20150724Comments.pdf

BRANDON KARPEN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-007 4
(208) 334-03s1
IDAHO BAR NO. 7956
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-59I8
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE JOINT )
APPLICATION OF UNTTED WATER IDAHO ) CASE NO. UWr-W-15-02
INC. AND THE CITY OF BOISE,IDAHO FOR )
APPROVAL OF AN AGREEMENT FOR ) COMMENTS OF THE
REPLACEMENT AND OPERATION OF FIRE ) COMMISSION STAFF
HYDRANTS AND RELATED RATE MAKING )TREATMENT.
COMES NOW the Staff of the Idaho Public Utilities Commission, by and through its
Attorney of record, Brandon Karpen, Deputy Attorney General, and in response to the Notice of
Application and Notice of Modified Procedure issued in Order No. 33300 on May 12,2075, in
Case No. UWI-W-I5-02, submits the following comments.
BACKGROUND
On April 10,2015, United Water Idaho Inc. ("United Water") and the City of Boise,
Idaho ("Boise" or the "City") filed a joint Application seeking Commission approval of an
agreement between the parties to transfer responsibility for operation, maintenance, and
replacement of fire hydrants within Boise's municipal boundaries from the City to United Water.
United Water also seeks approval of related non-standard ratemaking treatment to recover the
increased costs associated with the transfer from ratepayers.
The parties represent that Boise currently owns and maintains more than 6,700 fire
hydrants in Boise's city limits. In July 2074, the parties entered into the agreement for the City
STAFF COMMENTS JULY 23,2015
to transfer ownership and operation of the hydrants to United Water over a 4}-year period (the
"Agreement"). The Agreement calls for Boise to provide an annual report to United Water
identifying hydrants that need to be replaced at the end of their 4}-year life cycle. United Water
will then replace and maintain the new hydrants. The parties estimate that approximately 168
hydrants will be replaced each year over the next 40 years.
United Water further requests assurance from the Commission that the costs associated
with the transfer will be fully included in rate base (not using the traditional l3-month average),
and recovered in any subsequent general rate proceedings over the life of the Agreement. United
Water estimates that "the annual revenue requirement associated with the initial capital
investment [will be] approximately $765,000." Application at fl 7. According to United Water,
this initial cost would increase the initial year's rates by approximately $1.45 per customer. .Id.
atn 12.
Each party has reserved the right to declare the Agreement "null and void" should the
Commission not approve the Agreement, including the specific accounting treatment requested
by United Water. Agreement at $ 2.
STAFF REVIEW
Rationale for the Agreement
The Application and direct testimony ofNeil Oldemeyer of the City of Boise explains the
rationale for the Agreement. Application at 9; Oldemeyer at 4. Mr. Oldemeyer discusses
several reasons for the Agreement: (1) to provide operations consistent with other communities
in the state; (2) to create equity among taxpayers and ratepayers; (3) to make available capital
funding for fire protection infrastructure; and (4) to vest ownership of the hydrants with the
entity that owns the infrastructure connected to the hydrants. The City also suggests that the
proposed transaction should conform with the intent of the franchise agreement. Staff will
address each of the stated reasons below.
l. To provide operations consistent with other communities in the state
United Water and the City argue that Boise is unique in Idaho because in nearly all other
cities, the entity that provides the water for fire protection also owns the fire hydrants. While
this is true, the parties fail to acknowledge that in nearly all Idaho cities, it is the city that owns
the water system and the hydrants and provides the water for fire protection. By transferring
STAFF COMMENTS ruLY 23,2015
ownership of hydrants to UWI, Boise will stand out as one of the only cities in the state to not
own its fire hydrants.
If consistency with other communities in Idaho is a worthwhile goal, the proposed
transfer may only partially achieve this end. Regardless, Staff does not believe that consistency
with other cities in the state is necessarily important. Boise has always been unique with regard
to water services and fire protection and will continue to be unique, even if the Application is
approved.
