20150813City of Boise Reply Comments.pdf

Douglas K. Strickling (ISB No. 3230)
BOISE CITY ATTORNEY'S OFFICE
P.O. Box 500-83701
150 North Capitol Boulevard
Boise, Idaho 83702
Tel: [phone]
Fax: [phone]
dstrickling@cityofboise. org
IN THE MATTER OF TIIE JOINT
APPLICATION OF UNITED WATER IDAHO,
INC. AND THE CrTY OF BOTSE,IDAHO FOR
APPROVAL OF AI\ AGREEMENT FOR
REPLACEMENT AND OPERATION OF FIRE
IIYDRANTS AI\D RELATED RATE MAKING
TREATMENT.
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
cAsE NO. UWI-W-15-02
CITY OF BOISE GENERAL
COMMENTS AND REPLY TO
COMMENTS OF TIIE
COMMISSION STAFF
The City of Boise City, by and through its attomey of record, Douglas K. Strickling,
hereby provides the following General Comments and Reply in Response to the Comments of
the Commission Staff.
Background:
On July 15,2014, the City of Boise City ("Boise" or "City") entered into a negotiated Agreement
(the "Agreement") with United Water Idaho, Inc. ("United Water" or "LfWI") providing for the
transfer from the City to UWI of ownership, maintenance and replacement responsibilities for
approximately 6,700 fre hydrants located within Boise. United Water owns and operates a potable
water system which provides service to water users located both within and without the City. UWI
owns the water system hydrants located outside the City limits but does not own the water system
hydrants located within the City. Those hydrants, for a reason neither the City nor IJWI can
historically determine, are currently owned and maintained by the City. The Agreement to transfer
the hydrants was approved unanimously by the Boise City Council and signed by the Mayor.
GENERAL COMMENT AND REPLY TO STAFF
COMMENTS August 13,2015
On April 10, 2015, United Water and Boise, filed a joint Application ("Application") seeking
Commission approval of the terms of the Agreement allowing for the gradual transfer of the
operation, maintenance and replacement of the hydrants located within the City over a forty (40) year
period and seeking permission for UWI to recover the increased costs associated with the transfer
from UWI ratepayers. Commission approval of the Agreement and UWI's requested cost
accounting treatment are conditions precedent to consummation of the hydrant transfer.
On May 12, 2015, the Commission issued a Notice of Order and Notice of Application
requesting public comment on the filed Application. On June 2,2015, the Commission Staff
took the additional step of issuing a press release notifuing the public of the filed application and
the opportunity to comment on the application. The press release contents were reported in the
Idaho Statesman. Only one (1) comment was received. The comment came from a member of
the public who indicated support for ownership of hydrants by United Water but disagreement
with the cost recovery mechanism.
During the pendency of the Application Boise and UWI provided detailed responses to
Discovery Production Requests of the Commission Staff ("Staff'). Commission Staff Comments
were filed on July 23,2015.
General Comments:
The Agreement is based on the fundamental premise that hydrants are an integral part of a water
system and the ownership, operation and maintenance of hydrants by the water service provider
provides for a more efficient system from both a water system maintenance and a fire protection
perspective. United Water, the Boise Fire Department and the Boise Public Works Department,
who each possess relevant expertise in this area, agree with this fundamental premise. United
Water, within the corporate boundaries of Boise, does not own, operate or maintain hydrants. To
the best of Boise and UWI's knowledge, UWI is the only municipal water service provider in the
State of Idaho that does not own, operate and maintain all fire hydrants within their corporate or
certified boundaries. UWI does own, operate and maintain all hydrants located within its
GENERAL COMMENT AND REPLY TO STAFF
COMMENTS 2 August 13,2015
certified area outside the corporate boundaries of the City of Boise. This bifurcated hydrant
system in Boise creates issues from an operational standpoint.
The Agreement is also based on the premise that users of the water system should equitably pay
for the costs of operation, maintenance, and replacement of all elements of that system. All
providers of municipal water service in the State of Idaho, including UWI in its certified area
outside of Boise, recover the costs of owning, maintaining and replacing fire hydrants through
water customer charges. Boise citizen ratepayers are treated differently. These Boise citizen
ratepayers are paying the costs of UWI's ownership, maintenance and replacement of hydrants
located outside the City limits through customer service charges while also paying the costs
associated with Boise's ownership and the maintenance of hydrants through General Fund tax
revenues. UWI ratepayers located outside of Boise do not currently share in the cost of
maintaining and replacing hydrants located within the City.
