFF ANALYSIS
Staff recognizes PacifiCorp prepared this integrated resource plan amid disparate
jurisdictional environments, specifically in regard to resource acquisition and greenhouse gas
regulation. Throughout the development period for the IRP, there were nearly 40 participants
providing input, including Commission representatives from all states within the Company
STAFF COMMENTS AUGUST 21 , 2007
jurisdiction except for California. While this is not the first IRP to address constrained resource
procurement, the 2007 IRP does represent the first of such plans in which state policies, such as
renewable portfolio standards (RPS), have been in place within its service territory. PacifiCorp
continues to maintain a portfolio acquisition strategy that highlights fuel source diversity, a
balance between cost and risk, and a commitment to renewable energy resources. Staff believes
there is still additional work that needs to be done toward reconciling varying state initiatives
within the planning process, in conjunction with potential federal carbon legislation. Staff also
recognizes additional work in this area by the IRP group and the Multi-State Process (MSP)
workgroup.
PacifiCorp continues to expand its analysis of potential portfolios, employing multiple
modeling tools, an abundance of in-house, public, and consultant data, and an array of stochastic
and deterministic scenarios to identify and to test the robustness of the preferred portfolio.
PacifiCorp utilizes an iterative approach to determine the preferred resource acquisition path.
initial round of 12 resource portfolios were assessed under various cost and risk scenarios that
highlighted uncertainty in various assumptions, such as fuel prices, load growth and emissions
costs. Certain portfolios then went through a secondary screening process based on sensitivity to
changes in what the Company terms "secondary variables and other resource selection factors.
Id. at 124. These scenarios consist of such conditions as adjusting the planning reserve margin
and construction costs. The first two phases were performed in the aforementioned CEM. After
developing a generation investment schedule and determining timing and amount of front office
transactions (new to the 2007 IRP), the Company then performs stochastic risk analysis using the
PaR model, applying Monte Carlo methods to test for risk exposure due to variation in loads
natural gas prices, hydro availability, and thermal unit availability. The Company then evaluated
the results based on a set of performance measures that included cost, risk, emissions and
reliability.
Staff is satisfied with the breadth of future risks that were incorporated into the Company
analysis with the caveat that evolving regulatory environments will require the Company to further
expand its analysis prior to the next IRP filing. It is Staff s opinion that resource acquisition will
become further constrained for PacifiCorp, and may expose certain jurisdictions, especially Idaho
to resource decisions based less on economics and more on politics. The avenues the Commission
has available to mitigate this concern are through the IRP planning process, the request for
proposals (RFP) process for resource procurement, and the MSP and allocations process. Staff is
STAFF COMMENTS AUGUST 21 , 2007
currently an active participant in developing the IRP, but not the RFP process. Staff believes that
it is imperative that the Commission becomes more involved in these areas to assure that the
ratepayers of Idaho are well represented.
The resultant preferred portfolio consists of a wide array of supply side resources, DSM
balancing transactions and transmission upgrades. The Company has developed a plan that
acknowledges diversity and builds upon prior commitments, such as the Company s pursuit of
1,400 megawatts of cost-effective wind resources. PacifiCorp s preferred resource portfolio is
summarized below.
PacifiCorp 2007 Preferred Portfolio
527
200
548
357
200 200 300
2.5
393 272 149 192 165
602
.. DSM is scaled up by 10% to account for avoided line losses.
*'* Front office tramadion amO1.Ult5 reflect purchase;; mane for the year, and are not additive.
400
176
600
500
400
630
* Transmission resource proxies represent a range ,of possible procurement strategies, including new ""heeling con-
tU\cts or construction oftrnnsmission facilities by PacifiCorp ,or as a joint project with other parties.
STAFF COMMENTS AUGUST 21, 2007
Planning Constraints
Staff has noted that the 2007 IRP planning process has proceeded amid a time of great
change for the Company. Foremost is the acquisition of the Company by MEHC. During that
process, the Company agreed to a variety of commitments both system-wide and within its six
jurisdictions. See Final Order No. 29998. Included among these are the commitments to acquire
400 MW of cost-effective renewable resources (Commitment 40), increase and upgrade
transmission capabilities (Commitments 34 and 35), and investigate clean-coal and emissions
reducing technologies (Commitments 41 through 43 and 122).