2. To provide equity amonq taxpayers and ratepayers
In its testimony, the City points out that in Boise, customers of United Water pay for the
entire water system except for fire hydrants. The hydrant expenses are paid from the City's
General Fund which is supported primarily by property taxes. Governments, non-profits, and
other tax-exempt entities do not pay property taxes, yet they receive the benefits of fire
protection. 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 generally agrees that all beneficiaries of fire hydrants should contribute toward their
costs. However, Staff has two concerns with this reasoning. First, Staff believes that the
proportionate amounts each customer pays could be substantially changed as a result of the
transfer of ownership. Under the City's "ownership" concept the amount beneficiaries pay
through taxes is based mostly on property value. Under United Water ownership, hydrant costs
would primarily be recovered through customer charges, which vary by meter size. Depending
on the specific property characteristics and water demands, some customers could pay
substantially different amounts for fire hydrants under United Water ownership than under City
ownership. For example, a large, multi-story office building may have relatively minor water
usage because its water usage is due only to bathrooms, break rooms, and perhaps cafeterias,
with little or no outside landscaping requiring irrigation, yet have a high property value and a
more costly requirement for fire protection. At the opposite extreme, a homeowner's association
with lots of landscaping may be a large water user, but will pay less taxes and have little or no
requirements for fire protection.
Staff is not suggesting that a substantial reshuffling of the amounts individual customers
ultimately pay for fire protection is inappropriate, just that some customers could be significantly
affected. Without knowing the specific taxes, meter sizes, and possible future rate changes, it is
STAFF COMMENTS ruLY 23,2015
not possible to reasonably predict the impact on specific customers. Granted, at present, there
would be no impact because United Water is not proposing rate increases or changes due to the
proposed transfer of hydrant ownership. In the future, Staff believes rate changes would be
necessary for United Water to recover the revenue requirement associated with the hydrants.l
Second, while governments and other entities are exempt from paying property taxes,
each of these entities do pay a3Yo franchise fee that is ultimately credited to the City's General
Fund. As explained in greater detail below, the franchise fees paid by all United Water
customers within city limits is more than2.5 times the City's budget for maintaining and
replacing fire hydrants. See "Franchise Fees" section below. For example, the City currently
budgets about $450,000 for fire hydrants, but collected about $1.16 million in franchise fees
from United Water in FY 2014. See supra Table 1.
3. To make available capital funding for fire protection infrastructure and other essential
services
In testimony supporting the Application, Boise's witness states that the City currently
includes about $450,000 in its capital budget for fire hydrant work, which includes replacement
of about 100 hydrants annually. Mr. Oldemeyer further states that "If the fire hydrants were
owned and operated by United Water, the City's fire hydrant budget could be eliminated and, in
the discretion of the Council, this money be reallocated to the replacement of other critical fire
equipment such as engines and trucks or to enhance or preserve the current level of services for
fire, police, libraries and parks." (Direct, p. 6, lines 12-16).
In production requests, Staff asked why Boise City believes United Water customers
should fund Boise's fire protection equipment, infrastructure, enhance or preserve the current
level of services for fire, police, libraries and parks. In response, the City stated that it simply
believes United Water and/or its customers should be responsible for the ownership, replacement
and maintenance costs of integrated hydrants within the City. Costs associated with ownership,
replacement and maintenance, the City believes, are utility related and should be allocated and
collected from ratepayers as they are in vinually every city in Idaho. The City further stated that
the costs of funding Boise's fire protection equipment, infrastructure, enhancement or
'United Water filed a general rate case on May 24,2015 seeking an overall average rate increase of 13.2 percent.
The rate case filing does not include any rate, revenue or cost impacts to the proposed transfer ofownership offire
hydrants from the City to United Water.
STAFF COMMENTS JULY 23,2015
preservation of the cuffent level of services for fire, police, libraries and parks will continue to be
borne by the City's General Fund, which includes all taxpayers of the City. The City notes that
approximately 85 percent of United Water customers are Boise citizens and represented by the
City's elected officials who approved the hydrant transfer agreement. This 85 percent along with
the other 15 percent of United Water customers already pay, as incorporated in their rates, for the
operation and maintenance of hydrants owned and operated by United Water in unincorporated
Ada County and areas of Eagle.
