20181106Keen Direct.pdf

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STATE OF IDAHO
OFFICE OF THE ATTORNEY GENEBAL
LAWRENCE G. WASDEN
November 6,2018
Transmitted Via Hand Delivery and by E-mail
Commission Secretary
Idaho Public Utilities Commission
472W. Washington St.
Boise, Idaho 83702
Re: Case Nos. AVU-E-17-09 and AVU-G-I7-05
Enclosed for filing in the above-referenced Case Nos. are an original and 9 copies of the Direct
Testimony of Shelley Keen, along with IDWR ExhibitNo. 901.
A service list is attached, with the parties receiving a complete copy of this filing. If you have
any questions, please do not hesitate to contact Ganick Baxter on behalf of the Idaho Department of
Water Resources at 208-287 -4800 or gbaxter@ i d wr. i dah o. gov.
Sincerely
Baxter
Deputy Attorney General
Enclosures
Natural Resources Division - Water Besources Section
P.O. Box 83720 Boise, ldaho 83720-0098
Telephone: [phone], Legal FAX: [phone]
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ON BEHALF OF THE IDAHO DEPARTMENT OF WATER RESOURCES pr . !,r. r ,-.. i. U i t: ii.'.-;.:
LAWRENCE G. WASDEN
ATTORNEY GENERAL
DARRELL G. EARLY
Deputy Attorney General
Chief, Natural Resources Division
GARRICK L. BAXTER,ISB #6301
EMMI BLADES,ISB # #8682
Deputy Attorneys General
Idaho Department of Water Resources
P.O. Box 83720
Bo ise, ldaho 837 20-0098
Telephone: [phone]
Facsimile: (208) 287 -67 00
sarrick.baxter@idwr. idaho. eov
emm [e-mail]
BEFORE THB IDAHO PUBLIC UTILITIES COMMISSION
t .: rtl !n' I sr-LlLr,:'*;,lfiilSSlOH
TN THE MATTER OF THE JOINT
APPLICATION OF HYDRO ONE
LIMITED (ACTING THROUGH ITS
INDIRECT SUBSIDIARY, OLYMPUS
EQUITY LLC) AND
AVISTA CORPORATION FOR AN
ORDER AUTHORIZING PROPOSED
TRANSACTION
CASE NOS. AW-8.17-09
AVU-G-17-05
DIRECT TESTIMONY OF'
SHELLEY KEEN
FOR THE IDAHO DEPARTMENT OF WATER RESOURCES
I Q. Please state your name, job title and business address.
2 A. My name is Shelley Keen. I am employed as the Water
3 Allocation Bureau Chief of the Idaho Department of Water Resources
4 ("IDWR"). My business address is 322 E. Front Street, Suite 648,
5 Boise, ID 83720-0098.
6 a. Please briefly describe your educational background.
7 A. I graduated from Central Washington University,
8 Ellensburg, Washington, with a Bachelor of Arts Degree in
9 Geography (Natural Resource Policy emphasis) in 1988. I have also
l0 attended the University of Idaho, Moscow, Idaho, where I completed
l l 42 graduate level semester credit hours in Geography and Public
12 Administration. I have also affended Boise State University, Boise,
l3 Idaho, where I completed 9 undergraduate level semester credits
14 hours in Computer Information Systems.
l5 a. Please briefly describe your professional experience
16 with IDWR.
17 A. In started working for IDWR in 1990 as a Water Resource
18 Agent in the Adjudication Technical Section. I then became a Water
19 Rights Supervisor in the Water Rights Section in 1994 and Water
20 Rights Section Manager in2007. I became Water Allocation Bureau
2l Chief in 2018.
22 a. What are your duties as Water Allocation Bureau
23 Chief?
24 A. My duties include managing the water appropriation and
25 water right adjudication programs of IDWR and supervising IDWR's
26 four regional managers.
Keen, Di I
Idaho Department of Water Resources
I Q. What is the purpose of your testimony?
2 A. The purpose of my testimony is to provide background on
3 IDWR's water right settlement with Avista Corporation ('Avista")
4 and to document that the settlement ensures that the public interest, as
5 it relates to Avista's water use pursuant to its water rights, will not be
6 adversely affected by the merger.
