SUBMITTED VIA E-TARIFF FILING. August 4, 2017

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1 Millennium Tower 719 Second Avenue, Suite 1150 Seattle, WA (206) Phone (206) Fax SUBMITTED VIA E-TARIFF FILING August 4, 2017 The Honorable Kimberly D. Bose Secretary Federal Energy Regulatory Commission 888 First Street, NE Washington, DC Re: Idaho Power Company, Docket No. ER Revisions to the Amendments to the Idaho Power Company Open Access Transmission Tariff to Facilitate Entry into the Energy Imbalance Market Dear Secretary Bose: Pursuant to Section 205 of the Federal Power Act ( FPA ), 16 U.S.C. 824d (2012), and Part 35 of the Federal Energy Regulatory Commission s ( Commission or FERC ) regulations, 18 C.F.R. pt. 35 (2017), in response to comments submitted by the Bonneville Power Administration ( Bonneville ), Idaho Power Company ( Idaho Power ) hereby submits for filing a revision to Section of Attachment O of its Open Access Transmission Tariff ( OATT ) and commits to providing the requested clarification in its transmission business practices. I. BACKGROUND On July 11, 2017, Idaho Power submitted revisions to its OATT to facilitate its entry into the Energy Imbalance Market ( EIM ) of the California Independent System Operator ( CAISO ). As described in that filing, Idaho Power held a stakeholder process, which included two meetings and three opportunities for written comments, in order to ensure its transmission customers were informed and aware of proposed tariff changes necessary for Idaho Power to join the EIM. The Commission established a comment deadline of August 2, On July 28, 2017, Bonneville contacted Idaho Power about two comments concerning proposed tariff changes that Bonneville did not raise during the stakeholder process. The two entities held a call on August 1, 2017 to determine whether they could agree upon an approach to resolve Bonneville s concerns without unduly delaying Idaho Power s tariff changes. Bonneville requested clarification that a load could be the subject of a Pseudo-Tie within the definition of Dynamic Transfer in Section 1.21 of the OATT. The proposed definition of Dynamic Transfer in Section 1.21 of the OATT indicates that dynamic transfers apply to the movement of all or a portion of the real energy services associated with a generator or load out

2 Ms. Kimberly D. Bose August 4, 2017 of one BAA into another. Idaho Power acknowledges Bonneville s observation that the subreference to a Pseudo-Tie does not refer to a load even though load is referenced in the definition of a Dynamic Transfer. Idaho Power will include a clarification in its transmission business practices that a load can be the subject of a Pseudo-Tie. Additionally, Bonneville had concerns with Section of Attachment O of the Idaho Power OATT, which sub-allocates to transmission customers four charges that Idaho Power could receive from CAISO in its role as the Market Operator. Those changes are: Shortfall Receipt Distribution, Shortfall Allocation Reversal, Shortfall Allocation, and Default Loss Allocation. Bonneville requested these charges be allocated to Idaho Power as the EIM Entity. Idaho Power agreed to make this change. On August 2, 2017, Bonneville submitted comments to this effect. II. DESCRIPTION OF TARIFF FILING Section of Attachment O sub-allocates four charges the Idaho Power EIM Entity could receive from CAISO as the Market Operator to transmission customers based upon Metered Demand. These changes are: Shortfall Receipt Distribution, Shortfall Allocation Reversal, Shortfall Allocation, and Default Loss Allocation. The amendment submitted with this filing allocates the four charges to the Idaho Power EIM Entity. No other changes are proposed. III. EFFECTIVE DATE AND REQUEST FOR WAIVERS Idaho Power is not proposing a change to its requested January 25, 2018 effective date for Section of Attachment O. As discussed in Idaho Power s July 11, 2017 filing letter, the proposed EIM tariff changes were submitted in multiple tariff records. Specifically, the current tariff record containing Section of Attachment O is: Attachment O Section 8, Settlements and Billing, Idaho Power s etariff software cannot accommodate multiple effective dates within a tariff record. As a result, where a tariff record contains sections with different requested effective dates, the effective date labeled within etariff metadata is the earlier of the two dates. The Section 8 tariff record that is the subject of this filing contains two effective dates: January 25, 2018 or seven days prior to the start of parallel operations, and April 4, 2018 or the implementation date of IPC s participation in the EIM, whichever is later. Accordingly, the etariff record was filed with a January 25, 2018 effective date. Since the proposed effective date is later than 61 days from the date of this filing, Idaho Power is not proposing a revision to the originally requested effective date. Additionally, because the requested effective date is more than 120 days after the date this filing, Idaho Power seeks waiver of section 35.3(a)(1) of the Commission s regulations, 18 C.F.R. 35.3(a)(1). Good cause exists for granting this waiver because it will permit Idaho Power s revised tariff record to be in place in a timeframe necessary to support final design, testing, and startup, thereby providing all parties with necessary regulatory and operational Page 2