Boise and UWI, through the Agreement, have established a mechanism to correct the past
practice of separating ownership of hydrants from the water service provider, to correct the
maintenance and fire protection inefficiencies associated with this past practice and to address
the cost recovery inequities over a gradual period with minimal impact to Boise citizen
ratepayers and UWI ratepayers located outside the City. The Agreement has the unanimous
approval of the Boise Mayor and City Council, who believes the Agreement represents the best
interest of the citizens of Boise including United Water Boise citizen ratepayers. The City will
continue to fund the operation and maintenance of the hydrants until they are transferred. The
minimal cost to the ratepayers will be offset by enhanced operational and fire protection services.
In addition, the gradual release of Boise funds used to maintain and replace fire hydrants may be
used to enhance fire service and/or other municipal services needed and utilized by the Boise
citizen ratepayers.
Reply to Staff Comments:
Rationale for Agreement
While Staffls ultimate recommendation is to disapprove the Agreement
Staff has no dispute with the fundamental assumptions set forth above.
GENERAL COMMENT AND REPLY TO STAFF
terms, it appears that
The City believes that
August 1,3,2015COMMENTS
compelling information was provided to support the rationale of the Agreement, from both a
utility basis and even more broadly at a community level. Boise understands that Staff has a
narrow focus on the cost to ratepayers, yet is apparently unconcerned by the current
inconsistency where Boise citizen ratepayers subsidize hydrant ownership, maintenance and
replacement outside of the City.
The Application and Agreement indicates that Boise leadership from the Mayor and Council to
the Fire Department believes it is in the Boise citizens and Boise UWI customers' best interests
to transfer ownership, operation, and maintenance of these City-owned hydrants to United
Water. The transfer is occurring over 40 years to ensure a modest impact on customer rates and
to allow United Water to gradually accept these assets in a way that minimizes liability to the
company and ensures funding for hydrant maintenance, operation and replacement.
1. Operation of hvdrants within Boise CiW should be consistent with other communities in
the state.
Staff makes the statement that "Boise will stand out as one of the only cities in the State to not
own its own hydrants." (Staff Comment p. 3) However, as the Staff comments also point out,
Boise is unique among Idaho cities in that it does not own its municipal water system. The core
issue has little to do with whether a private company or a municipality owns fire hydrants. It is
about Boise's system being split between the two, which has created an operational model that is
fundamentally flawed and unnecessarily inefficient. United Water and Boise have recognized
this systemic flaw and, through the Agreement, have established a fair and responsible
mechanism to remedy it.
To clarify an issue for Staff and the Commission, Boise would very much like to own and
operate the entire water system located within Boise's corporate limits. The lack of ownership
and control of the water serving Boise citizens has created numerous governance issues and lost
opportunities for which franchise fees only partially compensate. Boise also recognizes that the
gradual release of hydrant ownership to UWI means there will be additional assets to purchase
when and if the time comes for Boise to purchase the water system. However, Boise has
determined, through its the Mayor, Council and Fire Department, that ownership and operation
GENERAL COMMENT AND REPLY TO STAFF
COMMENTS August 13,2075
of hydrants by UWI, as Boise's current water service provider, is the most efficient and safe way
to provide water service and fire protection to its citizens and citizen ratepayers.
2. There should be equity among ratepavers and taxpayers.
Staff asserts the "City contends that it would be more equitable for all water users to pay for the
fire hydrants, which would occur under United Water ownership." (Staff Comments p. 3) This
is a not a contention, but a fact. All the other systems in Idaho recover costs for hydrants in their
water rates. UWI recovers its costs for hydrants in its water rates for hydrants operated outside
of the City. No other Idaho city relies on franchise fees or taxes to finance the maintenance and
replacement of hydrants. It is equitable that Boise residents pay for fire hydrants-an essential
portion of the water system-through their water rates. It is for this reason that Boise supports
UWI's request to include the hydrant replacements in their rates.
Staff argues that the proportionate amounts each customer pays could be substantially changed
as a result of the transfer of ownership. The comments go on to lay out two "extreme" scenarios.
The City disputes that these scenarios are probable or that rate disparity issues can be attributed
to the Agreement. Any rate system that is based on averages and reasonable assumptions will
generate extreme scenarios where charges are arguably disproportionate to the services received.