7 a. What code sections govern IDWR's participation in
8 this proceeding?
9 A. Idaho Code S 42-1701'(6) has specific application to this
l0 proceeding and states:
I I Any authorization or order of the Idaho public utilities
12 commission, under the provisions of section 6l-328, Idaho Code,
13 approving the sale, assignment or transfer of hydropower water
14 rights used in the generation of electric power shall be issued
15 only upon such conditions as the director of the department of
16 water resources shall require as necessary to prevent any change17 in use of water under the water rights held for hydropower
18 pu{poses that would cause injury to any water rights existing on
19 the date of the sale, assignment or transfer. Any such conditions
20 shall ensure that the public interest, as it pertains to the use of
2l water under the hydropower water rights, will not be adversely
22 affected. Conditions, if any, imposed by the director shall be
23 subject to review under section 42-l70lfu(4), Idaho Code.
24
25 Idaho Code $ 6l-328 provides, in relevant part:
Keen, Di 2
Idaho Department of Water Resources
1
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5
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The commission shall include in any authorization or order the
conditions required by the director of the department of water
resources under section 42-1701(6), Idaho Code. The commission
may attach to its authorization and order such other terms and
conditions as in its judgment the public convenience and
necessity may require.
8 a. Can you provide an overview of how IDWR became
9 involved in this proceeding?
l0 A. In July of 2018, IDWR was notified of the Joint
11 Application for an Order Authorizing Proposed Transaction ("Joint
12 Application") filed by Avista and Hydro One Limited ("Hydro One")
13 with the Idaho Public Utilities Commission ('?UC"). The Joint
14 Application sought the PUC's approval, pursuant to Idaho Code $ 61-
l5 328, of a planned merger between Avista and Hydro One.
16 Immediately, IDWR was concerned the merger could result in a
17 change in the use of water authorizedby Avista's hydropower water
l8 rights, especially Avista's water rights for power generation at Post
19 Falls Dam. To ensure that the public interest, as it pertains to
20 Avista's use of water under its water rights, would not be adversely
21 affected, IDWR moved to intervene in the PUC proceeding. The
22 PUC subsequently granted IDWR's petition to intervene.
23 While IDWR's petition to intervene was pending before the
24 PUC, IDWR and Avista held settlement discussions regarding
25 Avista's water rights. IDWR and Avista reached an agreement that
26 addressed IDWR's concerns. Importantly, IDWR and Avista reached
27 an agreement regarding subordination of Avista's water rights
28 consistent with the historical operations at Post Falls Dam. IDWR
Keen, Di 3
Idaho Department of Water Resources
I and Avista agreed that Avista's water right claim nos. 95-4518, 95-
2 9115, and 95-9119 shall be recommended in the Coeur d'Alene-
3 Spokane River Basin Adjudication with the following subordination
4 language:
5 The use of water confirmed in this right shall be junior and
6 subordinate to permits, licenses, or decrees for all uses within
7 the State of ldaho with a priority date of, or eorlier than, July
8 25, 2018, diverted upstreamfrom all three points of diversion
9 for this right.
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The use of water confirmed in this right shall be junior and
subordinate to permits, licenses, or decrees for all uses, except
for permits, licenses, or decrees for irrigation storage or power
purposes, within the State of ldaho with a priority date later
than July 25, 2018, diverted upstreamfrom all three points of
diversion for this right.
The use ofwater confirmed in this right shall not be
subordinate to permits, license, or decrees within the State of
Idaho diverted downstreamfrom all three points of diversion
for this right.
23 a. Will the proposed transaction adversely affect the
24 public interest as it applies to the use of water under Avista's
25 water rights?
26 A. No. The agreement ensures that the public interest, as it
27 relates to Avista's water use pursuant to its water rights, will not be
28 adversely affected by the proposed transaction between Avista and
29 Hydro One. The agreement safeguards existing and future water
30 users from changes in historical operations, protects the summer lake
Keen, Di 4
Idaho Department of Water Resources
1 level of Coeur d'Alene Lake, and supports the ongoing operations of
2 Post Falls Dam consistent with prior agreements and the Idaho
3 Department of Environmental Quality 401 Certification.
4 a. Are you sponsoring any exhibits with your testimony?
