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Home My WebLink About20150710Application for Intervenor Funding.pdfMARKA.ECnoHAWK ErucL.Omun JoSEPHT. PRESToN ATToRNf,YS MomclSANADI Paur,rcal Ecno H.Lwr & Or,sEN, Pr,r,c S05Pmsrmrc Aw., Srs. 100 POBOX6119 Pocernl,ro, ID tlit2(Xt{l f 9 2g&47E.1624 208.47&1670mx WWW.ECHOHAWICCOM July 9, 2015 C-{r- tfiv:, Jr:i GJ, a f\.,g (.r'l (* -1rir() o l1:1.:;r _t: - r,r,.1 \P (Jrt\) P.O. Box 83720 472 W . Washington Street Boise,ID 83720-0074 Re: X'iling of Application for Interenor X'unding of the ldaho Irrigation Pumpers Association, Inc. Case Nos. IPC-E-15-01, AYU-E-15-01, PAC-E-15-03, Consolidated Dear Commission Secretary Jewell: Enclosed for filing in the above-referenced matter please find the original and eight (8) copies of the Application for Intervenor Funding of The Idaho Irrigation Pumpers Association, Inc. Please file the Application accordingly and return a conforned copy to us in the enclosed envelope. Thank you for your kind assistance. Please contact me if you have any questions. Jean D. Jewell, Secretary Idaho Public Utilities Commission Sincerely, ,/4W*$ta* Monica Sanada Paralegal H:\WDOX\CLIENTS\ I 343\000 l\0005 84 I 6.DOCX Eric L. Olsen #4811 Echo Hawk & Olsen, PLLC 505 Pershing, Suite 100 P.O. Box 6119 Pocatello, Idaho 8320 5 -61 19 Telephone: (208) 478-1624 Facsimile: (208) 478-167 0 elo@echohawk.com Attorneys for Intervenor Idaho Irrigation Pumpers Association, Inc. ^i l: [ ]qLi: ' Jti:- , L.: .. ': il i'ir' Iil .r,f{ *: 5l BEFOERE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF IDAHO POWER COMPANY'S PETITION TO MODIFY TERMS AND CONDITIONS OF PURPA PURCHASE AGREEMENTS CASENO. IPC-E-15-01 IN THE MATTER OF AVISTA CORPORATION'S PETITION TO MODIFY TERMS AND CONDITIONS OF PURPA PURCHASE AGREEMENTS CASE NO. AVU.E-I5-01 IN THE MATTER OF ROCKY MOUNTAIN POER COMPANY'S PETITION TO MODIFY TERMS AND CONDITIONS OF PURPA PURCHASE AGREEMENTS CASE NO. PAC-E-15-03 APPLICATION FOR INTERVENOR FUNDING OF THE IDAHO IRRIGATION PUMPERS ASSOCIATION. INC. COMES NOW the Idaho Irrigation Pumpers Association, Inc. (Irrigators"), by and through counsel of record, Eric L. Olsen, and hereby respectfully makes application to the Idaho Public Utilities Commission ("Commission") for intervenor funding, pursuant to Idaho Code 5 6l-617A and IDAPA 55 31.01.01.161 through .165, in this consolidated case, as follows: (A) A summary of the expenses that the Irrigators request to recover broken down into legal fees, consultant fees and other costs and expenses is set forth in Exhibit "A" attached APPLICATION FOR INTERVENOR FUNDING OF THE IDAHO IRRIGATION PUMBERS ASSOCIATION,INC. - I hereto and incorporated by reference. Itemized statements are also included as Attachments 1 and 2 to Exhibit "A" in support of said summary and are incorporated by reference (B) The Irrigators' Legal Counsel, Eric L. Olsen, and its consultant, Anthony J. Yankel, P.E., fully participated in these proceedings. Procedurally, this case was completed on an accelerated basis, with direct and rebuttal testimony being filed and all parties preparing for and attending the