These scenarios are not the result of the transfer of Boise hydrant assets to United Water. They
are a simply a function of the existing rate system methodology.
One area Staff fails to address is the inequity of Boise citizen ratepayers supporting, in their
rates, the ownership, operation and maintenance of UWI hydrants located outside City
boundaries without the reciprocal support of the outside ratepayers paying for hydrants within
the City. The transfer of the hydrants to United Water will remedy this inequity and allow the
entire United Water system to be operated as an integrated system and for the ratepayers to share
equally in benefits provided by that integrated system.
Finally, Staffs Comments ask the Commission, in essence, to review Boise's municipal
budgeting and the expenditure of tax and franchise fee receipts. This is an area the legislature
(see Idaho Code $ 6l-1040 which specifically excludes municipal corporations from IPUC
GENERAL COMMENT AND REPLY TO STAFF
COMMENTS August 13,2015
regulation) and Courts (see Alpert v. Boise Water Corporation 795 P.2d 298 (Idaho 1990) and
ACHD v. IPUC l5l Idaho I (2010)) indicate are beyond the scope of the Commission's
authority. In Alpert, a case which specifically addressed the franchise fees paid by United Water
to Boise City, the Idaho Supreme Court held the IPUC had limited jurisdiction and stated:
"In the complaint filed by the plaintiffs the district court was requested to determine the
validity of the franchise contracts between utilities and the cities. The district court was also
requested to determine the authority of the cities to grant a utility franchise, the validity of
the franchise fee and the authority of the city to impose a franchise fee.
The subject matter of the complaint filed in district court clearly raises legal issues to be
resolved by the courts rather than an administrative agency. The action filed in district court
does not deal with the subject matter traditionally regulated by the public utility commissions
and does not fall into a category of regulation that requires the technical expertise of a public
utility commission."
795 P.2d at 302. The City asks that the Commission, when reviewing Staffls Comments,
recognize its lack of authority in regulating the expenditure of funds by the City and adhere to
the holding in Alpert. The City would also ask the Commission to respect and defer to the broad
authority and judgment of local elected officials in the collection and expenditure of legally
collected franchise fees and tax revenue.
Staff states the "the franchise fees paid by all United Water customers within City limits is more
than 2.5 times the City's budget for maintaining and replacing hydrants". (Staff Comments p. 4)
Implied in this statement is that the City should earmark these funds for hydrants. The City
could do so. The City could also earmark franchise fees for payment toward other water utility
related items in the Fire Department's projected Fiscal Year 2015 budget of $44,770,730 or
water utility related items in the City's overall General fund budget of $203,253,593 (see
Response to Production Request No. 7, City of Boise FY 2015 Budget Update p. 8-9). To
expand on Staffs suggestions, the City could also begin earmarking Idaho Power fees for
electric-related purposes such as light bulb replacements and earmark Intermountain Gas fees for
boiler replacements. However, what Staff is asking the Commission to do, in reviewing the City
expenditure of franchise fees and General Fund revenues for specific items, such as hydrant
maintenance and replacement in this case, is unwarranted and unnecessary and would add an
administratively burdensome step to the already extensive public budgeting process. The use
and expenditure of franchise fees are not restricted or limited by Idaho Code $ 50-329(A). In
GENERAL COMMENT AND REPLY TO STAFF
COMMENTS August 13,2015
compliance with State Code and reasonable accounting practices the City uses franchise fees in
conjunction with tax and other General Fund revenues to cover the expenses of the City. The
Commission should refuse to engage in municipal oversight and legislative matters which, Staff,
contrary to law and practical application, recommends.
3. The Agreement mav make available capital funding for fire protection infrastructure
and other essential services which is a benefit to Boise citizen ratepavers.
Staff states that it is "beyond dispute that one of the City's primary motives for proposing
ownership transfer is to free-up funds currently used for hydrant maintenance/replacement and
use these funds for other purposes in the future." (Staff Comments p. 5) Boise disagrees. The
primary motive for the City proposing transfer is to provide a more efficient and effective water
and fire protection system. Another primary motive is to have an equitable system where
hydrant maintenance and replacement costs are allocated to water ratepayers as is done in every
other system in Idaho. The Agreement would have the incidental, and positive, effect of freeing-
up General Fund monies which could be used for tax relief or to pay for unfunded needs of the
Fire Department or to pay for unfunded General Fund needs which will provide a benefit to UWI
ratepayers who are also Boise citizens. As discussed previously, the use of those funds is within
the sound discretion of the Boise City Council as contemplated by the laws governing municipal
corporations.
