20050315Final Order No 29732.pdf

Office of the Secretary
Service Date
March 15 2005
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
RESORT WATER CO. INC. FOR ISSUANCE
OF A CERTIFICATE OF PUBLIC
CO NVENIEN CE AND NECESSITY, FOR
APPROVAL OF RATES AND CHARGES, AND
FOR APPROVAL OF RULES AND
REGULATATIONS GOVERNING THE
RENDERING OF WATER SERVICE
INTRODUCTION
CASE NO. RES-O4-
ORDER NO. 29732
On August 13, 2004, Resort Water filed an Application requesting issuance of a
Certificate of Public Convenience and Necessity. The Company also requested approval of an
increase in existing rates and charges for water service and approval of the Company s Rules and
Regulations governing the rendering of water service. On September 1 , 2004, the Commission
issued a Notice of Application and Order No. 29575 which suspended the Company s proposed
schedule of rates and charges. In Order No. 29690, the Commission extended the suspension
period for an additional 30 days, to March 15, 2005 and ordered the use of Modified Procedure
with a public workshop on February 8 , 2004. Comments were filed by the Staff and
approximately 30 customers.
Staff has reviewed the Company s filing, visited the Company s offices, reviewed its
financial position, toured the service area, and conducted a public workshop. Staff filed
extensive comments on February 17, 2005. The Company, in its reply comments filed on
February 25 , 2005, stated that although it believes the rates proposed in its Application are
supported by sound rate making theory and practice, that it would acquiesce to an Order
consistent with the Staff s recommendations. Thus, the Company agreed to the Staff s proposed
adjustments, return on equity, and rate design.
In this Order the Commission issues a Certificate of Public Convenience and
Necessity to Resort Water. Additionally, this Order establishes and approves rates, charges, and
customer rules and regulations governing the rendering of water service by the Company.
ORDER NO. 29732
THE INITIAL APPLICATION
According to the Company s Application, Resort Water provides domestic water
service to customers in Bonner County, Idaho, primarily located within the Schweitzer Mountain
Resort Planned Unit Development. Resort Water currently serves 287 residential units, or
equivalent residential units (ERU), which include 11 condominium associations billed as a single
customer, as well as six commercial customers representing approximately 91 ERU's. Resort
Water s current water rate is a monthly flat rate of $33.00 per ERU.
Resort Water originally requested an increase in the monthly flat rate from $33.00 per
ERU to $61.96 per ERU, an increase of 88%. The Application states that the Company seeks the
additional revenues to recover increased expenses and costs associated with plant additions, and
to produce a fair rate of return. Staff proposed and the Company accepted that the flat monthly
rate be increased to $44., an increase of 36%. Resort Water is owned by Harbor Mountain
Utility Company LLC, who in turn is part of a larger family of companies known as Harbor
Mountain LLC. In 1999 Schweitzer Mountain Resort, including the domestic water system
Resort Water, was purchased from the Trustee in a federal bankruptcy proceeding.
CUSTOMER COMMENTS
The Commission received approximately 30 written comments from Resort Water
customers. Twenty customers attended the public workshop held on February 8, 2005. Staff
answered questions for more than two hours.
Several Resort Water customers mentioned they do not understand the reason for
such a substantial increase in water rates.Others indicated that some increase in rates is
understandable; however, they questioned what system improvements have been made to justify
the requested rate increases. They fear customers are being asked to pay for future expansion of
property owned by Harbor Mountain or to make up for poor management decisions in the past.
Several customers were concerned whether or not the White Pine Lodge, a large condominium
building owned by one of Resort Water s affiliate companies, paid a connection fee. One
customer preferred metered rates rather than a flat monthly rate. Another customer requested
that the billing be on a yearly basis, and another requested quarterly, instead of monthly billing
because their respective condominium associations bill on a yearly and quarterly basis. There
was concern expressed that the calculation ofERU's was flawed in that the usage levels were too
high, and that snowmaking was under-allocated.