technical hearings held on June 29 through June 30, 2015. Irrigators' Consultant, Anthony J. Yankel testified in support of Idaho Power Company's ("IPC") Petition. Mr. Yankel's testimony showed how the current assumptions built into IPC's avoided cost methodology are inconsistent with the manner in which IPC's supply side resources are actually utilized, while at the same time IPC is making sales-for-resale at substantially lower prices than the avoided cost rates. Mr. Yankel further recommended that the Commission open up a new docket to refine the avoided cost methodology that takes in the account IPC's actual operating conditions. The Irrigators' Legal Counsel, Eric L. Olsen, also participated in the technical hearings and cross examined Staff and Intervenor witnesses. (C) The expenses and costs incurred by the Irrigators set forth in Exhibit A and accompanying attachments are reasonable in amount and were necessarily incurred. The expenses and costs were incurred in reviewing the Irrigators' data requests and responses, drafting and filing direct testimony, preparing cross examination questions for various witnesses, and participating in technical hearings held by the Commission. Without incurring these expenses and costs, the Irrigators would not have been able to fully participate in this matter. (D) The costs described in Paragraph (A) above constitute a financial hardship for the Irrigators. The Irrigators are an Idaho nonprofit corporation qualified under I.R.C. 5 501(c)(5) APPLICATION FOR INTERVENOR FLINDING OF THE IDAHO IRzuGATION PUMBERS ASSOCIATION, INC. - 2 representing farm interests in electric utility rate matters affecting farmers in southern and central Idaho. The Irrigators rely solely upon dues and contributions voluntarily paid by members, together with intervenor funding, to support activities. Each year mailings are sent to approximately 7000 Idaho Irrigators (approximately two-thirds in the Idaho Power Company service area and on-third in the RMP service area), soliciting annual dues. The Irrigators recommend members make voluntary contributions based on acres inigated or horsepower per pump. Member contributions have been falling which is believed to be attributable to the effects of the great recession and increased operating costs and threats, particularly those relating to water right protection issues. From member contributions the Irrigators must pay all expenses, which generally included mailing expenses, meeting expenses and shared office space in Boise, Idaho, in addition to the expenses relating to participation in matters before the Commission. The Executive Director, Lynn Tominaga, is the only part-time paid contractor, receiving a retainer plus expenses for office space, office equipment, and secretarial services. Officers and directors are elected annually and serve without compensation. It has been and continues to be a financial hardship for the Irrigators to fully participate in important cases such as this one due to the time and expense that has to be incurred to fully participate in such a case. As a result of the Irrigators' financial