3 Ms. Kimberly D. Bose August 4, 2017 certainty. 1 Additionally, maintaining the originally requested effective dates will facilitate an orderly implementation of EIM, and the proposed changes do not increase costs to transmission customers. To the extent that any filing requirement in Part 35 of the Commission s regulations is not satisfied by this filing and the materials enclosed herewith, Idaho Power respectfully requests waiver of such requirements. IV. COMMUNICATIONS All communications, correspondence, and documents related to this proceeding should be directed to the following persons: Malcolm McLellan* Van Ness Feldman LLP Millennium Tower 719 Second Avenue Suite 1150 Seattle, WA Tel: (206) mcm@vnf.com Julia Hilton* Idaho Power Company 1221 West Idaho Street Boise, Idaho Tel: (208) jhilton@idahopower.com * Designated for service of process V. CONTENTS OF FILING This filing includes the following Attachments in addition to this transmittal: Attachment A: Attachment B: Clean Tariff Sheets of Attachment O Section 8, Settlements and Billing Redlined Tariff Sheets of Attachment O Section 8, Settlements and Billing 1 E.g., PacifiCorp EIM Order at P 82; Midcontinent Indep. Sys. Operator, Inc., 145 FERC 61,208 at P 13 (2013). Page 3

4 Ms. Kimberly D. Bose August 4, 2017 VI. CONCLUSION For the reasons stated above, Idaho Power asks the Commission accept the proposed revisions to Section of Attachment with the effective date as discussed above. Respectfully submitted, Attachments /s/ Malcolm McLellan Malcolm McLellan Van Ness Feldman LLP Millennium Tower 719 Second Avenue Suite 1150 Seattle, WA Tel: (206) Attorneys for Idaho Power Company Page 4

5 Attachment A Clean Tariff Sheets of Amended OATT Sections Attachment A Clean Tariff Sheets of Amended OATT Sections

6 FERC Electric Tariff Page 1 of 5 8. EIM Settlements and Billing The IPC EIM BP shall include information on the specific charge codes applicable to EIM settlement. 8.1 Instructed Imbalance Energy (IIE) The IPC EIM Entity shall settle as IIE imbalances that result from (1) operational adjustments of a Transmission Customer s affected base generation schedule or Interchange, which includes changes by a Transmission Customer after T-57, (2) resource imbalances created by Manual Dispatch or an EIM Available Balancing Capacity dispatch, (3) an adjustment to resource imbalances created by adjustments to resource forecasts, or (4) other reasons IIE is calculated by the MO pursuant to Section 11.5 of the MO Tariff and using the RTD or FMM price at the applicable PNode. Any allocations to the IPC EIM Entity pursuant to Section (b)(1) and (2) of the MO Tariff for IIE that is not otherwise recovered under Schedule 10 of this Tariff shall be settled directly with each Transmission Customer according to this Section Uninstructed Imbalance Energy (UIE) Any charges or payments to the IPC EIM Entity pursuant to Section 29.11(b)(3)(B) and (C) of the MO Tariff for UIE not otherwise recovered under Schedule 4or Schedule 10 shall not be sub-allocated to Transmission Customers. 8.3 Unaccounted for Energy (UFE) Any charges to the IPC EIM Entity pursuant to Section 29.11(c) of the MO Tariff for UFE shall not be sub-allocated to Transmission Customers. 8.4 Charges for Under-Scheduling or Over-Scheduling Load Under-Scheduling Load Any charges to the IPC EIM Entity pursuant to Section (d)(1) of the MO Tariff for underscheduling load shall be assigned to the Transmission Customers subject to Schedule 4 based on each Transmission Customer s respective under-scheduling imbalance ratio share, which is the ratio of the Transmission Customer s under-scheduled load imbalance amount relative to all other Transmission Customers under-scheduled load imbalance amounts who have under-scheduled load for the Operating Hour, expressed as a percentage Over-Scheduling Load Any charges to the IPC EIM Entity pursuant to Section (d)(2) of the MO Tariff for overscheduling load shall be assigned to the Transmission Customers subject to Schedule 4 based on each Transmission Customer s respective over-scheduling imbalance ratio share, which is the ratio of the Transmission Customer s over-scheduled load imbalance amount