ORDER NO. 29732
FINDINGS OF FACT
I. CERTIFICATE OF CONVENIENCE AND NECESSITY
We find it appropriate and necessary to issue a Certificate of Public Convenience and
Necessity to Resort Water Company, Inc. The Company has offered water service to the general
public since late 1999. It is operating a water system on Schweitzer Mountain that has been in
existence since sometime in the late 1960's or early 1970's. Resort Water filed a complete
system map and a legal description of its requested and anticipated overall service area, and filed
the appropriate financial and cost-of-service data.The Company identified adjacent water
companies/cooperatives. It appears to provide service in harmony with the adjacent water
providers.Staff continues to investigate the status of the adjacent water providers.The
Company meets the two-part test of Idaho Code ~ 61-129 of selling water service to the public
for compensation within the State of Idaho. There is a need for water service (as demonstrated
by its existing services) and Commission Staff recommended that it be granted a Certificate of
Public Convenience and Necessity pursuant to Idaho Code ~ 61-526.
Commission Findines We find that Resort Water is operating as a public utility
pursuant to Idaho Code ~~ 61-124, 61-125 , 61-129, and should be granted a Certificate of Public
Convenience and Necessity pursuant to Idaho Code ~ 61-526.
II. TEST YEAR
The Company s Application uses a test year ending August 31 , 2003, based upon 12
months of actual data. Staff does not oppose the use of the 2003 test year. We find use of the
2003 test year is reasonable for purposes of this case.
III. RATE BASE
1. Acquisition Adjustment
The Company initially allocated $355 000 of the total purchase price for Schweitzer
Mountain Resort to the domestic water system assets, and included it as part of the rate base
calculation. We find, for the reasons set forth below, that instead of inclusion of the allocated
purchase price of $355 000 into rate base, that an acquisition adjustment to rate base in the
amount of $177 500 to be depreciated over a useful life of 50 years be included.
Staff attempted to verify financial information from Resort Water s predecessor that
would help determine what rate base amount, if any, the previous owner may have had in the
water system at the time of the bankruptcy and subsequent transfer out of bankruptcy to the
ORDER NO. 29732
Applicant. Original accounting records were unavailable to adequately determine the original
book value to calculate rate base at the time of purchase. There was, however, evidence
suggesting that the predecessor company had made continual improvements to the system in the
form of wells and water mains. There are no surviving source documents showing the cost
incurred when these improvements were made.Additionally, there was no evidence to
determine if the improvements were contributed plant.There was anecdotal evidence that
connection fees were collected~ but no evidence of when, from whom, or in what amounts. With
this limited information, we were unable to determine if the amount allocated by the Company as
a purchase price is more or less than the depreciated rate base less contributions of the previous
owner.
It has been a consistent policy of the Commission that rate base not include the
purchase price of a water system unless it could be reasonably shown that the customers have not
previously paid for the water system assets. In this case, the source documents and contribution
records from the predecessor company are not available. The prior company was not identified
as a regulated utility where annual reports and prior Commission files would be available. The
water system was part of a purchase from a bankruptcy estate which establishes that the total
price paid for the entire resort property was at arms length. The allocated portion to the water
system of $355 000 was based in part on an income ratio valuation completed by SNO
Engineering of Littleton, New Hampshire. Resort Water asserted that this valuation established
fair market value for the tangible assets functioning as the water system. However, as previously
stated, this does not adequately determine the appropriate book value of the system less
contributions.
The water system is an essential element of any business or resort operation on
Schweitzer Mountain. Without the water system, the value of any purchase of the Schweitzer
Mountain Resort would be greatly reduced. One could argue that a greater portion of the
purchase price should be allocated to the ski resort operations and condominiums also purchased
at the same time. However, some portion of the resort purchase price should be allocated to the
water system. The water system provides service to many customers in the area who are not
affiliated with the resort.If Resort Water had not decided to invest in the water system, there
would have been many customers of the system without a means to receive domestic water.
therefore believe, under the facts of this case, that it is good public policy to allow a new water
ORDER NO. 29732
company to include as part of its rate base a portion of its investment in the purchase of a failed
water company.
Nevertheless, we are not comfortable with accepting the Company s unsubstantiated
allocation amount for inclusion in rate base because of our previously stated concerns regarding
appropriate book value. We believe that the amount to be included in rate base as an acquisition
adjustment must be determined on a case-by-case basis. In this case, the Company actually paid
something for the water system as part of the total purchase, and there are tangible assets that
function as a water system. Therefore, we are justified in finding that some portion of the
purchase price should be included as an acquisition adjustment in rate base. The Company
should only be allowed to seek recovery of the allocated purchase price if it is less than the
previous owners ' net rate base. Given the lack of information regarding net rate base, the age of
the system and the fact that the system was purchased out of bankruptcy, we find it reasonable to
allow an acquisition adjustment to rate base in the amount of $177 500 to be depreciated over a
useful life of 50 years. With inclusion of the $177 500 acquisition adjustment in rate base
accumulated amortization/depreciation should be increased in the amount of $20,413. The
annual amortization/depreciation expense for this adjustment is $3 550.