constraints, participation in this case, and filing of testimony and cross-examination of witnesses has been selective. (E) The Irrigators' positions urged to be adopted by the Commission materially differed from those addressed by the Commission Staff and other parties. The Irrigators showed that the way in which IPC was operating its system was not consistent with the assumptions contained in the avoided cost model. This testimony supports the Commission shortening the APPLICATION FOR INTERVENOR FUNDING OF THE IDAHO IRRIGATION PUMBERS ASSOCIATION, INC. - 3 contract term as urged by IPC and Commission staff and supports the Irigators' proposal to firther refine the avoided cost methodology. (F) The Irigators' participation addressed issues of concem to the general body of users or consumers on IPC's system and Rocky Mountain Powers' ("RMP") system. If IPC or RMP have to purchase power that is not needed, all customerso rates will go up and such rates arguably would not be just and reasonable. (G) The Irrigators represent the irrigation class of customers under Schedule 24 on IPC's system and Schedule 10 on RMP's system. \ Based on the foregoing, it is respectfully submitted that the Irrigators are a qualifting intervenor and should be entitled to an award of costs of intervention in the maximum amount allowable pursuant to Idaho Code 5 6l-6l7[and IDAPA SS 31.01.01.161 through.165. DATED this 9tr day of July,2Ol5. Idatro Irrigation Pumpers Association, Inc. APPLICATION FOR INTBRVENOR zuNDING OF TIIE IDAHO IRRIGATION PUMBERS ASSOCIATION, INC. - 4 ECHO HAWK & OLSEN, PLLC CERTIFICATE OF SERVICE I hereby certify that on this 9th day of July,2Ol5,I caused to be served a true, correct, and complete copy of the foregoing document by the method indicated below, and addressed to the following: Jean D. Jewell, Secretary Idaho Public Utilities Commission P.O. Box 83720 472 W . Washington Street Boise, lD 83720-0074 Email: jj ewell@puc.state.id.us Donovan E. Walker Regulatory Dockets Idaho Power Company l22l W.Idaho St. P.O. Box 70 Boise,ID 83707-0070 Email : dwalker@idahopower.com dockets@ idahopower. com Donald L. Howell,II Daphne Huang Deputy Attorneys General Idaho Public Utilities Commission 472W. Washington P.O. Box 83720 Boise, ID 83720-0074 Email : don.howell@puc.idaho. gov daphne.huane@puc. idaho. eov Peter J. Richardson Gregory M. Adams Richardson Adams, PLLC 515 N. 27th Street Boise, lD 83702 Email : peter@richardsonadams. com sre s@.richardsonadams.com Don Reading 6070 Hill Road Boise,ID 83703 Email : dreading@mindsprins.com APPLICATION FOR INTERVENOR FUNDING OF THE IDAHO IRzuGATION PUMBERS ASSOCIATION, INC. - 5 tr U.S. Mail/Postage Paidtr E-Mail tr ,zTelecopy (Fax) V Overnight Mail tr Hand Delivered U.S. Mail/Postage Paid E-Mail Telecopy (Fax) Ovemight Mail Hand Delivered U.S. MaiVPostage Paid E-Mail Telecopy (Fax) Overnight Mail Hand Delivered tr U.S. Mail/Postage Paid V E-Mail tr Telecopy (Fax) tr overnight Mail tr Hand Delivered U.S. Mail/Postage Paid E-Mail Telecopy (Fax) Overnight Mail Hand Delivered vtrntr trVtrtru Vtrtrtr Benjamin J. Otto Idaho Conservation