Staff describes the reallocation of General Fund monies (including franchise fees and tax
receipts) formerly allocated to hydrant maintenance, operation and replacements as a "windfall"
to Boise. (Staff Comments p. 5) This is inaccurate and inappropriate for several reasons. First,
UWI Boise ratepayers have long enjoyed the benefits of hydrant maintenance and replacements
that they do not pay for in their rates, a rate break that is not enjoyed by almost all other
ratepayers in the State who do pay for municipal hydrants in their rates. Boise and UWI are not
seeking to recover for these past benefits. However, there is no reason to continue to perpetuate
this bifurcated system and inequitable funding mechanism. Second, the statement presumes that
the City's budget is without constraints. This presumption is incorrect. Fire stations, fire
equipment, police services, parks, and libraries have been, or are, on hold awaiting further
General Fund budget resources. Third, Staff fails to acknowledge the fact that the vast majority
GENERAL COMMENT AND REPLY TO STAFF
COMMENTS August 13,2075
of the United Water customers impacted, and we believe benefitted, by the hydrant transfer are
Boise citizens. The elected officials of Boise, who have approved the Agreement, are directly
accountable to the Boise rate payers and the Boise taxpayers impacted and benefitted by the
Agreement. Finally, Boise will continue to pay for hydrant operation and maintenance costs for
the next 40 years. Hydrant ownership will be transferred only after the useful life of the hydrant
is reached. While it would have been the City's preference to immediately transfer ownership of
all hydrants to UWI, the City recognizes it could potentially have an immediate and sizeable
impact on UWI ratepayers and is not the desire of United Water. The gradual transfer will allow
for a minimal impact on rates commensurate with the benefits received from being served by an
integrated system.
4. The Agreement expresses the intent of the parties to the franchise agreement.
Staff indicates that the current franchise agreement does not specifically address the issue of
hydrant ownership and the parties can express their intent clearly in a new franchise agreement.
(Staff Comments p. 4-5) UWI and Boise have entered into the hydrant transfer Agreement to
clearly express their intent regarding hydrant ownership and the expectations regarding the
provision of fire protection service required by the franchise agreement and IDAPA regulations.
The Agreement states that the City will no longer accept new hydrant ownership from United
Water and will transfer the existing City-owned hydrants to United Water over a 4O-year period.
The key elements of this clarified intent will be carried over into the franchise agreement
currently being negotiated.
5. Ownership of the hvdrants should reside with the entity that owns the infrastructure
connected to the hvdrants and has the greater experience and expertise to maintain them.
Staff states "It may be desirable for the entity that owns the hydrants to also own the
infrastructure connected to them in order to ensure that they can deliver sufficient fire flows in an
emergency." (Staff Comments p. 6) Boise agrees. Boise also agrees with the Staff comment
that hydrants are an "extremely critical component of nearly every water system" (Staff
Comments p. 6) and with the sole member of the public to comment who discussed the
importance of hydrants to the over-all water system. However, Boise disagrees with the Staff
GENERAL COMMENT AND REPLY TO STAFF
COMMENTS August 13,2015
minimization of the importance of creating a better and more efficient level of fire protection for
Boise City. Boise believes the Commission should support a better and more efficient level of
fire protection. Boise sees this result being achieved through the United Water's application of
expertise on common maintenance practices; location and maintenance tracking systems;
contract preparation and bid processes; and up-to-date knowledge of industry practices and
standards to ensure the system can be operated and maintained in a more efficient manner.
Boise agrees with Staff that a Class III fire rating is likely to be maintained, at least in the near
future, no matter who owns the hydrants. The key point to the Agreement, however, is to assure
that this Class III rating can be maintained more efficiently at minimal cost to the ratepayers.
Boise can assure the Commission that the operational aspects of the Agreement were thoroughly
vetted by the Boise Fire Department who supports it. The City would not have entered into an
Agreement if there was any concern that citizens would have been put at risk.
6. The budgetins and expenditure of municipal Franchise Fees and Taxes are beyond the
scope of the Commission's authority and not relevant to this Application.