As of 2007, the Company is slightly behind on its renewables acquisition target of 400
, though 335 MW in new wind projects are expected to be online by the end of the year. For
the 2007 IRP, the 400 MW of the targeted 1,400 MW has been included as a committed resource
though the timing of procurement for the remaining block was subject to further evaluation. Staff
believes that acquisition of these resources conforms to the commitments made, but at a cost much
higher than anticipated. This is evident with the three large wind projects expected to be online
this year, each of which have capital costs far in excess of those used as assumptions in the IRP.
Given the amount of wind already acquired and the fact that the preferred portfolio contains an
additional 600 MW of wind resources, there is a potential that the portfolio selected would have
been different had modeled costs been more in line with actual costs obtained in the RFP.
PacifiCorp has been active in its investigation of clean coal technologies and emissions
compliance issues. The Company is party to a number of initiatives, including those of the
Wyoming Infrastructure Authority (WIA) and EPRI, to investigate the potential of integrated
gasification combined cycle (IGCC) coal plants. It is in preparation stages for conducting a
feasibility study to investigate IGCC technologies at its existing Jim Bridger facility. While IGCC
has been a technology of interest for number of years, Staff recognizes that it is still unproven, and
is not surprised that IGCC coal was not part of the selected portfolio.
State initiatives have accelerated the Company s investigation into clean coal. For
example, the state of Washington has recently passed a bill that limits CO2 emissions levels to
100 lbs. per MWh or less for electric generation, far below the average levels of conventional
pulverized coal facilities. See Washington SB-6001-2007-08. In addition to state legislation
Washington has recently passed an initiative on establishing a renewable portfolio standard (RPS),
joining California and Oregon as having an RPS mandate that affects the Company. For the
purpose of modeling the standards, the Company includes a percentage commitment for
STAFF COMMENTS AUGUST 21 , 2007
renewables in its analysis. PacifiCorp s east side region (Utah, Idaho, and Western Wyoming),
show no signs of adopting an RPS in the near future, nor enacting emissions-curbing legislation
similar to the Company s west region (California, Oregon and Washington have greenhouse gas
mitigation legislation that supplements the RPS). While there has been a commonly held belief
that a federal RPS is possible, to date no such legislation is under consideration.
Given these state initiatives and commitments made during the acquisition by MEHC, the
IRP planning process has become increasingly more difficult and is receiving much more scrutiny
than in the past. Oregon, Washington, and Utah Commissions have enacted recent enhancements
to planning guidelines in order for the IRP to be in compliance with Commission requirements in
their respective states. Staff believes that the Company has effectively addressed the requirements
of the Idaho Commission. Staff points specifically to the inclusion of transmission resources in
the 2007 IRP and treatment of demand side management programs as an improvement spurred by
Commission directives.
Renewable Resources
As stated earlier, the 2007 IRP indicates that the Company s preferred portfolio contains
additional renewable resources beyond those identified in the 2004 IRP. The Company states that
it will continue to acquire additional renewable resources on its way toward procuring a total of
400 MW of renewable resources by the year 2010 and 2 000 MW by the year 2013. The 2007
IRP expedites the acquisition of the 1,400 MW, which initially was targeted to be online by 2015.
A contributing factor to this new schedule is the projected capacity deficits beginning in 2012
using a 12% planning reserve margin, a 15% planning reserve margin accelerates this deficiency
to 2008). 1 100 MW of renewable resources has been acquired or is currently being pursued
through the RFP process (RFP 2003B, amended in March 2006). Currently, the Company has
acquired four large-scale wind projects, including a purchase power agreement with the Wolverine
Creek project in Idaho prior to the development of the 2007 IRP, along with a geothermal facility
in Utah.
PacifiCorp utilizes a proxy resource in its portfolio analysis to represent renewable
resources. Staff acknowledges that the 2 000 MW of renew abies may not solely entail wind
facilities, though it is assumed that the majority will be wind. Staff has historically been and
continues to be supportive of cost effective wind generation to serve Idaho customers. The
absence of fuel costs and carbon emissions are as important now as they ever have been with
STAFF COMMENTS AUGUST 21 , 2007
ongoing fuel price volatility and likely emissions mitigation requirements. However, Staffwants
to be assured that wind characteristics are properly modeled in the IRP and that wind resources
can realistically be obtained at prices assumed when portfolios are compared.
Thermal Resources
Thermal resources figure heavily into PacifiCorp s future resource mix as it becomes
increasingly capacity and energy constrained. The preferred portfolio contains both combined
cycle combustion turbine (CCCT) gas units and supercritical pulverized coal facilities. The
portfolio recognizes two east side CCCTs totaling 905 MW as viable resources, along with a 602
MW west side CCCT. The coal resources total 867 MW, and are proposed to be located in the
east side of the system (Utah and Wyoming). Due to greater efficiencies and lower emissions
supercritical pulverized coal was selected rather than subcritical pulverized coal.