League 710 N. Sixth Street P.O. Box 844 Boise,ID 83701 Email : botto@idahoconservation.ore Matt Vespa Sierra Club 85 Second St., 2nd Floor San Francisco, CA 94105 Email : matt.vespa@sierraclub.org Leif Elgethun, PE, LEED AP Intermountain Energy Partners, LLC P.O. Box 7354 Boise, ID 83707 Email : leif@ sitebasedenergy. com Dean Miller McDewitt & Miller LLP 420W. Bannock St. Boise, ID 83702 Email : i oe@mcdevitt-miller.com Kelsey Jae Nunez Snake fuver Alliance P.O. Box 1731 Boise,ID 83701 Email : knunez@ snakeriveralliance.ore Ken Miller Snake River Alliance Email : kmiller@ snakeriveralliance.org Ted Weston Pacifi Corp/dba Rocky Mountain Power 201 S. Main Street, Suite 2300 Salt Lake city, uT 84111 Email : ted.weston@pacifi com.com APPLICATION FOR INTERVENOR FUNDING OF THE IDAHO IRRIGATION PUMBERS ASSOCIATION,INC. - 6 tr U.S. MailiPostage Paid V E-Mail tr Telecopy (Fax) tr Overnight Mailtr Hand Delivered tr U.S. Mail/Postage Paid Q,./r-vaittr Telecopy (Fax) tr overnight Mail tr Hand Delivered tr - U.S. Mail/Postage Paid-V E-Mail tr Telecopy (Fax) tr overnight Mail tr Hand Delivered tr U.S. Mail/Postage Paid V E-Mail tr Telecopy (Fax) tr overnight Mailtr Hand Delivered {u-*ul U.S. Mail/Postage Paid E-Mail Telecopy (Fax) Overnight Mail Hand Delivered tr U.S. Mail/Postage Paid(Y-tvtait tr Telecopy (Fax) n Overnight Mail tr Hand Delivered vtrtrx Daniel E. Solander Yvonne R. Hogle 201 S. Main Street, Suite 2300 Salt Lake City, UT 84111 Email : daniel. solander@pacifi corp.com yvonne.ho qel@pacifi corp.com Data Request Response Center PacifiCorp Email : datarequest@pacificorp.com C. Tom Arkoosh Arkoosh Law Offices 802 W. Bannock St., Ste. 900 P.O. Box 2900 Boise,ID 83701 Email : tom.arkoosh@arkoosh.com Erin Cecil Arkoosh Law Offices Email : erin. cecil@arkoosh.com Anthony Yankel 29814 Lake Road Bay Village, OH 44140 Email : tony@yankel.net Ronald L. Williams Williams Bradbury, PC 1015 W. Hays St. Boise, ID 83702 Email : ron@williamsbradbury.com Irion Sanger Sanger Law, PC 1117 SE 53'd Avenue Portland, OR972l5 Email : irionfEsanser-law.com APPLICATION FOR INTERVENOR FUNDING OF THE IDAHO IRzuGATION PUMBERS ASSOCIATION,INC. - 7 tr U.S. MailiPostage Paid-m./p-w"it tr Telecopy (Fax) tr overnight Mail tr Hand Delivered tr A.S. Mail/Postage Paid V E-Mail tr Telecopy (Fax) n Overnight Mail tr Hand Delivered V E-Mail vtrutr trWtrtrn trwntrtr U.S. Mail/Postage Paid E-Mail Telecopy (Fax) Overnight Mail Hand Delivered U.S. MaiVPostage Paid E-Mail Telecopy (Fax) Overnight Mail Hand Delivered W E-Mail U.S. MaiUPostage Paid E-Mail Telecopy (Fax) Overnight Mail Hand Delivered Michael G. Andrea Senior Counsel Avista Corporation 1411 E. Mission Ave., MSC-23 Spokane, WA99202 Email : michael. andrea@avistacom.com Clint Kalich, Manager Resource Planning & Analysis Avista corporation l4ll E. Mission Ave., MSC-7 Spokane, WA99202 Email : clint. kalich@avistacorp.com Frederick J. Schmidt Pamela S. Howland Holland & Hart, LLP 377 S. Nevada Street Carson City, NV 89703 Email : fschmidt@hollandhart. com Richard E. Malmgren Micron Technology, INc. 800 South Federal Way Boise,ID 83716 Email: remalmgren@micron.com