20071004Motion to Approve Settlement.pdf

Jordan A. White
Rocky Mountain Power
201 South Main, Suite 2300
Salt Lake City, Utah 84111
Tel: [phone]
Fax: [phone]
iordan. whiteaQpacificorp. com
Attorney for Rocky Mountain Power
William M. Eddie (ISB #5800)
ADVOCATES FOR THE WEST
610 SW Alder St., Suite 910
Portland , OR 97205
Ph: [phone]
Fax: [phone]
bedd ie~advocateswest. org
Attorney for Renewable Northwest Project
and NW Energy Coalition
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE PETITION OF
ROCKY MOUNTAIN POWER FOR AN ORDER
REVISING CERTAIN OBLIGATIONS TO
ENTER INTO CONTRACTS TO PURCHASE
ENERGY GENERATED BY WIND-POWERED
SMALL POWER GENERATION QUALIFYING
FACILITIES
CASE NO.PAC-07 -
(Reference related cases
nos. IPC-07-03 and
A VU-07 -
COMES NOW, Rocky Mountain Power ("Rocky Mountain Power" or the
Company ) and Renewable Northwest Project and Northwest Energy Coalition
Renewable Coalition ) hereinafter Party or collectively "Parties , and pursuant to RP
56 and 272 move the Commission for an order approving the enclosed Settlement
Stipulation dated October 3, 2007 ("Stipulation ) which is identified as Attachment 1. In
JOINT MOTION TO APPROVE SETTLEMENT STIPULATION-
support of this Motion, Rocky Mountain Power and Renewable Coalition respectfully
state as follows:
Introduction and Backaround
On June 17 , 2005, in Case No. IPC-05-, Rocky Mountain Power filed
a petition with the Commission requesting a temporary suspension from the Company
obligation under Sections 201 and 210 of the Public Utility Regulatory Policies Act of
1978 ("PURPA") and various Commission orders , to enter into new contracts to
purchase energy generated by wind powered Qualifying Facilities ("QFs ). Rocky
Mountain Power and Avista intervened in IPC-05-22 and requested any suspension
of obligations under PURPA apply to each of the three major regulated utilities in Idaho.
Following a public hearing and oral argument on August 4, 2005, the Commission
entered Interlocutory Order No. 29839. The Interlocutory Order did not approve a
temporary suspension but, instead, reduced the published rate eligibility cap for
intermittent QF wind projects from 10 average MW/month to 100 kW and required
individual contract negotiations for wind QFs larger than 100 kW. Order No. 29839 also
established grandfathering criteria for QF wind projects that were in various stages
negotiation with Rocky Mountain Power at the time Order No. 29839 was issued.
On August 23, 2005 in Order No. 29872, the Commission designated
Interlocutory Order No. 29839 as final Order No. 29851 to allow parties to seek
reconsideration and appeal of the Interlocutory Order. Subsequently, Order No. 29872
denied the petitions and cross-petitions for reconsideration of final Order No. 29851 filed
by Windland Incorporated , Rocky Mountain Power and the Commission Staff and
established the right of aggrieved parties to appeal all final and interlocutory orders
JOINT MOTION TO APPROVE SETTLEMENT STIPULATION-
previously issued in Case No. IPC-05-22 to the Idaho Supreme Court. No appeals
were filed.
In Interlocutory Order No. 29839 (Final Order No. 29851), the Commission
found that wind generation presents operational integration costs to a utility different
from other PURPA qualified resources. (Order No. 29839 p. 8). The Commission also
found that the unique supply characteristics of wind generation and the related
integration costs provide a basis for adjustment of the published avoided cost rates, a
calculated figure that may be different for each utility. (Order No. 29839 p. 8).