5 A. Yes. I am sponsoring IDWR Exhibit No. 901, which is a
6 leffer from the Director of IDWR to the PUC and the agreement
7 between IDWR and Avista.
8 a. What is IDWR requesting of the PUC?
9 A. IDWR requests that if the PUC approves the pending
l0 transaction between Avista and Hydro One, the PUC include the
11 agreement as an attachment or exhibit to any such order so that the
12 resolution of this issue is documented in the order.
13 a. Do you have anything further to add at this point?
14 A. No I do not.
Keen, Di 5
Idaho Department of Water Resources
ON BEHALF OF THE IDAHO DEPARTMENT OF WATER RESOURCES
LAWRENCE G. WASDEN
ATTORNEY GENERAL
DARRELL G. EARLY
Deputy Attorney General
Chief, Natural Resources Division
GARRTCK L. BAXTER, TSB #6301
EMMI BLADES,ISB # #8682
Deputy Attorneys General
Idaho Department of Water Resources
P.O. Box 83720
Boise, Idaho 83720-0098
Telephone: [phone]
Facsimile: (208) 287 -6700
qarrick.baxter@idwr. idaho. eov
emm [e-mail]
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE JOINT
APPLICATION OF HYDRO ONE
LIMITED (ACTTNG THROUGH ITS
TNDIRECT SUBSIDIARY, OLYMPUS
EQUITY LLC) AND
AVISTA CORPORATION FOR AN
ORDER AUTHORIZTNG PROPOSED
TRANSACTION
CASE NOS. AVU-E-17-09
AVU-G-17-0s
IDWR EXHIBIT 901 TO SHELLEY
KEEN'S DIRECT TESTIMONY
FOR THE IDAHO DEPARTMENT OF WATER RESOURCES
August 10,2018
Transmitted Via Hand Delivery and by E-mail
Paul Kjellander, President
Kristine Raper, Commissioner
Eric Anderson, Commissioner
C/O Diane Hanian, Commission Secretary
Idaho Public Utilities Commission
472W. Washington St.
Boise, Idaho 83702
Re: Case Nos. AVU-E-17-09 and AVU-G-17-05
Dear Commissioners,
I am writing to update you regarding discussions between the Idaho Department of Water
Resources ("IDWR") and Avista Corporation ("Avista"). Since early 2018, IDWR and Avista have been
discussing Avista's water right claims in the Coeur d'Alene-Spokane River Basin Adjudication
("CSRBA"). The main focus of our discussions has been Avista's hydropower water rights at the three
dams and power plant at Post Falls ("Post Falls dam"). The State of Idaho has a history of disputes over
hydropower water rights. The Swan Falls controversy of the early 1980s involving Idaho Power's
hydropower water rights at Swan Falls dam led to the commencement of the Snake River Basin
Adjudication ("SRBA") in 1987. Litigation in the SRBA related to ldaho Power's Swan Falls water
rights did not conclude until2}l2. A main reason for engaging with Avista early in the CSRBA was to
avoid extended litigation over Avista's hydropower water rights, especially over the issue of
subordination to existing and future water rights.
In July of 2018, IDWR was notified of the Joint Applicationfor an Order Authorizing Proposed
Transaction ("Joint Application") filed with the Idaho Public Utilities Commission (*PUC") by Avista
and Hydro One Limited ("Hydro One"). The Joint Application sought the PUC's approval of a planned
merger between Avista and Hydro One pursuant to ldaho Code $ 6l-328. Immediately, IDWR was
concerned the merger would disrupt the adjudication claim discussions and might impede or prevent
resolution of the issues. Furthermore, IDWR was concemed the merger could result in a change in the
use of water authorized by Avista's hydropower water rights. To ensure that the public interest, as it
pertains to Avista's use of water under its hydropower water rights, would not be adversely affected,
IDWR moved to intervene in the PUC proceeding. The PUC subsequently granted IDWR's petition to
intervene.