Scott Dale Blickenstaff The Amalgamated Sugar Co, LLC 1951 S. Satum Way, Suite 100 Boise, ID 83702 Email : sblickenstaff@amalsugar.com Andrew Jackura Sr. Vice President North America Development Camco Clean Energy 9360 Station Street, Suite 375 One Tree, CO 80124 Email : andrew j ackura@ camcocleanenergy.com APPLICATION FOR INTERVENOR FLINDING OF THE IDAHO IRRIGATION PUMBERS ASSOCIATION, INC. - 8 tr U.S. MaiVPostage Paid A/ E-Mail X Telecopy (Fax) tr Overnight Mail n Hand Delivered tr U.S. Mail/Postage Paidfr/ E-Mail tr Telecopy (Fax) tr Overnight Mail tr Hand Delivered U.S. Mail/Postage Paid E-Mail Telecopy (Fax) Overnight Mail Hand Delivered U.S. Mail/Postage Paid E-Mail Telecopy (Fax) Ovemight Mail Hand Delivered tr - U.S. Mail/Postage Paid LlV E-Mail tr Telecopy (Fax) tr Overnight Mail tr Hand Delivered tr /A.5. Mail/Postage Paid V E-Mailtr Telecopy (Fax) tr overnight Mail tr Hand Delivered nVtrtru trYtrn Dean J. Miller McDewiu & Miller LLP 420W. Bannock St. Boise, ID 83702 Email : j oe@mcdevitt-miller.com John R. Hammond, Jr. Fisher Pusch LLP 101 S. Capitol Blvd., Suite 701 Boise, ID 83702 Email: jrh@fi sherpusch.com John Gorman Ecoplexus,Inc. 650 Townsend Street, Suite 310 San Francisco, CA 94103 Email: i ohns@ecoplexus.com H:\WDOX\CLIENTS\ I 343\000 I \0005 8399. DOC APPLICATION FOR INTERVENOR FUNDING OF THE IDAHO IRRIGATION PUMBERS ASSOCIATION,INC. - 9 trwtrtru trYtrtr U.S. Mail/Postage Paid E-Mail Telecopy (Fax) Overnight Mail Hand Delivered U.S. Mail/Postage Paid E-Mail Telecopy (Fax) Overnight Mail Hand Delivered tr -ti.S. Mail/Postage Paid Ay E-Mail U Telecopy (Fax) L. OLSEN DilIIBIT A ST]MMAPRY OF EXPENSES INCT]RRED BY IRRAGATORS l. [rgal Fees: Eric L. Olsen @artner) 37.5hrs @ $200/trour Costs: Travel/IVlileage: Lodging & Meals Total Legal Fees and Costs: 2. Consultant Anthony J. Yankel: Consultant Fees: 163 houn @ $150/hour Expenses: Travel, Lodging, Meals: Total Consultant Fees and Costs: TOTAL X'EES AI\[D COSTS $ 7,500.00 $ 250.00$ 206.43 $24,450.00 $ 1.327.29 $ 7,956.43 $25.777.29 $:[I.Z!3,ZZ ATTACHMET{T 1 Trans Date 02t09t2015 02t10t2015 o2t1312015 02t17t2015 02118t2015 02t24t2015 03t10t2015 03117t2015 03117t2015 02t23t2015 ELO Hours to Bill AmountAtty ELO ELO ELO ELO ELO ELO ELO ELO ELO Rate 0.4 200.1200 200 200 200 200 200 0.2 0.3 80 REVIEW NOTICE OF PURPA CASE; TELEPHONE CONFERENCE WITH TONY YANKEL REGARDING SAME 220 CALL AND LEAVE MESSAGE WITH LYNN TOMINAGA TELEPHONE CONFERENCE WITH LYNN TOMINAGA REGARDING INTERVENTION IN PURPA CASE SEE THAT PETITION TO INTERVENE IS PREPARED AND SEE THAT DATA REQUESTS ARE PREPARED REVIEW AND REVISE PETITION TO INTERVENE AND FIRST DATA REQUESTS; REVIEW FILED DOCUMENTS REVIEW PROTECTIVE AGREEMENT AND SIGN AND E-MAIL SIGNATURE PAGE AND EXHIBIT A; CALL AND LEAVE MESSAGE WITH TONY YANKEL REGARDING SIGNING EXHIBIT A CALL AND LEAVE MESSAGE WITH TONY YANKEL RE: PROTECTIVE AGREEMENT TELEPHONE CONFERENCE WITH TONY YANKEL RE: THE UPCOMING PURPA STATUS CONFERENCE; PARTICIPATE IN SCHEDULING CONFERENCE REVIEW DON HOWELL'S LETTER TO THE COMMISSION RE: THE MOTIONS TO CLARIFY; REVIEW RESPONSES TO DATA REOUESTS 20 REVIEW