Commission Findines We find an acquisition adjustment of $177 500, to be
depreciated over a useful life of 50 years and included in rate base, to be just and reasonable and
in accord with public policy.
2. Recent Improvements
The Company has operated the water system SInce 1999, and has made
improvements to the system since that time. The most costly additions were two wells and a
storage tank. Since 1999, the Company has expended a total of $509 331 in capital
improvements that should be included in rate base. Attached as Attachment A to Staff s
Comments is a detailed schedule of the improvements made to the water system since 1999.
Attachment A to Staff s Comments also lists the dates showing when an asset was put into
service and how much of the asset has been depreciated to date. As of August 31 , 2004, the
additions to rate base have accrued $56 369 in accumulated depreciation.
depreciation expense for these assets is $12 994.
The annual
ORDER NO. 29732
3. Storage Tank Contribution
The Company has in the past collected a hook-up fee. Since 1999, the Company has
collected $128 609 in the form of hook-up fees from customers connecting to the system. This
a deduction from rate base. The hook-up fees for one of the Resort's large condominium
additions (White Pine Lodge) has not been paid to the Company. An affiliate company of the
Applicant owns this facility. In lieu of the hook-up fee, the affiliate company has agreed to build
an additional 60 000-gallon water storage facility and contribute it to Resort Water Company.
Staff has determined that the additional storage tank would contribute to the ability of the water
company to meet peak flows and have enough water capacity for firefighting. Therefore, the
addition of the storage tank to the Company is a prudent addition to plant. Because the water
storage tank will be contributed to the Company, it will not increase rate base nor impact rates
paid. It will, however, make for a more reliable system, and therefore we find this contribution
in lieu of the hook-up fee is prudent and reasonable.
4. Working Capital
The Company and Staff have agreed that working capital in the amount of$15 048 is
reasonable and should be included in rate base. The amount is calculated based on 45 days of
annual expenses as recommended by Staff in this case ($122 058/365 x 45). We find this to be a
reasonable amount for working capital.
5. Rate Base Calculation
We find that total rate base for the Company be computed as follows:
System Improvements since 1999
Working Cash
$509 331
$ 15 048
$177.500
$701 879
Acquisition Adjustment
Total
Less:
Accumulated Depreciation
Contributions to Capital
($ 76 781)
($128.609)
$496,489Net Rate Base
ORDER NO. 29732
Commission Findines We find that Resort Water s net rate base should be set at
$496 489. We find that contribution to the Company of the 60 000-gallon storage tank by the
White Pine Lodge in lieu of a hook-up fee is prudent and reasonable.
IV. RETURN ON EQUITY AND CAPITAL STRUCTURE
1. Return on Equity
The Company has requested an 11 % return on its equity. We find this request to be
reasonable for this particular water company, and therefore adopt 11 % as the rate of return on the
Company s equity. The Company does not recognize any debt on its books. We find the capital
structure acceptable with an effective 11 % overall rate of return on its net rate base, or a annual
return of $54 614. The overall effective tax rate of approximately 25.89%, results in a gross-up
factor of 1.35. When the gross-up factor is applied to the return, the Company should be allowed
to earn $73 729 as the pre-tax earnings requirement ($54 614 x 1.35).
2. Annual Expenses
The Company asserted it has annual expenses in the amount of $122 058.
Approximately one-half of this is for gross labor cost. Staff audited the method of allocating
each employee s time to determine how much time was spent doing exclusively water utility
work, and how much time was spent doing work for the other entities. The other annual
expenses were also audited to ensure that the Company was only paying expenses that are
directly associated with the operation of the water utility. The Company did not include any
amount transferred to its affiliates or parent as an annual expense. We find the labor allocation
to be appropriate at this time for this case and agree that the amount of annual expenses is
$122 058.