As a consequence of the filed update to the 2004 IRP, the Company suspended its 2009
RFP, but recently issued a new RFP (RFP 2012) to acquire the east side baseload resources. RFP
2012 utilizes the Intermountain Power Plant Unit 3 (340 MW) as a benchmark resource for 2012
and Bridger 5 (575 MW) as a benchmark for a 2014 resource. The Oregon PUC denied approval
of the draft RFP, citing that the Company did not adequately justify the need for the amount of
thermal resources it is seeking. See OPUC Docket No. UM 1208. While the preferred portfolio in
the 2007 IRP still supports the decision, it is unclear how the Oregon ruling will affect the
acquisition and cost recovery of the projects. Should the Company modify the resource
acquisition strategy proposed in the 2007 IRP based on the various competing position of state
jurisdictions, Staff recommends that the Company address these modifications and potential
impacts on a state-by-state basis in its next IRP, if not sooner in an update to the 2007 IRP.
Staff finds that the inclusion of CCCTs in the preferred portfolio is a suitable means for the
Company to address both energy and capacity needs efficiently. As was the case in the 2004 IRP
no simple cycle combustion turbines (SCCTs), commonly used for peaking needs, were included
in the preferred portfolio. CCCTs provide greater operational flexibility, lower heat rates, and
enjoy economies of scale over SCCTs. The obvious drawback of gas- fired resources is the
reliance on volatile natural gas supplies as a fuel source. Staff is actively evaluating the
Company s gas procurement and risk management policies and will provide input into Company
strategies. For modeling purposes , PacifiCorp looked at a number of natural gas forecasts from
multiple sources, representing a wide range of possible future prices. Recent history has proven
STAFF COMMENTS AUGUST 21 , 2007
that predicting commodity prices for natural gas is exceedingly difficult. Staff acknowledges that
the Company took an earnest approach at capturing gas price volatility when analyzing potential
portfolios.
Demand Side Measures
Demand side measures ("DSM") are an important piece of the Company s preferred
portfolio. The Company anticipates further expansion of its existing 150 MW of irrigation and air
conditioning load control program in Utah and Idaho. In 2010, a 100 MW irrigation load control
program will be added and will be split between its eastern and western systems. The Company
will continue to run programs to acquire 250 aMW of cost-effective energy efficiency and an
additional 200 aMW if cost-effective initiatives can be identified. The Company identified that
DSM is an important resource to meet short-term energy needs.
PacifiCorp classifies its DSM programs as dispatchable (Class 1), energy efficiency (Class
2), or price response (Class 3). Only Classes 1 and 3 are modeled through the CEM. Class 2 was
evaluated outside of the CEM as a load decrement. The CEM is a new tool for the Company, and
could not sufficiently include Class 2 DSM in the model. The Company has indicated that the
next IRP will include Class 2 DSM in the model. Nevertheless, Staff finds that the methods
employed by the Company properly incorporates energy efficiency measures in the planning
process. The 2007 IRP includes continued pursuit of potentially 450 aMW of these measures.
It should be noted that the preferred portfolio acquires Class 1 DSM as of2010. Staff
encourages the Company to closely monitor demand side opportunities with the intent to expedite
expansion ofDSM prior to its 2010-2011 time frame should the possibility arise. Staff maintains
that DSM can be an effective, cost-efficient means at the Company s disposal to meet its load
obligations. As an example, the Company has had great success with the Irrigation Load Control
program in Idaho, and has enacted a pilot curtailable option this year. The Company will provide
a report later this year with the potential for program expansion. Staff also recommends that the
Company investigate critical peak pricing programs to augment its existing time-of-use schedule.
The deployment of advanced metering, a necessity for peak pricing programs, should be part of
that investigation.
STAFF COMMENTS AUGUST 21 , 2007
Action Plan
PacifiCorp s Action Plan is summarized in the attachment to Staffs comments. The
Action Plan details the steps that the Company intends to take in order to acquire the identified
resources and further improve the IRP process. Staff believes that the identified course of action
is appropriate given the analysis and conclusions reached in the 2007 IRP.