On April 23, 2007 , Rocky Mountain Power filed a Petition to initiate this
case. In its Petition the Company presented the final Wind Integration Study and
requested that the Commission issue its order establishing the following:
(a)Raising the cap on entitlement to published avoided cost rates for
intermittent wind powered from the current level of 100 kW to 10 000 average kWs per
month ("10 average MWs/mo" or "10 aMW'); and
(b)Reducing the published avoided cost rates applicable to intermittent wind
powered QFs to compensate for the increase in system costs due to wind variability.
The Company proposed new published avoided cost rates for wind QFs in its Petition;
and
(c)Authorizing Rocky Mountain Power to purchase state-of-the-art wind
forecasting services that will provide Rocky Mountain Power with forecasts of wind
conditions in those geographic areas in which wind generation resources are located.
The Petition requested that QFs reimburse the Company for their share of the on-going
cost of the wind forecasting service; and
JOINT MOTION TO APPROVE SETTLEMENT STIPULATION-
(d)Authorizing the Company to include a "mechanical availability guarantee
in all contracts with new intermittent wind powered QF resources. The mechanical
availability guarantee would require wind powered QFs to demonstrate monthly that
except for scheduled maintenance and events of force majeure the QF wind project
was physically capable and available to generate at full output during 85% of the hours
in the month.
(e)Finally, the Petition requested that if the Commission ordered the changes
to the published rates , authorized the acquisition and funding of the wind forecasting
services and authorized the inclusion of mechanical availability guarantees in future
contracts for purchases of energy from intermittent wind powered QFs , Rocky Mountain
Power proposed that the Commission remove the requirement that the 90%/110%
performance band be included in new contracts for energy purchases from intermittent
wind powered QFs.
On June 20 2007, a public workshop was held in this docket, although the
discussion on that day primarily focused on Idaho Power Company s wind integration
study. Interested parties (including the Renewable Coalition) continued to have informal
discussions with Rocky Mountain Power on its study.
Subsequently, on July 31 , and August 10 , 2007 , Commission Staff
sponsored joint settlement workshops in Case Nos. IPC-07-03 (Idaho Power), PAC-
07-07 (Rocky Mountain Power) and AVU-07-02 (Avista) to explore whether parties
of record could agree to a common generic wind integration adjustment to published
rates.
JOINT MOTION TO APPROVE SETTLEMENT STIPULATION-
Participants in the joint settlement workshops were unable to reach a
compromise generic agreement. However, as a direct result of those joint settlement
discussions, additional informal discussions regarding settlement have continued.
The result of those informal settlement discussions is a Settlement
Stipulation which is presented with this Petition.
Settlement Provisions
The Stipulation , Attachment 1 , has several features which are explained in
more detail as follows:
10.Intearation Charae Rocky Mountain Power s study concluded that it
would incur integration costs averaging $5.04/MWh for a level of wind penetration on its
system of about 20% of peak load. The Stipulation proposes an integration charge
equivalent to the calculated cost of wind integration on a per MWh basis provided in the
Company s most recent Commission-acknowledged Integrated Resource Plan ("I RP"
The Company current estimated cost of wind integration in the 2005 IRP
$5.04/MWh. The estimated cost of wind integration in the 2007 IRP, which is now
pending Commission acknowlegement, is $5.1 O/MWh.
11.The term "applicable published rate" means the applicable avoided cost
rate approved by the Idaho PUC for purchases of power from QFs producing less than
10aMW, for the relevant contract year and time period of energy generation.
12.Assumptions and Reasonableness
After several years of integrating significant amounts of wind energy to its
system , Rocky Mountain Power s most recent (2007) IRP only slightly revised the
Company s estimated cost of wind integration from $5.04/MWh in the 2005 IRP to
JOINT MOTION TO APPROVE SETTLEMENT STIPULATION-
$5. 1 O/MWh. These figures represent the average cost of wind integration for the full
IRP portfolio of wind generation. Rocky Mountain Power presently integrates 400 MWof
installed wind capacity to its system , and has entered final agreements to integrate an
additional 530 MW. In addition , Rocky Mountain Power reasonably anticipates acquiring
another 400 MW of wind generation during calendar 2008-2009 through asset
ownership or power purchase agreements. .