While IDWR's petition to intervene was pending before the PUC, IDWR and Avista continued
discussing Avista's hydropower water rights at Post Falls dam. We are pleased to inform you that IDWR
and Avista reached an agreement that addresses IDWR's concems. Specifically, IDWR and Avista have
IDVvR Exhibit No. 901
Case Nos. AVU-E-I 7-09/AVU-G-1 7-05
S. Keen, ldaho Department of Water Resour@s
Schedule 1, Page 1 of 1'l
August 10,2018
Letter to Commissioners
Page2
reached an agreement regarding subordination of Avista's water rights consistent with the historical
operations at Post Falls dam. IDWR and Avista have agreed that Avista's water right claim nos. 95-4518,
95-91 15, and 95-91 19 shall be recommended in the CSRBA with the following subordination language:
The use of water confirmed in this right shall be junior and subordinate to permits, licenses, or
decrees for all uses within the State of Idaho with a priority date of, or earlier than, July 25,2078,
diverted upstream from all three points ofdiversion for this right.
The use of water confirmed in this right shall be junior and subordinate to permits, licenses, or
decrees for all uses, except for permits, licenses, or decrees for irrigation storage or power
purposes, within the State of Idaho with a priority date later than July 25,2078, diverted upstream
from all three points ofdiversion for this right.
The use of water confirmed in this right shall not be subordinate to permits, license, or decrees
within the State of Idaho diverted downstream from all three points of diversion for this right.
The agreement ensures that the public interest, as it relates to Avista's water use pursuant
to its water rights, will not be adversely affected by the proposed transaction between Avista and
Hydro One. The agreement safeguards existing and future water users from changes in historical
operations, helps protect the summer lake level of Coeur d'Alene Lake, and supports the ongoing
operations of Post Falls dam in a manner consistent with prior agreements and the Idaho Department of
Environmental Quality 40 I Certification.
A copy of the agreement between IDWR and Avista is attached to this letter. To ensure
documentation of the agreement before the PUC, IDWR requests that if the PUC approves the pending
transaction between Avista and Hydro One, the PUC include the agreement as an attachment or exhibit to
any such order so that the resolution of this issue is documented in the order.
Sincerely,
Director
Attachment: Agreement Regarding Subordination of Avista's Post Falls Hydroelectric Facility Water
Rights
Cc: All parties
IDWR Exhibit No. 901
Case Nos. AVU-E-1 7-09/AVU-G-1 7-05
S. Keen, ldaho Department of Water Resources
Schedule 1, Page 2 of 1 1
Agreement Regarding Subordination of Avista's Post Falls Hydroelectric Facility Water Rights
Purpose
This Agreemenf reached between Avista Corporation, a Washington corporation ("Avista") and the
ldaho Department of Water Resources ("lDWR") (collectively the "Parties), is intended to capture the
mutual understanding of the Parties regarding subordination of Avista's Post Falls water rights, of record
with IDWR as Avista's claim nos. 95-4518, 95-9115, and 95-9119 (hereafter "Avista's water rights"). This
Agreement guides the Parties' actions in settings including, but not limited to, the Coeur d'Alene-
Spokane River Basin Adjudication ("CSRBA") and the currently pending proceeding before the ldaho
Public Utilities Commission ("PUC") related to the proposed merger of Avista and Hydro One Limited
(acting through its indirect subsidiary Olympus Equity LLC)("Hydro One").
This Agreement is built upon several interests of the Parties:. To protect the summer lake level of Coeur d'Alene Lake;o To ensure the public interest, as it relates to the use of water by Avista, will not be adversely
affected by the proposed transaction between Avista and Hydro One; ando To support the ongoing operations of the three dams and power plant at Post Falls ("Post Falls
dam") in a manner consistent with prior agreements and as referenced by the ldaho
Depaftment of Environmental Quality 401 Certification ("401 Certification") for Post Falls dam
and the Federal Energy Regulatory Commission's License for the Spokane River Project #2545
("FERC license").