7 FERC Electric Tariff Page 2 of 5 relative to all other Transmission Customers over-scheduled load imbalance amounts who have over-scheduled load for the Operating Hour, expressed as a percentage Distribution of Under-Scheduling or Over-Scheduling Proceeds Any payment to the IPC EIM Entity pursuant to Section (d)(3) of the MO Tariff shall be distributed to Transmission Customers that were not subject to underscheduling or overscheduling charges during the Trading Day on the basis of Metered Demand and in accordance with the procedures outlined in the IPC EIM BP. 8.5 EIM Uplifts EIM BAA Real-Time Market Neutrality (Real-Time Imbalance Energy Offset - BAA) Any charges to the IPC EIM Entity pursuant to Section (e)(3) of the MO Tariff for EIM BAA real-time market neutrality shall be sub-allocated to Transmission Customers on the basis of EIM Entity BAA Real-Time Congestion Offset Any charges to the IPC EIM Entity pursuant to Section (e)(2) of the MO Tariff for the EIM real-time congestion offset shall be allocated to Transmission Customers on the basis of EIM Entity Real-Time Marginal Cost of Losses Offset Any charges to the IPC EIM Entity pursuant to Section (e)(4) of the MO Tariff for realtime marginal cost of losses offset shall be sub-allocated to Transmission Customers on the basis of EIM Neutrality Settlement Any charges to the IPC EIM Entity pursuant to Section (e)(5) of the MO Tariff for EIM neutrality settlement shall be sub-allocated as follows: Description Allocation Neutrality Adjustment (monthly and daily) Rounding Adjustment (monthly and daily) Real-Time Bid Cost Recovery Any charges to the IPC EIM Entity pursuant to Section 29.11(f) of the MO Tariff for EIM real-time bid cost recovery shall be sub-allocated to Transmission Customers on the basis of.

8 FERC Electric Tariff Page 3 of Flexible Ramping Product Any charges or payments to the IPC EIM Entity pursuant to Section 29.11(p) of the MO Tariff for the Flexible Ramping Product shall be sub-allocated to Transmission Customers on the basis as follows: Description Flexible Ramping Forecasted Movement Resource Settlement Flexible Ramping Forecasted Movement Demand Allocation Daily Flexible Ramping Uncertainty Award (in both upward and downward directions) Monthly Flexible Ramping Uncertainty Award (in both upward and downward directions) Any other Flexible Ramping Product charges or payments Allocation Inaccurate or Late Actual Settlement Quality Meter Data Penalty To the extent the IPC EIM Entity incurs a penalty for inaccurate or late actual settlement quality meter data, pursuant to Section of the MO Tariff, the IPC EIM Entity shall directly assign the penalty to the offending Transmission Customer Other EIM Settlement Provisions Any charges to the IPC EIM Entity pursuant to the MO Tariff for the EIM settlement shall be sub-allocated. The charges shown in the following table shall be sub-allocated as follows: Description Allocation Invoice Deviation (distribution and IPC EIM Entity allocation) Generator Interconnection Process IPC EIM Entity Forfeited Deposit Allocation Default Invoice Interest Payment IPC EIM Entity Default Invoice Interest Charge IPC EIM Entity Invoice Late Payment Penalty IPC EIM Entity Financial Security Posting (Collateral) IPC EIM Entity Late Payment Penalty Shortfall Receipt Distribution IPC EIM Entity Shortfall Allocation Reversal IPC EIM Entity Shortfall Allocation IPC EIM Entity Default Loss Allocation IPC EIM Entity