3. Revenue Requirement
The Company s total revenue requirement is the sum of the following:
Annual Expenses
Annual Depreciation
Grossed-up Return
$122 058
$ 16 544
$ 73.729
$212 331
Commission Findines We find that Resort Water s rates should include a return on
equity of 11
%;
Resort Water s annual expenses should be set at $122 058; and Resort Water
annual revenue requirement should be set at $212 331.
ORDER NO. 29732
V. RATE DESIGN
1. Customers Equivalent Residential Units
Resort Water has an unmetered water system with a mix of commercial and
residential customers.The nature of the mountain resort area and large amounts of snow
covering meters makes individual metering difficult and impractical. Given the varied nature of
the customer use, as well as the relatively unique nature of the ski mountain resort water
company, the Company s proposed billing system uses an "equivalent residential unit" (ERU) as
the means to determine monthly usage.
The ERU establishes a base-billing unit as the amount of water used by a single
residential customer. It also is meant to create equity for unmetered customers by establishing a
way to distinguish between different uses. The Company and Staff worked together to find a
methodology for assigning a weighting determination for each customer. Because of the varied
nature of usage discussed earlier and for ease of billing, all individual condominium and single-
family residential units are treated equally, each as one (1) equivalent residential unit. The
weighting of commercial and snowmaking uses are more difficult to establish.
The Company used the following methodology to estimate water flows
commercial units incorporated in multi-use buildings and to determine the flows associated with
an equivalent residential unit. (See Staff Production Response No. 1.)
1. Take overall water usage from a known time period when a virtual 100%
capacity of our users are present, and subtract all known water use from
metered users, i., Mill Building and Lakeview Lodge.
2. Estimate the amount of water used from the various restaurants on the
system using IDAPA 58.01.03.007.08 (Wastewater Flows from Various
Establishments in Gallons per Day).
3. Subtract this quantity of water from overall water usage. After
subtracting commercial usage, we should be left with residential users.
4. Divide (total water used - commercial use) by known residential users to
develop a gallons per day (gpd) per ERU.
5. Apply this gpd per ERU to each of the commercial uses to determine new
ERU s for each business.
6. Use historical data for Lakeview Lodge and Mill Building to determine
ERUs attributable to each of the uses.
ORDER NO. 29732
7. Change the number of customers (ERUs) in the rate calculation to
determine a new calculation of rate per month per ERU.
8. Total ERUs change from 383.5 to 378.5 due to new commercial ERUs.
Individual commercial ERUs changed slightly as shown. (See
Attachment B to Staffs Comments for summary of results.
Staff performed a similar analysis. Staff recommended adding an additional six
commercial units uncounted in the Lazier Complex in the Company s revised ERU calculation.
The result is a slight shifting of ERU s between the Company s initial Application and the
recalculated ERUs. There is no change in the overall number of ERUs for residential and
commercial customers. The Company, however, did not consider water usage for snowmaking
equipment in either the Company s original Application or in its revised ERU calculations.
2. Snowmaking ER Us
Staff discussed this issue with the Company and Staff believes that snowmaking can
be a significant user of the Company s water. Yet in years with adequate snowfall, there may be
no snowmaking at all. In discussions with the Company, Staff discovered snowmaking has a
maximum use of 120 gallons per minute for 12 hours and may be performed over a maximum of
8 days. Using this rate and the determined average use per ERU of 236 gallons per day,
snowmaking would equate to 368 ERUs or an amount almost equal to the entire residential and
commercial demand. Staff believes an assignment of this many ERU s to snowmaking would be
unreasonable. The system does not have adequate capacity to provide water to all residential and
commercial customers at system peak while at the same time provide maximum capacity for
snowmaking.
Staff proposed the following ERU ratio for snowmaking. Snowmaking water usage
would only occur during the ski season/winter months. Like the previous ERU determination
Staff believes snowmaking is a peak demand allocation.However, for snowmaking Staff
proposed an ERU calculation based on contribution to the seasonal demand. If we assume the
Company uses an average of four days of snowmaking over the ski season (assumed November
25 to March 31 or 126 days), then snowmaking days would be equal to approximately 3% of the
total available peak season days. Staff believes snowmaking should then contribute
approximately 3% of the total ERUs, or 12 ERUs. Staff recommended 12 ERUs for
snowmaking and a total of395 ERUs on the system.