Acknowledgement
In Idaho, as in most states, the Commission "acknowledges" rather than "approves" a
utility s IRP. Other states where PacifiCorp serves have similar IRP requirements and provisions
for acknowledgement; however
, "
acknowledgement" may be viewed differently in some states
than in others. Staff believes it may be helpful to explain what it believes is meant by
acknowledgement in Idaho. The following policy on integrated resource planning, adopted by the
Commission in Order No , 25260, Case No. GNR-93-3 is provided in the way of explanation:
POLICIES ADDRESSING INTEGRATED RESOURCE PLANNING. Each
electric utility regulated by the Idaho Public Utilities Commission with retail
sales exceeding 500 000 kilowatt hours in a calendar year shall employ
integrated resource planning. Each electric utility's integrated resource plan
must be updated on a regular basis (no later than biennially), must provide an
opportunity for public participation and comment, and must be implemented.
This plan constitutes the base line against which the utility s performance will
ordinarily be measured. The requirement for implementation of a plan does
not mean that the plan must be followed without deviation. The requirement
of implementation of a plan means that an electric utility, having made an
integrated resource plan to provide adequate and reliable service to its electric
customers at the lowest system cost, may and should deviate from that plan
when presented with responsible, reliable opportunities to further lower its
planned system cost not anticipated or identified in new existing or earlier
plans and not undermining the utility s reliability. In order to encourage
prudent planning and prudent deviation from past planning when presented
with opportunities for improving upon a plan, an electric utility s plan must be
on file with the Commission and available for public inspection, but the filing
of the plan does not constitute approval or disapproval of the plan having the
force and effect oflaw, and the deviation from the plan would not constitute
violation of the Commission s orders or rules. The prudence of a utility s plan
and the utility s prudence in following or not following a plan are matters that
may be considered in a general rate proceeding or other proceeding in which
those issues have been noticed.
STAFF COMMENTS AUGUST 21 , 2007
The 2007 IRP represents PacifiCorp s best effort to plan according to what is known at this
point in time. Staff fully expects that as conditions change and as new and better information
becomes available, future IRPs will change accordingly. For PacifiCorp, the environment for
resource planning is certainly in a state of flux. Not only is the Company at a point of significant
resource procurement, it has to do so under increasingly stringent conditions in order to
accommodate various state jurisdictional requirements. The IRP can no longer be looked upon as
choosing resources based solely on cost/risk metrics. Political initiatives are now an important
part of the planning process. Due to the nature of IRP acknowledgement, states such as Idaho
have a more diminutive role in resource evaluation than ever before. Staff plans to look closely at
all utility IRPs, chosen portfolios, action plans and RFPs to assure that the most economical
resources are acquired.
RECOMMENDATION
Staff believes that the Company has adequately met the Commission s requirements in
regard to the 2007 IRP. While not endorsing the proposed action plan, Staff believes that
PacifiCorp has performed extensive analyses, provided sufficient opportunities for public input
and that the end result is representative of the best information available to the Company at the
time of preparation. Stafftherefore recommends that the Commission acknowledge the 2007
Integrated Resource Plan. Given the increasing role of jurisdictional resource mandates in the
planning process, Staff further recommends that future IRPs incorporate a section devoted to the
impacts, if any, of state policies on the selection of preferred portfolios. Such a section would
enable the Commission to view the IRP from a system-wide standpoint, and from an Idaho
jurisdictional perspective.
Respectfully submitted this). ,1:: day of August 2007.
;J~~
eil Price
Deputy Attorney General
Technical Staff: Bryan Lanspery
i:umisc:comments/paceO7.11npbl
STAFF COMMENTS AUGUST 21 , 2007
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CERTIFICATE OF SERVICE
HEREBY CERTIFY THAT I HAVE THIS 21 sT DAY OF AUGUST 2007
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN
CASE NO. PAC-07-, BY MAILING A COpy THEREOF, POSTAGE PREPAID
TO THE FOLLOWING:
DEAN BROCKBANK
SENIOR COUNSEL
ROCKY MOUNTAIN POWER
201 S MAIN ST STE 2300
SALT LAKE CITY UT 84111
MAIL: dean.brockbank~pacificom.com
BRIAN DICKMAN
MANAGER, ID REGULATORY AFFAIRS
ROCKY MOUNTAIN POWER
201 S MAIN ST STE 2300
SALT LAKE CITY UT 84111
E- MAIL: brian. dickmanCCV,pacificofP com
DATA REQUEST RESPONSE CENTER
ACIFICORP
825 NE MULTNOMAH STE 2000
PORTLAND OR 97232
MAIL: datarequest(CUJJacificofP com
SECRE~Y 1
CERTIFICATE OF SERVICE