Subordination of Avista's water rights
The Parties agree that Avista's water rights are subordinated consistent with the following language, and
the following language will be included in the CSRBA claims for Avista's water rights and will be
incorporated in IDWR's recommendations of Avista's water rights in the CSRBA Director's Report for
Basin 95 ("Director's Repoft"):
The use of water confirmed in this right shall be junior and subordinate to permits,
licenses, or decrees for all uses within the State of ldaho with a priority date of, or
earlier than, July 25, 2018, diverted upstream from allthree points of diversion for this
right.
The use of water confirmed in this right shall be junior and subordinate to permits,
licenses, or decrees for all uses, except for permits, licenses, or decrees for irrigation
storage or power purposes, within the State of ldaho with a priority date later than July
25, 2018, diverted upstream from all three points of diversion for this right.
The use of water confirmed in this right shall not be subordinate to permits, license, or
decrees within the State of ldaho diverted downstream from all three points of
diversion for this right.
Agreed Actions bythe Parties
1. Upon both Parties' signature to this Agreement, IDWR will convey to the PUC a copy of this
Agreement along with a letter stating that if the PUC approves the pending transaction between
Avista and Hydro One, the PUC shall reference this Agreement in any such order. The letter will
lD\ /R Exhibit No. 901
Case Nos. AVU-E-1 7-09/AVU-G-1 7-05
S. Keen, ldaho Department of Water Resources
Schedule 1, Page 3 of 11
1
also explain that with this Agreement, IDWR is satisfied that the proposed merger, with respect
to Avista's water rights, will not be adverse to the public interest;
2. Avista will not object to the terms of subordination described above which will be included in
the Director/s Report for Avista's water rights, and will support those terms in the CSRBA;
3. The Parties agree on dismissa I or withdrawal, as appropriate, of Avista's federal water right
claims in the CSRBA, numbered 95-16663 and 95-16664; and
4. Avista also owns certain water rights for power purposes at Cabinet Gorge darn, of record with
IDWR as water right nos. 95-4565,96-2179,96-2180, and 96-2269. IDWR and Avista agree to
work, in good faith, toward reaching an agreement regarding subordination of Avista's water
rights at Cabinet Gorge dam.
General Terms
1-. Consideration. The Parties acknowledge receiving sufficient consideration for the commitments
contained in this Agreement and waive any argument that they might have in any judicial
proceeding that no consideration exists to support this Agreement or that the consideration
received is not sufficient.
2. Bindine Effect of Asreement. This Agreement is intended to be a final and binding agreement
between IDWR and Avista, jointly and severally, and inures to the benefit of, and is binding
upon, the successors in interest and assigns of each entity. The Parties further agree that this
Agreement is not contingent upon approval of the pending PUC merger case between Avista
and Hydro One.
3. Capacitv to Execute Agreement. The Parties warrant and represent that the person executing
this Agreement on its behalf is empowered to do so and thereby binds it by signing this
Agreement.
4. Waivers. The failure to object to any breach of any term or condition in this Agreement shall
not constitute a waiver, and no failure to object shall be deemed a waiver of any prior or
subsequent breach.
5. Entiretv of Agreement. This Agreement represents the entire and integrated agreement
between the Parties with respect to the subject matter hereof. No promise or inducement has
been offered or made except as herein set forth, and this Agreement is executed by each party
without reliance upon any statement or representation by any other party or its agent.
5. Modification. To the extent this Agreement may be amended or modified, it shall be only by a
written agreement signed by each of the parties to this Agreement.
7. Dispute Resolution. The Parties agree to meet and discuss informally, in good faith, before filing
an action arising from the Agreement.
8. Execution of Agreement in Parts. Due to time constraints, the parties acknowledge that it is not
possible to have all Parties sign the same copy of this Agreement. Therefore, the parties agree
that this Agreement may be executed in any number of counterparts, each of which shall be
deemed an original, but all of which together shall constitute one and the same instrument.
IDWR Exhibit No. 901
Case Nos. AVU-E- 1 7-09/AVU-G-1 7-05
S. Keen, ldaho Department of Water Resources
Schedule 1, Page 4 of 11
2
9. Signatures. ln witness whereof, the parties to this Agreement through their duly authorized
representatives have executed this Agreement and certify that they have read, understood, and
agreed to the terms and conditions of this Agreement as set forth herein.