It is the Parties' position that the integration charges set out in the Stipulation are
reasonable at. the current time. Rocky Mountain Power believes that the integration
charge set out in the Stipulation is within a reasonable range of estimates of the
Company s costs of integrating wind resources. If the best available scientific data and
the Company s experience demonstrates that the percentage integration charge should
be increased or decreased, the Company will include that information in its integrated
resource planning process and present those results to the Commission.
Finally, the Parties believe that the integration charge contained in the Stipulation
will provide long-term stability for QF development and will provide customers with
protection from published rates that are too high.
13.Elimination of the 90%/110%Performance Band Mechanical
Availability Guarantee. In the Stipulation the Parties have agreed that inclusion of the
90%/110%" performance band approved by the Commission in Order No. 29632 will be
eliminated from the template Firm Energy Sales Agreement for future Wind QFs. The
90%/110% performance band will be replaced in future FESAs by the integration charge
described above, a mechanical availability guarantee as described in Rocky Mountain
Power s Petition in this case , and a wind forecasting charge as described in paragraph
JOINT MOTION TO APPROVE SETTLEMENT STIPULATION-
16 below.QFs currently holding approved FESAs which include the 90%/110%
performance band can elect to amend their existing FESAs to replace the 90%/110%
performance band with the mechanical availability guarantee but if they make that
election , they will be subject to the wind integration charge and wind forecasting charge
in effect when their wind QF project achieves its Operation Date.
14.On-aoina Review of Wind Intearation Costs In the Stipulation , the
Parties have agreed that Rocky Mountain Power will continue to review its wind
integration study and update its study to include the results of available scientific data
and actual operating experience. Rocky Mountain Power will review its expected cost
of wind integration in light of the best available scientific data and actual operating
experience.Expected wind integration cost information will be included in the
Company s integrated resource planning ("IRP") process in the same way that costs for
other generating resources are included in the IRP. Rocky Mountain Power currently
provides public input meetings for its IRP assumptions. Idaho wind developers will be
notified as part of the public meeting process and can contribute their input at those
meetings to discuss Rocky Mountain Power s wind integration study and new data
related to wind integration costs prior to the publishing of the Company s next (2009)
IRP.
15.Wind Eneray Production Forecastina During the workshops
undertaken in this case , a lot of time and effort was devoted to trying to understand how
the use of state-of-the-art wind energy production forecasting could be used to reduce
the cost of integrating intermittent wind resources on utility systems. There seems to be
general consensus that wind energy production forecasting will be useful in achieving
JOINT MOTION TO APPROVE SETTLEMENT STIPULATION-
that goal. To that end , in the Stipulation the Parties have agreed that Rocky Mountain
Power will have the option of contracting with a nationally recognized wind energy
production forecasting vendor to produce a wind energy production cost for Rocky
Mountain Power s service area. The cost of this wind energy production forecasting will
be allocated to all Wind QFs signing new FESAs with Rocky Mountain Power on a
uniform per MW basis. The cost of wind forecasting attributable to an individual Wind
QF will be shared equally between Rocky Mountain Power and the Wind QF , with an
annual cap on the Wind QFs maximum liability for such costs set at 0.1 % of the total
energy payments Rocky Mountain Power made to the Wind QF under the applicable
FESA during the previous Contract Year. During the first Contract Year, the cap will be
set at 0.1 % of the Wind QFs estimated total energy payments based on the Wind QF's
original estimate of energy production in their FESA. Rocky Mountain Power will deduct
the Wind QF's calculated share during the first eleven months of each year and
subsequently refund any overpayment (payments that exceed the cap) in the December
invoice.. Rocky Mountain Power will consult with Wind QFs in setting up the protocols
for the wind energy forecasting program. It is Rocky Mountain Power s intent that the
wind energy forecasting program be practical and cost effective.