COMISSION CONSOLIDATION ORDER TELEPHONE CONFERENCE WITH TONY YANKEL RE: RESULTS OF STATUS CONFERENCE AND ADDITIONAL DATA REQUESTS REVIEW SCHEDULING ORDER AND RESPONSES OF IPC AND RMP TO CLEARWATER AND SIMPLOT MOTIONS IN PREPARATION FOR ANNUAL MEETING FINALIZE SECOND DATA REQUESTS TO IPC; FINALIZE DATA REQUESTS TO ROCKY 03t13t2015 ELO 140 100 800.4200 40 60200 200.1 1.1200 400.2 0.1 03t23t2015 ELO 03t25t2015 ELO 200 0.6 120 0410112015 ELO 04t16t2015 ELO 04t20t2015 ELO 04t21t2015 ELO 0412212015 ELO 04t27t2015 ELO 0512712015 ELO 40 280 0.2 200 200 200 200 MOUNTAIN; SEE THAT SAME ARE FILED AND SERVED ON PARTIES REVIEW DEADLINES; TELEPHONE CONFERENCE WITH TONY YANKEL RE: TIMING OF FILING TESTIMONY TELEPHONE CONFERENCE WITH TONY YANKEL REGARDING USE OF CONFIDENTIAL INFORMATION FOR TESTIMONY AND OUTSTANDING DATA REQUESTS; REVIEW PROTECTIVE AGREEMENT AND RULES OF PROCEDURE; CALL AND LEAVE MESSAGE WITH DONOVAN WALKER REGARDING USE OF CONFIDENTIAL INFORMATION; TELEPHONE CONFERENCE WITH DONAVAN WALKER REGARDING SAME TELEPHONE CONFERENCE WITH TONY YANKEL REGARDING REVIEW OF TESTIMONY; REVIEW DRAFT TESTIMONY REVISE TESTIMONY; CONFERENCE WITH YANKEL REGARDING SAME; REVIEW REVISED TESTIMONY REVIEW AND REVISE YANKEL DIRECT TESTIMONY AND PREPARE REDACTED VERSION; TELEPHONE CONFERENCE WITH YANKEL REGARDING SAME; CONFERENCE WITH TJL REGARDING SAME FILED TELEPHONE CONFERENCE WITH TONY YANKEL REGARDING REVIEW OF DIRECT TESTIMONY OF THE INTERVENORS IN PURPA CASE; SEE THAT OTHER INTERVENOR TESTIMONY IS PRINTED AND PUT IN BINDER; BEGIN REVIEWING DIRECT TESTIMONY IN PREPARATION FOR HEARING TELEPHONE CONFERENCE WITH TED WESTON RE: GETTING COPY OF CONFIDENTIAL TESTIMONY REVIEW EMAIL FROM RMP COUNSEL AND EMAIL CONFIDENTIAL PORTION OF YANKEL TESTIMONY TELEPHONE CONFERENCE WITH TONY YANKEL REGARDING: UPCOMING HEARING WHETHER HE NEEDS TO ATTEND THE HEARING; REVIEW COMMISSION RULES ON PRESENTATION OF TESTIMONY; EMAIL DONOVAN WALKER OF IPC; CALL AND LEAVE MESSAGE WITH TED WESTON; REVIEW STAFF AND INTERVENOR TESTIMONY; TELEPHONE CONFERENCE WITH TED WATSON REGARDING: PRESENTATION OF TESTIMONY; CONTINUED REVIEW OF INTERVENOR TESTIMONY 440 6803.4200 400.2200 500 520 05t2812015 06/08/2015 ELO ELO 20 60 0.1200 0.3 2.6 200 200 06/09i201 5 06t2212015 ELO ELO o6t28t2015 06t29t2015 ELO ELO 06/30/201s ELO 200 200 200 1.5 3OO CONTINUE REVIEW OF INTERVENOR TESTIMONY 200 TELEPHONE CONFERENCE WITH TONY YANKEL RE: HEALTH ISSUES AND TRAVELING; TELEPHONE CONFERENCE WITH DAPHNE HUANG RE:YANKEL'S TRAVEL ISSUES; DMFT EMAIL TO PARTIES RE: SAME AND TESTIFYING VIA CONFERENCE CALL; TELEPHONE CONFERENCE WITH DAPHNE HUANG RE: COMMISSIONER'S POSITION ON THE PRESENTING THE TESTIMONY OF TONY YANKEL; TELEPHONE CONFERENCE WITH TONY YANKEL RE: ATTENDANCE AT HEARING PREPARE FOR CROSS EXAMINATION OF STAFF AND INTERVENOR WITNESSES 200 17OO PREPARE FOR HEARINGS; PARTICIPATE lN TECHNICAL HEARINGS AND CROSS EXAMINE WITNESSES 8OO PREPARE FOR AND PARTICIPATE IN TECHNICAL HEARINGS; CROSS EXAMINE WITNESSES AND MAKE CLOSING STATEMENT 3OO PREPARE APPLICATION FOR INTERVENTOR FUNDING 4OO FINALIZE APPLICATION FOR INTERVERNOR FUNDING 7500 8.5200 7nno15 