ORDER NO. 29732
Commission Findines: We find that water usage for Resort Water s customers
should be measured on an equivalent residential unit (ERU) basis, and calculated as set forth
above. We find it just and equitable to allocate some ERU's to the smowmaking activities. We
find the current number ofERUs for the system to be 395, including 12 ERUs for snowmaking.
3. Monthly Flat Rates
Resort Water s service area is a ski resort subject to a considerable amount of snow
cover. Its peak demand occurs sometime between Thanksgiving and New Years. The system
peak is contrary to most other water systems with the typical peak demand occurring during the
summer irrigation season. These three conditions (flat rates, snow cover, and holiday peaking)
create unique rate design considerations. First, there are very few meters on the system. Second
even if there were meters, reading the meters would be nearly impossible because of the amount
of snow covering the meters during the Company s short peak season. While we generally
believe there are many advantages to metered rates, we do not believe meters and metered rates
to be appropriate in this situation.
At the current time the Company is charging a flat rate of$33.00 per month per ERU.
This would allow the Company annual revenue for the total recommended 395 ERUs
$156 420. Based upon the finding that the revenue requirement for the Company should be
$212 331 , the Company is currently under-earning and rates should be adjusted.
With an overall annual revenue requirement of$212 331 and a total of395 ERUs the
annual revenue requirement per ERU is $537.55. This equates to $44.80 per month per ERU.
every ERU provides $537.55 annually, the Company s revenue requirement would be satisfied.
The Company has proposed to continue billing an equal monthly flat rate. The
Company has further notified Staff that it has not had a problem with seasonal disconnects or
collections. Although Staff looked at two alternative rate designs, Annual and Seasonal Rates
based on the Company s experience and for ease of billing, Staff recommended a monthly flat
rate of $44.80 per month per ERU. This amount is equal to the annual revenue requirement per
ERU divided by 12 months.
Commission Findines We find that the Company is currently under-earning, that
current rates are unreasonable, and that an increase is justified pursuant to Idaho Code ~ 61-622.
We find that the rate of $44.80 per month per ERU is just and reasonable.
ORDER NO. 29732
4. Reconnection Charges
Because of the concern for seasonal disconnection, we find a two-tiered reconnection
charge to be prudent: a $20 reconnection charge for disconnections of 30 days ' duration or less;
and a charge of $179.20 for disconnections of more than 30 days' duration. Additionally, we
find it reasonable to include a $60 after hours charge for reconnections that are requested after
hours.
Typically the reconnection charge for customers disconnected for 30 days or less is
approximately equal to the direct cost of performing the reconnection. Cost for reconnections
range from $10 to $35. The Company has requested a reconnection charge of $20. We find that
a $20 reconnection charge for disconnection of 30 days duration or less is reasonable. We find
that a reconnection charge for disconnections of more than 30 days' duration should be equal to
four times the customer s monthly charge. This is based on the assumption that customers will
likely be connected for the ski season (five months) and it typically takes two months for a
customer to be disconnected for non-payment and one month or less for reconnection, leaving
four months remaining where a customer may have little interest in paying.
The Company also requested an after hours reconnection charge of $60. Resort
Water is somewhat remote and the Company s employees do not live within the service territory.
The travel time from Sandpoint to the service territory is approximately 30 minutes in good
weather and can be twice as long in winter driving conditions. Therefore, we find the requested
$60 is a reasonable after hours reconnection charge.
Commission Findines We find that the reconnection charge should be bifurcated
into two charges in order to discourage seasonal disconnection. We find that a reconnection
charge of$20 for those disconnected for 30 days or less, and a charge of$179.20 (four times the
monthly charge) for those disconnected for more than 30 days, as well as an after hours
reconnection charge of $60 to be just and reasonable.
5. Line Extension Agreement
Resort Water Company is located in a high growth area of Idaho. Even though
growth has not occurred as fast as the Company initially anticipated, there is a considerable
amount of growth potential in Resort Water s service area. The rates for Resort Water Company
are on the high-end of the spectrum for small to mid-sized water companies.One factor
providing upward pressure on rates is the level of rate base. Without an adequate line extension
ORDER NO. 29732
policy any growth on Resort's system will provide further upward pressure on rates. Properly
designed line extension policies can appropriately allocate costs
, '
minimize risk to the utility, and
provide a stabilizing factor to the utility s general body of customers.
The Company had initially filed two line extension agreements with its Application.