Staff cites ldaho Code $ 50-329(A) (1) (a) for the proposition that franchise fees be used "in lieu
of payment of any tax or fee imposed by the City for the installation, maintenance and removal
of hydrants." (Staff Comments p. 7-8) This provision of state law prohibits the city from
charging UWI for using City rights-of-ways and property for accessing, installing and
maintaining fire hydrants. The City certainly acknowledges this restriction and does not impose
or collect any fee from United Water for the installation, maintenance or removal of hydrants in
the City and will not do so as hydrants are transferred. The City fully complies with all the
requirements set forth in the cited Code section and will continue to do so in the future.
Commission Staff seems to interpret $ 50-329(AXl) to stand for the proposition that UWI
franchise fees are paid, in part, as compensation to the City for City maintenance and ownership
of fire hydrants and, therefore, any change in hydrant maintenance must be accounted for
through franchise fee adjustment. This interpretation is wrong.
GENERAL COMMENT AND REPLY TO STAFFCOMMENTS 9 August 13,2015
The City is authorized by Idaho Code $ 50-329(A) to collect franchise fees from public service
providers franchised by the City. The fees, which are limited to 3Yo of gross revenues received
by the public service provider within the City, are paid by the public service to the city in
quarterly installments. Franchise fees paid by a public service provider are then collected by the
public service provider from its customers within the City. (Idaho Code $ 50-329(AXb)). There
is no restriction in the code on how those franchise fees are budgeted and expended by the City.
In practice the franchise fees collected from UWI are combined with other franchise fees, tax
receipts and other City revenues and placed in a General Fund to fund a variety of City services
including Fire Department personnel and equipment, Police and Parks. The City has been
collecting franchise fees in one form or another from United Water and its predecessors since
1938 (see Boise's Water The Private Side of Public Works by Robert T. Kent and Boise State
University (2007)).
Franchise fees are collected as general compensation to the City for, amongst other things,
allowing United Water to utilize public property and rights of way for the location of its
facilities, as payment in lieu of paying other fees which could be assessed by the City (see Idaho
Code $ 50-329(,{)), as payment for being free from competition from other similar service
providers and for providing a service which the City has the exclusive right to provide. The
legality of specific franchise fees assessed by Boise to UWI was upheld in the case of Alpert v.
Boise lMater Corporation which held the following:
"B. Franchise Fee. The practice of charging franchise fees as consideration for
granting of a franchise was first noted in Boise City v. Idaho Power Co., 37 Idaho
798, 220 P. 483 (1923), which involved the issue of cancellation of a franchise
contract where Idaho Power has purchased two competing power plants and sought to
consolidate the franchises. As consideration for the granting of the franchise, Boise
City had charged a percentage of the utility's gross revenue collected from its Boise
patrons. The Court held that the Commission had no authority to invalidate the
franchise cancellation agreement entered into between Boise city and Idaho Power,
and further held that the payments from the utility to the city constituted valid
consideration for a valuable property right which the city surrendered.
It is well established that Idaho cities have the right to own and operate utilities and
provide those services to their residents. The cities contend that their surrender of
this right is valid consideration for the franchise fee charged to the utilities. We agree.
The franchise agreements in the present case are contracts and the franchise fees are
GENERAL COMMENT AND REPLY TO STAFF
COMMENTS t0 August 13,2015
simply payments or consideration for the rights granted by the cities to the utilities.
Idaho Const. ar. 15, section 2;\.C.40-2308".
StafPs comments regarding the collection and expenditure of franchise fees by the City, asks the
Commission to ignore the clear decision set forth in Alpert and regulate the assessment of
franchise fees. Staff is also asking the Commission to effectively rewrite Idaho Code 50-329(,4.)
to allow the Commission to regulate the City's expenditure of franchise fees collected from
United Water. The Commission has no authority to do so.
Staff asserts that it "does not believe it should be the responsibility of United Water customers to
fund the city's services for fire, police, library and parks." The City does not collect fees from
United Water customers to fund City services. However, Idaho Code 50-329(A) (b) clearly
requires UWI's franchise fee obligation to be passed on by UWI to its customers. In doing so,
the legislature has determined that UWI customers can indirectly pay for the City services
funded by franchise fees. Staff apparently disagrees with this legislatively determined process
and is asking the Commission to rewrite the Code to prohibit the collection of franchise fees paid
by the customer when the franchise fees may be used by the City to fund services, benefitting
Boise citizen ratepayers and taxpayers, with which Commission disagrees. The Staff position is
contrary to law and is beyond the authority of the Commission.