It is beyond dispute that one of the City's primary motives for proposing the owneiship
transfer is to free-up funds currently used for hydrant maintenance/replacement and use these
funds for other purposes in the future. This represents a windfall for the City. Unless there is an
offsetting reduction in franchise fees charged to United Water customers for the benefit of the
City, or alternatively, a reduction in taxes charged by the City, customers will effectively
continue to pay the City, through taxes and franchise fees, for services it no longer provides,
while also eventually paying United Water for services formerly provided by the City.
Furthermore, as revenue requirement increases for United Water and its customers due to the
transfer, revenue generated by the city through franchise fees will also increase. In effect, the
City is able to increase its available budget without having to raise taxes. While this result may
be reasonable from a tax payer standpoint, Staff does not believe it should be the responsibility
of United Water customers to fund the City's services for fire, police, library and parks.
4. To conform with the intent of the franchise asreement
United Water currently operates in the City of Boise under a November 1,1994,
franchise agreement that expires on November 1,2015. Sections 5(d) and (e) of the franchise
agreement require United Water to provide apparatus, equipment and fixtures to maintain a Class
III fire rating and to follow a capital improvement plan for improving fire protection. The City
states that hydrants are a small but integral part of the water system necessary to provide fire
protection within the City. United Water owns and maintains all other portions of water mains
necessary to provide that protection. The parties, Boise states, believe that hydrants should be
part of the fire protection works, apparatus and fixtures provided by United Water pursuant to the
franchise agreement.
The current franchise agreement does not specifically address ownership of fire hydrants.
Further, while the parties claim that it is the intent of the franchise agreement for United Water to
STAFF COMMENTS JULY 23,2015
own the hydrants, the current agreement has been in place for nearly 2l years and the parties
appear to have operated under a completely opposite interpretation of the franchise agreement's
intent. Nonetheless, Staff recognizes that a new franchise agreement will be negotiated very
soon in which hydrant ownership could specifically be addressed, and the parties can then
express their intent clearly.
If the Commission denies the transfer of ownership of new and replacement hydrants,
Staff is uncertain as to whether the City could require United Water to take ownership as a
condition of the new franchise agreement. Clearly, both United Water and the City have power
to negotiate, while the Commission has none. Nevertheless, Staff believes that it would be
unlikely that United Water could be forced to take ownership of hydrants it currently does not
possess.
5. To vest ownership of the hldrants with the entity that owns the infrastructure connected to
the hydrants. and has the experience and expertise to maintain them
In response to production requests, Boise states oowhile Boise operates sewer, geothermal
and irrigation systems, which require expertise and resources similar to maintaining a municipal
water system and its components, greater efficiencies can be obtained if UWI owns and
maintains the hydrants. Integrating the hydrants into the United Water system, the City states,
will allow United Water to apply their 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 effrcient manner." Answer to Staff Production Request No. 4.
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.
However, it could also be argued that the entity that would normally operate the hydrants, i.e.
Boise City and its firemen, be very familiar with the locations, capabilities, condition and
operation of the hydrants they must depend upon in an emergency. Staff believes it is essential
that both United Water and the City have full confidence in the locations, capabilities, condition
and operation of the hydrants, regardless of which entity owns them.
Although they are an extremely critical component of nearly every water system, fire
hydrants are very simple devices that require very little expertise to operate and very minimal
costs and effort to maintain. Staff believes both the City and United Water have ample ability to
STAFF COMMENTS JULY 23,2015
properly operate and maintain fire hydrants. If this Application is approved, Boise City states
that it will retain the expertise and continue to maintain responsibility to operate and maintain the
hydrants it will still own over the projected 4}-year transition period. The City pledges to work
closely with United Water to ensure consistent and ongoing operation and maintenance of the
hydrants, consistent with the expectations and standards outlined in the Agreement.
Both Boise City and United Water believe that United Water ownership of fire hydrants
will eventually provide a greater level of fire protection than is currently being provided under
Boise City ownership. In response to Staff production requests, the City stated that it would
expect better coordinated maintenance and operation of the system and hydrants, work being
completed by industry specialists, and funding readily available for timely replacement and
installation of the hydrants. All of these elements, the City states, should create a better and
more efficient level of fire protection for Boise City.