Conclusion
Rocky Mountain Power and Renewable Coalition request that the Commission
process this Motion by modified procedure in accordance with RP 201 et seq.
For the reasons cited herein , Rocky Mountain Power and Renewable Coalition
respectfully submit that the Stipulation is in the public interest and hereby jointly request
that, after appropriate review, the Commission enter its Order (1) approving the
JOINT MOTION TO APPROVE SETTLEMENT STIPULATION-
Stipulation; and (2) authorizing Rocky Mountain Power to enter into new contracts with
existing and future wind QFs utilizing the charges, terms and conditions contained in the
Stipulation.
Respectfully submitted this day of October, 2007.
ROCKY MOUNTAIN POWER
JORDAN A. WH ITE
Attorney for Rocky Mountain Power
Respectfully submitted this day of October 2007.
RENEWABLE NORTHWEST PROJECT
AND NW ENERGY COALITION
WILLIAM M. EDDIE
JOINT MOTION TO APPROVE SETTLEMENT STIPULATION-
Stipulation; and (2) authorizing Rocky Mountain Power to enter into new contracts with
existing and future wind QFs utilizing the charges, terms and conditions contained in the
Stipulation.
jr,
Respectfully submitted this.tZ-- day of October, 2007.
ROC
JORDAN A. WHITE
Attorney for Rocky Mountain Power
Respectfully submitted this day of October 2007.
RENEWABLE NORTHWEST PROJECT
AND NW ENERGY COALITION
WILLIAM M. EDDIE
JOINT MOTION TO APPROVE SETTLEMENT STIPULATION -
CERTIFICATE OF SERVICE
I hereby certify that on the 3rd day of October 2007 , I caused to be served , via
the method(s) indicated below, true and correct copies of the foregoing document
upon:
Commission Staff
Scott Woodbury
Deputy Attorney General
Idaho Public Utilities Commission
472 W. Washington (83702)
O. Box 83720
Boise, Idaho 83720-0074
Hand Delivered
S. Mail
Overnight Mail
FAX
--X Email scott.woodburvaQpuc.idaho.Qov
Avista Corporation
Michael Andrea, Attorney
Avista Corporation
1411 E. Mission Avenue
Spokane, WA 99203
Hand Delivered
S. Mail
Overnight Mail
FAX
--X Email
m ichael. andreaaQavistacorp. com
Exergy Development Group of Idaho
Peter J. Richardson, Esq.
Richardson & O'Leary
515 N. 2ih Street
O. Box 7218
Boise, Idaho 83702
Hand Delivered
---1LU.S. Mail
Overnight Mail
FAX..x Email
petera;D.richardsonandolearv. com
Don Reading
Ben Johnson Associates
6070 Hill Road
Boise, Idaho 83702
Hand Delivered
---1LU.S. Mail
Overnight Mail
FAX..x Email dreadinQaQmindsprinq.com
Idaho Windfarms LLC
Glenn Ikemoto
Authorized Manager
Idaho Windfarms, LLC
672 Blair Ave.
Piedmont, CA 94611
Hand Delivered
---1LU.S. Mail
Overnight Mail
FAX..x Email qlennia;D.pacbelLnet
JOINT MOTION TO APPROVE SETTLEMENT STIPULATION -
Intermountain Wind LLC
Dean J. Miller
McDevitt & Miller LLP
PO Box 2564
Boise, ID 83701-2564
Stephen Martin
Intermountain Wind LLC
PO Box 3189
Idaho Falls, ID 83404-3189
Hand Delivered
S. Mail
Overnight Mail
FAX
----X. Email
ioeCWmcdevitt-m iller. com
INL
Gary D. Seifert, P.
Kurt Myers, P. E.