As discussed previously, Staff is erroneously asking the Commission to enter into the realm of
City budgeting and the expenditure of franchise fees and tax revenues. The City could
specifically allocate franchise fees collected from United Water or ldaho Power or Intermountain
Gas or Republic Waste Services to specific expenditures. However, to do so would be
unnecessary, burdensome and serye no practical purpose. Staff was provided a copy of the
City's fiscal year 2014 budget book and 2015 budget update (Response to Production Request
No. 7) which show the valuable public services provided to the benefits of Boise's citizen
ratepayers.
With regard to the franchise fees and expenditure of tax funds the Staff states that "Boise
acknowledges that it is the discretion of the City Council to determine if a savings achieved by
GENERAL COMMENT AND REPLY TO STAFF
COMMENTS l1 August 13,2015
hydrant transfers to the General Fund will result in a tax reduction, a deferred tax increase or a
re-allocation of the resources to fire protection or other resources." (Staff Comments p. 9) The
City not only acknowledges that point, the City emphasizes it. The expenditure of General Fund
monies including franchise fees and tax revenues is in the discretion of the Boise City Council
after public hearings and an extensive budgeting process. The City would ask the Commission
to acknowledge the powers of the City Council and defer to their discretion with regard to the
expenditure of franchise fees and other City General Fund revenues.
7. The Agreement provides at least equivalent benefits and costs to United Water
Ratepavers.
The benefits of this Agreement to the Boise citizen ratepayers are well documented. Staff does
not disagree that transfer will provide a more efficient water and fire protection system.
It is important to put the cost of the Agreement in perspective using the numbers provided by
Staff. Staff points out that the initial cost to the average customer is $0.24 per bi-monthly bill or
$1.45 per year. From another perspective, using Staffs net present value analysis, a similar
calculation can be performed. Staff states that the net present value cost over an SO-year period
is $118 per customer. If this is broken down to a monthly calculation [$118 / (80 years* 12
months/year)] the cost is 12 cents per month. This amount seems nominal. Certainly the amount
of benefit the ratepayer derives from having an integrated system is at least 12 cents per month.
Conclusion:
UWI and the City have presented considerable evidence that the Application, seeking approval
of the proposed Agreement transferring fire hydrant ownership, will provide the benefit of more
efficient water and fire protection service to United Water ratepayers. UWI and the City have
provided considerable evidence that the payment for the maintenance and replacement of
hydrants by United Water ratepayers will put Boise ratepayers in an equitable position with other
ratepayers in the United Water system and with ratepayers throughout the State of Idaho. UWI
and the City have presented considerable evidence that the impact on ratepayers is minimal and
at least commensurate with the benefits to be derived by those ratepayers. The City supports
GENERAL COMMENT AND REPLY TO STAFF
COMMENTS t2 August 1,3,2015
United Water's efforts to include gradually those minimal costs to the ratepayer in their water
rates as proposed by the Agreement and Application. The lack of public comment on the
proposal despite fairly extensive publicity, is strong evidence that the public and UWI ratepayers
have no concern with the proposal.
Commission Staff comments present a thinly-veiled request for the Commission to overturn
Alpert and rewrite Idaho Code $$ 50-329 and 50-329(A) to limit the collection of franchise fees
from a franchised utility by a municipality and to regulate the expenditure of franchise fees by a
municipality. The Commission should reject those arguments.
The Cityrequests the Commission approve the Agreement and Application as proposed.
DATED this fiy'dayof August, zots.
CITY OF BOISE CITY
GENERAL COMMENT AND REPLY TO STAFF
Dougla(K. Strickling
Attorneyfor City of Boise City
COMMENTS 13 August 13,2015
CERTIFICATE OF SERVICE
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I hereby certify that on tne lfudaVof August, 2Ol5,I caused to be served, via the
method(s) indicated below, true and correct copies of the foregoing document, upon:
Jean Jewell, Secretary
Idaho Public Utilities Commission
47 2 W est Washington Street
P.O. Box 83720
Boise,lD 83720-0074
ijewell@nuc. state.id.us
Brandon Karpen
Deputy Attorney General
Idaho Public Utilities Commission
P.O. Box 83720
Boise, Idaho 83720-0074
Brandon. [e-mail]. gov
Dean J. Miller (ISB No. 1968)
McDEVITT & MILLER LLP
420 West Bannock Street
P.O. Box 2564-83701
Boise, D 83702
j oe@mcdevitt-miller. com
GENERAL COMMENT AND REPLY TO STAFF
COMMENTS 14 August 13,2015