Agreed to, the 25th of Ju|y,2018.
Avista Corp
Bruce Howard, Sr. Director
Real Estate and Environmental Affairs
IDWR Exhibit No. 901
Case Nos. AVU-E-1 7-09/AVU-G-1 7-05
S. Keen, ldaho Department of Water Resources
Schedule 1, Page 5 of 1 1
For IDWR
Gary Spackman, Director
ldaho Department of Water Resources
3
ACKNOWLEDGEMENTS
'TATE
oF!C,,.shix54tl,
couNry oplc(o-w.{_
On thir?5 day of July, 2018, before me,?.oJ Pc ic(
A notary public of the State of personally appea red tJ.,cr- fi-.*fd
a St. b,re.c+or-of Avista Corporation, known or identified to me to
be the person who executed the foregoing instrument on behalf of Avista Corporation, and he/she
acknowledged to me that he/she executed the same.
NOTARY PUBLIC
Residing at:1_
My commission expires: r ?()
STATE OF
On this _ day of July, 20L8, before ffi€, ,
A notary public of the State of ldaho, personally appeared GARY SPACKMAN, the Director of the ldaho
Department of Water Resources, known or identified to me to be the person who executed the
foregoing instrument on behalf of the ldaho Department of Water Resources, and he acknowledged to
me that he executed the same.
NOTARY PUBLIC
Residing at:
My commission expires
lDVl/R Exhibit No. 901
Case Nos. AVU-E-1 7-09/AVU-G-1 7-05
S. Keen, ldaho Department of Water Resources
Schedule 1, Page 6 of 11
ss.
ss.
4
COUNTY OF
-
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9. Sirnatures. tn witness whereof, the parties to this Agreement through their duly authorized
representatives have executed this Agreement and certify that they have read, understood, and
agreed to the terms and conditions of thls Agreement as set forth herein.
Agreed to, the 25th of Ju|y,2018.
For Avista Corp
Bruce Howard, Sr. Director
Real Estate and Environmental Affairs
Gary Director
ldaho Department of Water Resources
IDVIR Exhibit No. 901
Case Nos. AVU-E-1 7-09/AVU-G-1 7-05
S. Keen, ldaho Departmenl of Water Resources
Schedule 1,Page7 ol 11
For
3
ACKNOWLEDGEMENTS
STATE OF
COUNTY OF
On this _ day of July, 2018, before rn€, ,
A notary public of the State of . personally appeared
a _ of Avista Corporation, known or identified to me to
be the person who executed the foregoing instrument on behalf of Avista Corporation, and he/she
acknowledged to me that he/she executed the same.
NOTARY PUBLIC
Residing at:
My commission expires:
ss.
STATE OF Hn, "''
COUNry OF Srr{r--
)
) ss.
)
On this.Sayof Juiy,2018, before me,Y;*. A r^)t^,l.d -
A notary public of the State of ldaho, personally appeared GARY SPACKMAN, the Director of the ldaho
Department of Water Resources, known or identified to me to be the person who executed the
foregoing instrument on behalf of the ldaho Department of Water Resources, and he acknowledged to
me that he executed the same.
g\|^l A
NOTARY PUBLIC
+Residing at: ?)a.l,a^ }{<t cx*
My commission expires:{:'{lo,\:o.;r..:
a
Or IDA
IDWR Exhibit No. 901
Case Nos. AVU-E-1 7-09/AVU-G-1 7-05
S. Keen, ldaho Department of Water Resources
Schedule 1, Page 8 of 11
*
4
rJ/^,;nQr,.*.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this lOth day of August 2018, I served a true and correct
copy of the foregoing document on the following by the method(s) indicated.
AVISTA CORPORATION
David Meyer X u.s. Mail, postage prepaid
Vice President and Chief Counsel of [-l uana Delivery
Regulatory & Governmental Affairr E lvernrsht Mail
Avista Corporation E ;ffi1i"""P.O.Box3727
Spokane, WA99220-3727
David.meyer@av istacorp.com
Idaho Public Utilities Commissioners
C/O Diane Hanian
Commission Secretary
Idaho Public Utilities Commission
472W. Washington St.