INL
2525 S. Fremont Ave.
O. Box 1625, MS 3810
Idaho Falls, Idaho 83415
Hand Delivered
--1LU.S. Mail
Overnight Mail
FAX
Email qarv.seifertaQinLqov
Kurt. mversaQinLqov
William M. Eddie
JOINT MOTION TO APPROVE SETTLEMENT STIPULATION -
PAC-O7-
ATTACHMENT 1 TO:
JOIN,T MOTION FOR APPROVAL OF
SETTLEMENT STIPULATION
Jordan A. White
Rocky Mountain Power
201 South Main , Suite 2300
Salt Lake City, Utah 84111
Tel: [phone]
Fax: [phone]
iordan. whiteaQpacificorp. com
Attorney for Rocky Mountain Power
William M. Eddie (ISB #5800)
ADVOCATES FOR THE WEST
610 SW Alder St., Suite 910
Portland, OR 97205
Ph: [phone]
Fax: [phone]
bedd ie~advocateswest. org
Attorney for Renewable Northwest Project
and NW Energy Coalition
;'~
c. .::L)
fl!1...lIt) L - 4 j'i :
roA1'/0 PUBLIC
UTiLITIES COl~1MISSiON
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE PETITION OF
ROCKY MOUNTAIN POWER FOR AN ORDER
REVISING CERTAIN OBLIGATIONS TO
ENTER INTO CONTRACTS TO PURCHASE
ENERGY GENERATED BY WIND-POWERED
SMALL POWER GENERATION QUALIFYING
FACILITIES
STIPULATION
CASE NO.PAC-07-
(Reference related cases
nos. IPC-07-03 and
A VU-07 -
This Settlement Stipulation ("Stipulation ) is entered into by and among
Rocky Mountain Power ("Rocky Mountain" or "the Company ), Renewable Northwest
Project and NW Energy Coalition ("Northwest Coalition), the Staff of the Idaho Public
Utilities Commission ("Staff'), and the other signatories to this Stipulation , all of which
are individually referred to as "Party" or collectively referred to as, the "Parties.
PAC-O7-07 SETTLEMENT STIPULATION-
INTRODUCTION
The Parties agree that this Stipulation represents a fair, just and
reasonable compromise of the issues raised in this proceeding and that this Stipulation
is in the public interest. The Parties believe that the Stipulation and its acceptance by
the Idaho Public Utilities Commission ("IPUC" or "Commission ), represents a
reasonable resolution of the issues identified in this matter. The Parties, therefore
respectfully request that the Commission , in accordance with Rule of Procedure ("RP"
274 , approve the Stipulation and all of its terms andcondition$ without material change
or condition.
II.BACKGROUND
In Case No. IPC-05-, the Commission endeavored to properly
determine the appropriate pricing of intermittent generation purchased from Qualified
Facilities ("QFs ) pursuant to Section 201 and 210 of the Public Utility Regulatory
Policies Act of 1978 ("PURPA") and ascertain whether any related utility integration
costs were fully reflected in the published avoided cost rates.Pending this
determination, the Commission issued Order No. 29839 in August 2005 reducing the
published rate eligibility cap for intermittent QFs using wind as the motive force ("Wind
QFs ) from 1 0 average MW ("aMW') per month to 1 00 kW and required individual
contract negotiations for Wind QFs larger than 100 kW.
As part of its 2004 Integrated Resource Plan Rocky Mountain Power
performed a study to quantify the additional costs it would incur directly related to
purchasing a significant amount of wind generation ("Wind Integration Study" or
Study ). In April 2007, Rocky Mountain Power filed the Study with the Commission
PAC-O7-07 SETTLEMENT STIPULATION-
together with the Petition that initiated this docket proposing an integration adjustment
set at $5.04/MWh. In its Petition , Rocky Mountain requested that the Commission issue
an order:
Raising the cap on entitlement to published avoided cost rates for
intermittent Wind QFs from the current level of 100 kW to 10 000 average kWs per
month ("10 aMWs/month"
Reducing the published avoided cost rates applicable to intermittent Wind
QFs to compensate for the increase in system costs due to wind variability as described
in the -Petition;
Authorizing Rocky Mountain Power to purchase state-of-the-art wind
energy production forecasting services that will provide Rocky Mountain Power with
forecasts of wind conditions in those geographic areas in which Wind QFs are located.