9 FERC Electric Tariff Page 4 of MO Tax Liabilities Any charges to the IPC EIM Entity pursuant to Section 29.22(a) of the MO Tariff for MO tax liability as a result of the EIM shall be sub-allocated to those Transmission Customers triggering the tax liability. 8.7 EIM Transmission Service Charges There shall be no incremental transmission charge assessed for transmission use related to the EIM. Participating Resources and Balancing Authority Area Resources will not incur unreserved use charges solely as a result of EIM Dispatch Instruction. Schedule 11 of this Tariff shall apply to any amount of actual metered generation in an Operating Hour, if any, which is in excess of the sum of both: (1) the greatest positive Dispatch Operating Point or Manual Dispatch of the IPC EIM Participating Resource received during the Operating Hour, and (2) the Transmission Customer s Reserved Capacity. Any ancillary service charges that are applicable to Schedule 11 charges shall apply and shall include Schedules 1 and 1A of this Tariff. 8.8 Variable Energy Resource Forecast Charge Any costs incurred by the IPC EIM Entity related to the preparation and submission of resource Forecast Data for a Transmission Customer with a Non-Participating Resource electing either method (1) or (2), as set forth in Section of this Attachment O, shall be allocated to the Transmission Customer with a Non-Participating Resource electing to use either such method. For a Transmission Customer with a Non-Participating Resource electing method (3), as set forth in Section of this Attachment O, any charges to the IPC EIM Entity pursuant to Section (j)(1) of the MO Tariff for Variable Energy Resource forecast charges shall be suballocated to the Transmission Customer with a Non-Participating Resource requesting such forecast. 8.9 EIM Payment Calendar Pursuant to Section 29.11(l) of the MO Tariff, the IPC EIM Entity shall be subject to the MO s payment calendar for issuing settlement statements, exchanging invoice funds, submitting meter data, and submitting settlement disputes to the MO. The IPC EIM Entity shall follow Section 7 of this Tariff for issuing invoices regarding the EIM EIM Residual Balancing Account To the extent that MO EIM-related charges or payments to the IPC EIM Entity are not captured elsewhere in Attachment H-1, Schedules 1, 1A, 4, and 10 of this Tariff, or this Section 8, those charges or payments shall be placed in a balancing account, with interest accruing at

10 FERC Electric Tariff Page 5 of 5 the rate established in 18 C.F.R (a)(2)(iii), until IPC makes a filing with the Commission pursuant to Section 205 of the Federal Power Act proposing an allocation methodology Market Validation and Price Correction If the MO modifies the IPC EIM Entity settlement statement in accordance with the MO s market validation and price correction procedures in the MO Tariff, the IPC EIM Entity reserves the right to make corresponding or similar changes to the charges and payments suballocated under this Attachment O Allocation of Operating Reserves Payments Any payments to the IPC EIM Entity pursuant to Section (n)(1) of the MO Tariff for operating reserve obligations shall be sub-allocated to Transmission Customers with IPC EIM Participating Resources in the IPC BAA for Operating Hours during which EIM Transfers from the IPC BAA to another BAA occurred. Payments shall be sub-allocated on a ratio-share basis, defined as the proportion of the volume of Operating Reserves provided by an IPC EIM Participating Resource in the IPC BAA dispatched during the Operating Hour compared to the total volume of Operating Reserves provided by all IPC EIM Participating Resources dispatched in the IPC BAA for the Operating Hour Charges Any charges to the IPC EIM Entity pursuant to Section (n)(2) of the MO Tariff for operating reserve obligations shall not be sub-allocated to Transmission Customers.

11 Attachment B Redlined Tariff Sheets of Amended OATT Sections Attachment B Redline Tariff Sheets of Amended OATT Sections

12 FERC Electric Tariff Page 1 of 5 8. EIM Settlements and Billing The IPC EIM BP shall include information on the specific charge codes applicable to EIM settlement. 8.1 Instructed Imbalance Energy (IIE) The IPC EIM Entity shall settle as IIE imbalances that result from (1) operational adjustments of a Transmission Customer s affected base generation schedule or Interchange, which includes changes by a Transmission Customer after T-57, (2) resource imbalances created by Manual Dispatch or an EIM Available Balancing Capacity dispatch, (3) an adjustment to resource imbalances created by adjustments to resource forecasts, or (4) other reasons IIE is calculated by the MO pursuant to Section 11.5 of the MO Tariff and using the RTD or FMM price at the applicable PNode. Any allocations to the IPC EIM Entity pursuant to Section (b)(1) and (2) of the MO Tariff for IIE that is not otherwise recovered under Schedule 10 of this Tariff shall be settled directly with each Transmission Customer according to this Section Uninstructed Imbalance Energy (UIE) Any charges or payments to the IPC EIM Entity pursuant to Section 29.11(b)(3)(B) and (C) of the MO Tariff for UIE not otherwise recovered under Schedule 4or Schedule 10 shall not be sub-allocated to Transmission Customers. 8.3 Unaccounted for Energy (UFE) Any charges to the IPC EIM Entity pursuant to Section 29.11(c) of the MO Tariff for UFE shall not be sub-allocated to Transmission Customers. 8.4 Charges for Under-Scheduling or Over-Scheduling Load Under-Scheduling Load Any charges to the IPC EIM Entity pursuant to Section (d)(1) of the MO Tariff for underscheduling load shall be assigned to the Transmission Customers subject to Schedule 4 based on each Transmission Customer s respective under-scheduling imbalance ratio share, which is the ratio of the Transmission Customer s under-scheduled load imbalance amount relative to all other Transmission Customers under-scheduled load imbalance amounts who have under-scheduled load for the Operating Hour, expressed as a percentage Over-Scheduling Load Any charges to the IPC EIM Entity pursuant to Section (d)(2) of the MO Tariff for overscheduling load shall be assigned to the Transmission Customers subject to Schedule 4 based on each Transmission Customer s respective over-scheduling imbalance ratio share, which is the ratio of the Transmission Customer s over-scheduled load imbalance amount