Staff does not necessarily disagree, but believes that ownership by either party will
ensure adequate fire protection. Boise admits it has maintained a Class III fire rating-the same
as would be maintained under United Water ownership-for more than24 years and would
anticipate that rating to continue if it continues to own hydrants. Furthermore, hydrants currently
owned by the City that are at or near their 40-year life cycle are replaced by a contractor certif,red
to work on UWI's system.
Other Issues
Franchise Fees
Over the past five fiscal years, Boise City has collected a total of $5.37 million, or an
average of $ I ,074.973 per year in franchise fees from United Water. See Table 1 below. The
City currently assesses a3Yo fee upon United Water's customers based upon the amount billed
by United Water. Idaho Code $ 50-329,4.(1)(a). Section 50-329A further provides that:
Franchise fees paid by [United Water] will be in lieu of and as payment for any
tax or fee imposed by a city on a public service provider by virtue of its status as a
public service provider including. but not limited to, taxes, fees or charges related
to easements, franchises, rights-of-way, utility lines and equipment installation.
maintenance and removal during the term of the public service provider's
franchise with the city.
Idaho Code $ 50329,4.(1)(e) (emphasis added). Staff maintains the Legislature intended
franchise fees be "in lieu of and as payment for any tax or fee imposed by a city for the
STAFF COMMENTS JULY 23,2015
installation, maintenance and removal" of hydrants during the term of United Water's franchise
with the City. Id. As noted above, in last three fiscal years, the City collects over $l million in
franchise fees from United Water but budgets about $450,000 per year. Oldemeyer Direct at 5.2
The City states that it does not now or in the past use funds collected from United Water
through franchise fees to fund any specific costs associated with ownership and maintenance of
fire hydrants. In other words, according to the city, no portion of the franchise fees collected
from UWI ratepayers are specifically ear-marked or dedicated for fire hydrant maintenance and
replacement. Instead, the City reports, United Water franchise fees are combined with franchise
fees collected from other public utilities, monies from property taxes, and other revenue sources,
and placed into the City's General Fund. The General Fund is used to pay a wide variety of City
expenses.
Table I
F'Y UWI Franchise Fees
2010 s 946.921
20t1 984.722
2012 1,104,221
2013 1,183,182
2014 1.155,817
$s,374.863
Source: City response to Staff Production Request No. 7.
The City states that it has no intention of reducing its franchise fee even if it will no
longer be responsible for ownership and maintenance of fire hydrants. Franchise fees collected
from United Water, Boise argues, are a general payment to the City for the right to do business
within the City, to operate a water system in lieu of the City's operating that system and to utilize
public property and rights of way without the necessity of paying fees associated with the use of
those properties. The City is statutorily limited to collecting a maximum of three percent of
United Water's gross revenues for the right to operate within the City. Franchise fee revenues,
the City maintains, are connected to hydrant maintenance only in the incidental sense that
franchise fees are co-mingled with other General Fund revenues which are used to pay all
General Fund requirements, including replacement and maintenance of hydrants.
2 This budgeted amount is projected to fall short in the near future. Oldemeyer Direct at 5.
JULY 23,2015STAFF COMMENTS
Staff agrees with the City that it is allowed by statute to charge a franchise fee of up to
three percent. Nevertheless, Staff believes that a reduction in franchise fees would provide
equity for the increase in cost that will be bome by ratepayers.
City Taxes
The City explained that funds for hydrant maintenance and replacement are drawn from
its General Fund. Boise admits that residents will not necessarily realize any tax reductions or
other savings if fire hydrant ownership is transferred to United Water. If the cost of hydrant
replacement and maintenance is assumed by United Water and its utility ratepayers, which the
City believes is fair, equitable and consistent with practices throughout the State of Idaho, the
General Fund will no longer provide for expenditures for hydrant replacement and maintenance.
Boise acknowledges that it is in the discretion of its City Council whether these savings will
result in a tax reduction, a deferred tax increase or a re-allocation of the resources to fire
protection or other General Fund uses.