71912015 ELO ELO 200 200 1.5 2 37.5Billable ATTACHMENT 2 Date Feb. 10 q o0 rE oUo. 5 11 2 134 t72 182 2 4 94 102 Description Review filing and associated exhibit from Case 15-01 regarding the request to reduce the PURPA contracts from 20 years to 2 years. Read testimony of Company witnesses Grow and Allphin regarding case No. 15- Discussion with Don Reading regarding what other intervenors are thinking; begin development of interrogatories. Review materials from the last case where QF contracts were addressed--Case No. GNR-E-11-03. Finalize first set of interrogatories. Review treatment in past cases for QF's and follow the Commission orders regarding same. Review treatment in past cases for QF's and follow the Commission orders regarding same; discussions with Reading regarding his and my approach to the problem of too much QF. Review data responses to Simplot. Review data responses to Simplot; discussion with Reading; outline additional areas for questions. Review staff requests; review responses to Simplot. Review information (Company testimony and data responses) to develop a general approach to the case. Review responses to Irrigator requests; develop various scenarios of what went wTong. Review IPCo" cogenertion tariffs; compare with what is requested in the filing. t6 19 Mar 2 6 13 23 oo/ E or)Date E Description 24 4 Review filing of IPCo as well as responses to Irrigators and Simplot; develop interrogatories. 28 2 Review recently submitted material; analize IIPA request 10. April 2 2 Work with hourly system data to understand what happens when IPCo must curtail generation. 7 4 Review hourly system data to view how it works compared to the modeling of avoided cost. 8 6 Review hourly system data to view how it works compared to the modeling of avoided cost. 9 6 Review hourly system data to view how it works compared to the modeling of avoided cost. 10 5 Compile data regarding when the curtailments took place and what was being generated on the system. 13 8 Develop data for curtailments and the generation resources being used on the sYstem. t4 8 Develop data regarding the price of sales for resale and purchases vs the units operating on the system. 15 8 Develop table showing sales for resale prices vs. what units were operating on the system for June 2013. 16 8 Outline introduction to testimony; develop testimony regarding Exhibit 6 vs the information found. 17 8 Continue writing testimony; develop issues regarding sale-for-resale price and unit operation. 20 8 Draft introduction to testimony; review and edit testimony. ohotr =q o()Date g 21 7 Finalize testimony. Description 24 6 Review testimony of others; review data responses. June 23 5 Review testimony of others; develop crossexamination questions. 24 4 Review testimony of others; develop crossexamination questions. 25 4 Review additional testimony of others; develop crossexamination questions. 26 2 Final review of my testimony and others; prepare information needed to take to support my testimony. 28 7 Travel to Boise; review filing and my testimony 29 5 Prepare for and attend hearing 30 7 Return home. Total. 163