Boise, Idaho 83702
d [e-mail]. qov
Patrick Ehrbar
Director of Rates
State & Federal Regulation
Avista Corporation
patrick.ehrbar@av i stacorp.com
Elisabeth Thomas
Kari Vander Stoep
Dirk Middents
K&L Gates LLP
925 Fourth Avenue, Suite 2900
Seattle, WA 98104-1158
I iz.thomas@kl gates.com
kari. vanderstoep@kl gates.com
d irk.m [e-mail]
James Scarlett
Executive Vice President & Chief
Legal Officer
Hydro One Limited
j scarlett@hydroone. com
IDAHO PUC
E u.s. Mail, postage prepaid
I Uand Delivery
! Overnight Mail
E Facsimile
I Email
fl u.s. Mail, postage prepaid
fl HanO Delivery
fl Overnight Mail
E Facsimile
X Email
HYDRO ONE LIMITEDf] u.s. Mail, postage prepaid
f] gana Delivery
E Overnight Mail
E FacsimileX Email
E u.S. Mail, postage prepaid
E Uana Delivery
! ovemight vail
E Facsimile
X Email
IDWR Exhibit No. 901
Case Nos. AVU-E-1 7-09/AVU-G-1 7-05
S. Keen, ldaho Department of Water Resources
Schedule 1, Page 9 of 1 1
Brandon Karpen
Deputy Attomey General
Idaho Public Utilities Commission
472W. Washington
P.O. Box 83720
Boise, lD 83720-0074
brandon.karpen @puc. idaho. gov
Ronald Williams
Williams Bradbury, PC
P.O. Box 388
Boise, ID 83701
ron@wi I I iam sbradbury.com
Larry A. Crowley, Director
The Energy Strategies Institute, Inc.
5549 S. Cliffsedge Ave.
Boise,ID 83716
[e-mail]
Dean J. Miller
deanj m i I [e-mail]
Dr. Don Reading
6070 Hill Road
Boise, ID 83703
dread in e@m indsprin s.com
[e-mail]
[e-mail]
i ohn..i acobs@c learwaterpaper.com
dav [e-mail]
nathan. sm [e-mail]
COMMISSION STAFF
X u.s. Mail, postage prepaid
E Uana Delivery
! Ovemight Mail
E FacsimileI Email
IDAHO FOREST GROUP, LLC
X U.S. Mail, postage prepaid
E Uana Delivery
! Ovemight Mail
E Facsimile
X Email
X U.S. Mail, postage prepaid
! Uana Delivery
! Ovemight Mail
E Facsimile
X Email
E U.S. Mail, postage prepaid
E Uana Delivery
E Ovemight Mail
E Facsimile
X Email
X u.S. Mail, postage prepaid
E ganA Delivery
E Ovemight Mail
! Facsimile
X Email
X Email
X Email
X Email
X Email
X Email
CLEARWATER PAPER CORPORATION
Peter J. Richardson X U.S. Mail, postage prepaid
Richardson Adams, PLLC E uano Delivery
515 N.27ft St.
=
OvemightMail
Boise, tD 83702 H ;il:i|"""
oeter@richardsonadam s.com
ID\A/R Exhibit No. 901
Case Nos. AVU-E-1 7-09/AVU-G-1 7-05
S. Keen, ldaho Department of Water Resources
Schedule 1, Page 10 of 11
COMMUNITY ACTION PARTNERSHIP ASSOCIATION OF IDAHO
Brady M. Purdy x U.S. Mail, postage prepaid
Attorney at Law E uanA Delivery
2019 N. 17ft St. ! Ovemight Mail
Boise, rD 83702 H ;il:|i""'[e-mail]