Staff worked with the Company to incorporate its recommendations into one document
Main/Service Extension Agreement" attached to Staffs Comments as Attachment D. Approval
of the proposed Main/Service Extension Agreement makes the "Multiple Family Housing Water
System Agreement" unnecessary. There is sufficient flexibility in the proposed Main/Service
Extension Agreement to address single-family development and multi-family/commercial
development. Therefore, we approve the proposed Main/Service Extension Agreement and deny
the Company s proposed Multiple Family Agreement.
Commission Findines : We find that in order to appropriately allocate costs
minimize risk to the utility, provide a stabilizing factor to the utility s general body of customers
and to relieve upward pressure on general rates the Company should adopt the Main/Service
Extension Agreement attached to Staffs Comments as Attachment D.
6. Hook-up Fees
The Company did not request a hook-up fee in its Application. Most water utilities
have a hook-up fee to cover the actual cost of the customer s service installation such as the
service line and meter. Because Resort Water is a non-metered system, and according to the
Company, all lots have a service line with a shut-off stubbed onto each property, there is no
direct cost to the Company for the installation - with the exception of inspection time. We find
that the Main/Service Extension Agreement is an adequate substitute to hook-up fees and should
minimize the impact of growth on Resort Water s rate base.
Commission Findines:We find it acceptable that the Company has no hook-up fee
given the adoption of the Main/Service Extension Agreement in Section V above.
7. Customer Rules
Our review of the customer rules submitted by Resort Water finds that they are based
on rules approved for United Water Idaho with modifications to reflect Resort Water s particular
situation. Staff has worked with the Company to assure consistency among previously approved
water company rules and the Commission s Customer Relations Rules. We have further
reviewed the various forms to be used by the Company and find the billing statement, initial
ORDER NO. 29732
delinquent notice, summary of rates, and summary of rules to be reasonable. We approve of the
. rules as agreed to by the Staff and the Company and included as Attachment F to Staff s
Comments.
Commission Findines We find that the Company should adopt the proposed
Customer Rules included as Attachment F to Staff s Comments.
ULTIMATE FINDINGS OF FACT AND CONCLUSIONS OF LAW
Resort Water Company is a water corporation providing water service to the public
within the State of Idaho Idaho Code ~~ 61-124, 61-125, and is operating as a public utility.
Idaho Code ~ 61-129.
The Commission has jurisdiction over this matter as authorized by Title 61 of the
Idaho Code, and more particularly Idaho Code ~~ 61-501 , 61-502, 61-503 , 61-520, 61-523.
As set out in the body of this Order, the Commission finds that the existing rates are
unreasonable. The approved rates set forth in this Order are just and reasonable. Idaho Code
61-622.
ORDER
IT IS HEREBY ORDERED that Resort Water Company be granted a Certificate of
Public Convenience and Necessity.
IT IS FURTHER ORDERED that new rates in the amount of $44.80 per month per
ERU are approved. These rates are effective on and after March 15 2005.
IT IS FURTHER ORDERED that the Company submit tariffs conforming to the rates
set out above no later than April 15, 2005.
IT IS FURTHER ORDERED that the Company s total rate base be set at $701 879
(including an acquisition adjustment of $177 500). Additionally, contribution to the Company of
the 60 000-gallon water storage tank by the White Pine Lodge in lieu of a hook-up fee is deemed
prudent and reasonable, and is hereby ordered.
IT IS FURTHER ORDERED that Resort Water Company s Customer Rules and
Main/Service Extension Agreement, as proposed by Staff and agreed to by the Company, are
approved. Additionally the Company should charge a bifurcated reconnection charge as set for
above in Section V.
IT IS FURTHER ORDERED that Resort Water measure water usage on an
equivalent residential unit (ERU) basis, as calculated above in Section V.
ORDER NO. 29732
THIS IS A FINAL ORDER. Any person interested in this Order may petition for
reconsideration within twenty-one (21) days of the service date of this Order with regard to any
matter decided in this Order.Within seven (7) days after any person has petitioned for
reconsideration, any other person may cross-petition for reconsideration. See Idaho Code ~ 61-
626.
DONE by Order of the Idaho Public Utilities Commission at Boise, Idaho this
day of March 2005.
fl~
MARSHA H. SMITH, COMMISSIONER
ATTEST:
~~li
Commission Secretary
O:RESW0401 dw3
ORDER NO. 29732