13 FERC Electric Tariff Page 2 of 5 relative to all other Transmission Customers over-scheduled load imbalance amounts who have over-scheduled load for the Operating Hour, expressed as a percentage Distribution of Under-Scheduling or Over-Scheduling Proceeds Any payment to the IPC EIM Entity pursuant to Section (d)(3) of the MO Tariff shall be distributed to Transmission Customers that were not subject to underscheduling or overscheduling charges during the Trading Day on the basis of Metered Demand and in accordance with the procedures outlined in the IPC EIM BP. 8.5 EIM Uplifts EIM BAA Real-Time Market Neutrality (Real-Time Imbalance Energy Offset - BAA) Any charges to the IPC EIM Entity pursuant to Section (e)(3) of the MO Tariff for EIM BAA real-time market neutrality shall be sub-allocated to Transmission Customers on the basis of EIM Entity BAA Real-Time Congestion Offset Any charges to the IPC EIM Entity pursuant to Section (e)(2) of the MO Tariff for the EIM real-time congestion offset shall be allocated to Transmission Customers on the basis of EIM Entity Real-Time Marginal Cost of Losses Offset Any charges to the IPC EIM Entity pursuant to Section (e)(4) of the MO Tariff for realtime marginal cost of losses offset shall be sub-allocated to Transmission Customers on the basis of EIM Neutrality Settlement Any charges to the IPC EIM Entity pursuant to Section (e)(5) of the MO Tariff for EIM neutrality settlement shall be sub-allocated as follows: Description Allocation Neutrality Adjustment (monthly and daily) Rounding Adjustment (monthly and daily) Real-Time Bid Cost Recovery Any charges to the IPC EIM Entity pursuant to Section 29.11(f) of the MO Tariff for EIM real-time bid cost recovery shall be sub-allocated to Transmission Customers on the basis of.

14 FERC Electric Tariff Page 3 of Flexible Ramping Product Any charges or payments to the IPC EIM Entity pursuant to Section 29.11(p) of the MO Tariff for the Flexible Ramping Product shall be sub-allocated to Transmission Customers on the basis as follows: Description Flexible Ramping Forecasted Movement Resource Settlement Flexible Ramping Forecasted Movement Demand Allocation Daily Flexible Ramping Uncertainty Award (in both upward and downward directions) Monthly Flexible Ramping Uncertainty Award (in both upward and downward directions) Any other Flexible Ramping Product charges or payments Allocation Inaccurate or Late Actual Settlement Quality Meter Data Penalty To the extent the IPC EIM Entity incurs a penalty for inaccurate or late actual settlement quality meter data, pursuant to Section of the MO Tariff, the IPC EIM Entity shall directly assign the penalty to the offending Transmission Customer Other EIM Settlement Provisions Any charges to the IPC EIM Entity pursuant to the MO Tariff for the EIM settlement shall be sub-allocated. The charges shown in the following table shall be sub-allocated as follows: Description Allocation Invoice Deviation (distribution and IPC EIM Entity allocation) Generator Interconnection Process IPC EIM Entity Forfeited Deposit Allocation Default Invoice Interest Payment IPC EIM Entity Default Invoice Interest Charge IPC EIM Entity Invoice Late Payment Penalty IPC EIM Entity Financial Security Posting (Collateral) IPC EIM Entity Late Payment Penalty Shortfall Receipt Distribution IPC EIM EntityMetered Demand Shortfall Allocation Reversal IPC EIM EntityMetered Demand Shortfall Allocation IPC EIM EntityMetered Demand Default Loss Allocation IPC EIM EntityMetered Demand