Benjamin J. Otto
Idaho Conservation League
710 N. 6th St.
Boise, lD 83702
botto@idahocon servation.ore
Danielle Franco-Malone
Schwerin Campbell Barnard
Iglitzin & Lavitt LLP
l8 West Mercer Street, Suite 400
Seaffle, WA 98119-3971
[e-mail]
Norman M. Semanko
Parsons Behle & Latimer
800 West Main Street, Ste. 1300
Boise, Idaho 83702
[e-mail]
IDAHO CONSERVATION LEAGUE
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WASHINGTON AND NORTHERN IDAHO DISTRICT COUNCIL OF LABORERSxtrtrtrx
L. Baxter
IDWR Exhibit No. 901
Case Nos. AVU-E-1 7-09/AVU-G-1 7-05
S. Keen, ldaho Department of Water Resources
Schedule 1, Page 11 ot 1'l
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 6th day ofNovember 2018, I served a true and correct
copy of the foregoing document on the following by the method(s) indicated.
AVISTA CORPORATION
David Meyer X u.s. Mail, postage prepaid
vice president and chief counsel of ! uana Delivery
Regulatory & Govemmental Affairs E ovemight Mail
Avista corporation E iil:li''-P.O.Box3727
Spokane, WA99220-3727
Dav id.m e)rer@av istacorp.com
Idaho Public Utilities Commissioners
C/O Diane Hanian
Commission Secretary
Idaho Public Utilities Commission
472 W. Washington St.
Boise, Idaho 83702
diane.ho [e-mail]. gov
Patrick Ehrbar
Director of Rates
State & Federal Regulation
Avista Corporation
patrick.ehrbar@av i stacorp.com
Elisabeth Thomas
Kari Vander Stoep
Dirk Middents
K&L Gates LLP
925 Fourth Avenue, Suite 2900
Seattle, WA 98104-l158
I [e-mail]
kari.vanderstoep@kl gates.com
d irk. m iddents@-kl qates. com
James Scarlett
Executive Vice President & Chief
Legal Officer
Hydro One Limited
i [e-mail]
IDAHO PUC
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HYDRO ONE LIMITED
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Brandon Karpen
Deputy Attomey General
Idaho Public Utilities Commission
472W. Washington
P.O. Box 83720
Boise, lD 83720-0074
brandon.karpen@puc. idaho. gov
Ronald Williams
Williams Bradbury, PC
P.O. Box 388
Boise, ID 83701
ron@wi I I iam sbradbury.com
Larry A. Crowley, Director
The Energy Strategies Institute, lnc
5549 S; Cliffsedge Ave.
Boise, ID 83716
[e-mail]
Dean J. Miller
deanjm il [e-mail]
Dr. Don Reading
6070 Hill Road
Boise, lD 83703
dread in s@m indsprin g.com
caro l.hauen@c learwaterDaper.com
[e-mail]
i ohn j acobs@c learwaterpaper.com
dav id.wren@c learwaterpaper.com
nathan. sm [e-mail]
COMMISSION STAFF
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II}AHO FOREST GROUP, LLC
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CLEARWATER PAPER CORPORATION
Peter J. Richardson X u.s. Mail, postage prepaid
Richardson Adams, PLLC E uana Delivery
515 N. 27rh St.
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Boise, ID 83702 H ;il:|i""'peter@richardsonadam s. com
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COMMUNITY ACTION PARTNERSHIP ASSOCIATION OF IDAHO
Brady M. Purdy X u.s. Mail, postage prepaid
Attorney at Law E uana Delivery
2019 N. lTth St. E Ovemight Mail
Boise, tD 83702 H ;ffi1i"""
[e-mail]
Benjamin J. Otto
Idaho Conservation League
710 N. 6th St.
Boise, ID 83702
botto@ idahoconservation.orq
Norman M. Semanko
Parsons Behle & Latimer
800 West Main Street, Ste. 1300
Boise, Idaho 83702
[e-mail]
IDAHO CONSERVATION LEAGUE
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AVISTA CUSTOMER GROUP
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xtrtrtrx
WASHINGTON AND NORTHERN IDAHO DISTRICT COUNCIL OF LABORERS
Danielle Franco-Malone X U.S. Mail, postage prepaid
Schwerin Campbell Barnard f] Hana Delivery
Iglitzin t l-avitt lr.p f] ov^emight Mail
18 West Mercer Street, Suite 400 H ;ffili"""
Seattle, WA 98119-3971
[e-mail]
L. Baxter