Rocky Mountain Power also requested that the order provide that Wind QFs reimburse
the Company for its share of the on-going cost of the wind forecasting service;
Authorizing the Company to include a "mechanical availability guarantee
("MAG") in all contracts with new intermittent Wind QFs. The MAG would require
intermittent Wind QFs to demonstrate monthly that, except for scheduled maintenance
and events of force majeure, the Wind QF project was physically capable and available
to generate at full output during 85% of the hours in the month; and
If the Commission orders the requested changes to the published rates
authorizes the acquisition and funding of the wind forecasting services, and authorizes
the inclusion of a MAG in future contracts for purchases of energy from intermittent
Wind QFs, Rocky Mountain Power proposed that the Commission remove the
PAC-O7-07 SETTLEMENT STIPULATION-
requirement that the 90%/110% performance band be included in new contracts for
energy purchases from intermittent Wind QFs.
Interested parties participated in multiple workshops and settlement
discussions regarding the above-captioned proceeding and the related proceedings in
docket numbers IPC-05-22 and IPC-07-03.
As a result of those workshops and other settlement discussions, as a
compromise to fully resolve the issues as among the Parties raised in the above-
captioned proceeding, and for other consideration as set forth below, the Parties agree
to the following terms:
III.Terms of the Stipulation
(a)Rocky Mountain Power s published avoided cost rates for Wind QFs,wili
be adjusted to recognize an assumed cost of integrating the energy generated by Wind
QFs as a part of the Company s generating resource portfolio. The integration charge
will be equivalent to the calculated cost of wind integration on a per MWh basis provided
in the Company s most recent Commission-acknowledged Integrated Resource Plan
I RP"). The Company s current estimated cost of wind integration in the 2005 IRP is
$5.04/MWh. The estimated cost of wind integration in the 2007 IRP, which is now
pending Commission review, is $5. 1 O/MWh. The integration charge will remain fixed
throughout the term of the contract and will be applied as a decrement to the applicable
published rate.
The term "applicable published rate" means the applicable avoided cost rate
approved by the IPUC and updated periodically for purchases of power from QFs
PAC-O7-07 SETTLEMENT STIPULATION-
producing less than 10 aMW/month , for the relevant contract year and time period of
energy generation.
(b)The "90%/110%" performance band approved by the Commission
in Order No. 29632 will be eliminated from the template Firm Energy Sales Agreement
for future Wind QFs. The 90%/110% performance band will be replaced in future
FESAs by the integration charge described in paragraph 3(a) above, a MAG as
described in Rocky Mountain Power Petition in this case, and a wind forecasting
charge as described in paragraph 3(e) below.
(c)Rocky Mountain Power will review its expected cost of wind
integration in light of the best available scientific data and actual operating experience.
Expected wind integration cost information will be included in the Company s IRP
process in the same way that costs for other generating resources are included in the
IRP.
(d) Rocky Mountain Power currently provides public input meetings for its
I RP assumptions. Idaho wind developers will be notified as part of the public meeting
process and can contribute their input at those meetings to discuss PacifiCorp s wind
integration study and new data related to wind integration costs prior to the publishing of
the Company s next (2009) IRP.