15 FERC Electric Tariff Page 4 of MO Tax Liabilities Any charges to the IPC EIM Entity pursuant to Section 29.22(a) of the MO Tariff for MO tax liability as a result of the EIM shall be sub-allocated to those Transmission Customers triggering the tax liability. 8.7 EIM Transmission Service Charges There shall be no incremental transmission charge assessed for transmission use related to the EIM. Participating Resources and Balancing Authority Area Resources will not incur unreserved use charges solely as a result of EIM Dispatch Instruction. Schedule 11 of this Tariff shall apply to any amount of actual metered generation in an Operating Hour, if any, which is in excess of the sum of both: (1) the greatest positive Dispatch Operating Point or Manual Dispatch of the IPC EIM Participating Resource received during the Operating Hour, and (2) the Transmission Customer s Reserved Capacity. Any ancillary service charges that are applicable to Schedule 11 charges shall apply and shall include Schedules 1 and 1A of this Tariff. 8.8 Variable Energy Resource Forecast Charge Any costs incurred by the IPC EIM Entity related to the preparation and submission of resource Forecast Data for a Transmission Customer with a Non-Participating Resource electing either method (1) or (2), as set forth in Section of this Attachment O, shall be allocated to the Transmission Customer with a Non-Participating Resource electing to use either such method. For a Transmission Customer with a Non-Participating Resource electing method (3), as set forth in Section of this Attachment O, any charges to the IPC EIM Entity pursuant to Section (j)(1) of the MO Tariff for Variable Energy Resource forecast charges shall be suballocated to the Transmission Customer with a Non-Participating Resource requesting such forecast. 8.9 EIM Payment Calendar Pursuant to Section 29.11(l) of the MO Tariff, the IPC EIM Entity shall be subject to the MO s payment calendar for issuing settlement statements, exchanging invoice funds, submitting meter data, and submitting settlement disputes to the MO. The IPC EIM Entity shall follow Section 7 of this Tariff for issuing invoices regarding the EIM EIM Residual Balancing Account To the extent that MO EIM-related charges or payments to the IPC EIM Entity are not captured elsewhere in Attachment H-1, Schedules 1, 1A, 4, and 10 of this Tariff, or this Section 8, those charges or payments shall be placed in a balancing account, with interest accruing at

16 FERC Electric Tariff Page 5 of 5 the rate established in 18 C.F.R (a)(2)(iii), until IPC makes a filing with the Commission pursuant to Section 205 of the Federal Power Act proposing an allocation methodology Market Validation and Price Correction If the MO modifies the IPC EIM Entity settlement statement in accordance with the MO s market validation and price correction procedures in the MO Tariff, the IPC EIM Entity reserves the right to make corresponding or similar changes to the charges and payments suballocated under this Attachment O Allocation of Operating Reserves Payments Any payments to the IPC EIM Entity pursuant to Section (n)(1) of the MO Tariff for operating reserve obligations shall be sub-allocated to Transmission Customers with IPC EIM Participating Resources in the IPC BAA for Operating Hours during which EIM Transfers from the IPC BAA to another BAA occurred. Payments shall be sub-allocated on a ratio-share basis, defined as the proportion of the volume of Operating Reserves provided by an IPC EIM Participating Resource in the IPC BAA dispatched during the Operating Hour compared to the total volume of Operating Reserves provided by all IPC EIM Participating Resources dispatched in the IPC BAA for the Operating Hour Charges Any charges to the IPC EIM Entity pursuant to Section (n)(2) of the MO Tariff for operating reserve obligations shall not be sub-allocated to Transmission Customers.

17 CERTIFICATE OF SERVICE Pursuant to Rule 2010 of the Rules of Practice and Procedure of the Federal Energy Regulatory Commission, I hereby certify that I have this day caused the foregoing document to be served upon each person designated on the official service list compiled by the Secretary in this proceeding. Dated this 4th day of August, /s/ Christa Bearry Christa Bearry Idaho Power Company 1221 West Idaho Street Boise, Idaho Tel: (208) cbearry@idahopower.com

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