(e)Rocky Mountain Power will contract with a qualified wind energy
production forecasting vendor. The cost of this forecasting service will be allocated to
all Wind QFs holding FESAs with Rocky Mountain Power, and other wind generation on
Rocky Mountain Power s system, on a uniform per-MW basis. The cost attributable to
an individual Wind QF will be shared equally between Rocky Mountain Power and the
PAC-O7-07 SETTLEMENT STIPULATION-
Wind QF , with an annual cap on the Wind QFs maximum liability for such costs set at
1 % of the total energy payments Rocky Mountain Power made to the Wind QF under
the applicable FESA during the previous Contract Year. During the first Contract Year
the cap will be set at 0.1 % of the Wind QFs estimated total energy payments based on
the Wind QF's original estimate of energy production in their FESA. Rocky Mountain
Power will deduct the Wind QFs calculated share during the first eleven months of each
year and subsequently refund any overpayment (payments that exceed the cap) in the
December invoice. Rocky Mountain Power will consult with Wind QFs in setting up the
protocols for the wind energy forecasting program. It is Rocky Mountain Power s intent
that the wind energy forecasting program be practical and cost effective.
Reasonable Compromise The Parties agree that this Stipulation
represents a compromise of the Parties positions on the issues raised in the above-
captioned proceeding. As provided in RP 272 , other than any testimony filed in support
of the approval of this Stipulation, and except to the extent necessary for a Party to
explain before the Commission its own statements and positions with respect to this
Stipulation , all statements made and positions taken in negotiations relating to this
Stipulation shall be confidential and will not be admissible in evidence in this or any
other proceeding.
Best Efforts for Approval The Parties submit this Stipulation to the
Commission and recommend approval in its entirety pursuant to RP 274. The Parties
shall support this Stipulation before the Commission and no Party shall appeal a
Commission Order approving this Stipulation or an issue resolved by this Stipulation.
this Stipulation is challenged by any person not a party to this Stipulation , the Parties to
PAC-O7-07 SETTLEMENT STIPULATION-
this Stipulation reserve 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
Stipulation. Notwithstanding this reservation of rights, the Parties to this Stipulation
agree that they will continue to support the Commission s adoption of the terms of this
Stipulation.
Riaht to Withdraw If the Commission rejects any part or all of this
Stipulation , or imposes any additional material conditions on approval of this Stipulation
each Party reserves the right, upon written notice to the Commission and the other
Parties to this proceeding, within seven days of the date of such action by the
Commission , to withdraw from this Stipulation, and each Party shall be entitled to seek
reconsideration of the Commission s Order, file testimony as it chooses, cross-examine
witnesses , and do all other things necessary to put on such case as it deems
appropriate.In such case , the Parties immediately will request that a prehearing
conference be convened for purposes of establishing a procedural schedule for the
completion of the case. The Parties agree to cooperate in developing 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.
10.Public Interest The Parties agree that this Stipulation is in the public
interest and that all of its terms and conditions are fair , just and reasonable.
11.Commission Approval The obligations of the Parties under this
Stipulation are subject to the Commission s approval of this Stipulation in accordance
with its terms and conditions.
PAC-O7-07 SETTLEMENT STIPULATION-
12.Counterparts This Stipulation may be executed in counterparts and
each signed counterpart shall constitute an original document.
13.Sianature Clause The signatories hereto represent that they have been
authorized to enter into this Stipulation on behalf of the Party for whom they sign.
PAC-O7-07 SETTLEMENT STIPULATION-
Respectfully submitted this 2nd day of October 2007.
ROCKY MOUNTAIN POWER CORPORATION
JORDAN A. WHITE
Attorney for Rocky Mountain Power
RENEWABLE NORTHWEST PROJECT
AND NW ENERGY COALITION
WilLIAM M. EDDIE
PAC-O7-07 SETTLEMENT STIPULATION-
Respectfully submitted this 2nd day of October 2007.
ROCKY MOUNTAIN POWER CORPORATION
JOR
Attorney for Rocky Mountain Power
RENEWABLE NORTHWEST PROJECT
AND NW ENERGY COALITION
WILLIAM M. EDDIE
PAC-O7-07 SETTLEMENT STIPULATION-
IDAHO WINDFARMS LLC
=--bENN IK
Authorized Manager
PAC-O7-07 SETTLEMENT STIPULATION -