Benefits to United Water Ratepayers
As reflected in Mr. Oldemeyer's filed testimony (page 7, lines 17-21), if the proposal is
approved, United Water customers will benefit from having the oversight and maintenance of the
hydrants managed by United Water which has the experience and expertise to operate and
maintain the water distribution system (including hydrants). For many years United Water has
owned and operated a fleet of over 1,000 fire hydrants in its service areaoutside the City of
Boise. Integrating the hydrants into United Water's system, the utility contends, will allow the
Company to integrate the operation and maintenance of those hydrants into its tracking systems
(GlS & work management), contract preparation and bid processes, and current industry
practices and standards to ensure operational efficiency. United Water also points out that it has
the financial, technical, and operational resources to ensure that fire hydrants are maintained,
repaired, andlor replaced more quickly without the delay of coordinating those efforts with City
of Boise personnel. As reflected in Boise City's response to Staff s First Production Request No.
5, the City of Boise uses on-duty firemen to perform inspection and maintenance, while United
Water uses trained and certified water distribution system operators to perform hydrant
maintenance.
STAFF COMMENTS ruLY 23,2015
United Water admits that the proposed change in fire hydrant operation and maintenance
responsibility is not easily correlated to a direct one-to-one cost, service, or quality benefit, at
least not from a customer perspective, such as is the case when an old under-sized water main is
replaced with a new larger pipe with greater flow capabilities. However, the Company states,
water customers would benefit over time through enhanced overall fire protection system
integrity stemming from United Water's expertise, and technical and financial resources, and
ability to respond promptly to and resolve fire hydrant problems. United Water believes all
customers benefit from being connected to a domestic water system that is capable of delivering
safe and dependable service, including fire protection.
Costs to United Water Ratepayers
In the Application, United Water states that the annual revenue requirement per customer
would be approximately $0.24 per bi-monthly bill. Application at 4. While this is a reasonable
initial estimate, Staff believes that it is misleading because it fails to properly consider the long-
term impact on customers. Rather, the first year revenue requirement impact of $1.45, which is
the primary basis for United Water's estimate, is just the tip of the iceberg.
The full revenue requirement of the proposed transfer of ownership is more accurately
represented in the graph below. Each year for the 4}-year replacement cycle, United Water
would invest an additional $765,000. With each year's new investment, the revenue requirement
would increase in order to recover all of the revenue requirement components-return on rate
base, depreciation, O&M expenses, and taxes. The revenue requirement would begin to decline
in year 4l because no new investment would be considered. In actuality, however, a new
revenue requirement cycle would begin in year 41 as hydrants are replaced, but the associated
costs would not be attributable to the transfer of ownership from the City to United Water.
Consequently, those costs are not considered for purposes of this analysis.
STAFF COMMENTS l0 JULY 23,2015
Tota I Revenue Requirement
52,s00,000
$2,000,000
$1,500,000
s1,000,000
s500,000
(-ffi ,,,
jj.
25 30 35 40 45 50 55 60 65 70 75 8r
Years
5101520
The total annual revenue requirement starts at only about S85,000 in the first year, which
is approximately only a dollar per customer, but escalates each year until year 40 when the total
annual revenue requirement peaks at approximately $2.3 million. Over the 80-year replacement
and depreciation cycle, the total cumulative revenue requirement is $92.8 million,which has a net
present value of $10.4 million.
On a per customer basis, as shown, the annual revenue requirement begins at slightly less
than a dollar, but escalates to a peak of more than $26 per customer in year 40. Over the entire
S0-year cycle of replacement and depreciation, the cumulative revenue requirement per customer
will be approximately $ I ,050, which has a net present value of $ I 18.
Annual Revenue Requirement per Customer
s30
$is
s20
$rs
s10
$s
s"
404
Years
';;imlll$[}}[}ls101520
ffiffiffi
2s 30 35
hr'-.
Illllllil Itt r rr rrrr i,,,,
s0 ss 60 65 70 75 805
11STAFF COMMENTS JULY 23,2015
Any costs that would be associated with the transfer of ownership, including any increase
in annual revenue requirement, have not been included in United Water's current general rate
case filed on May 21,2015. If the Application is approved, all costs associated with the transfer
beginning immediately and going forward for the next 80 years would have to be recovered by
United Water through future rate filings.
From aratepayers' perspective, the cost of owning and maintaining fire hydrants is much
less if the City retains ownership than if ownership is transferred to United Water. This is
because United Water, as an investor-owned utility, is allowed to include in rates the opportunity
to earn a return on its investment, whereas a municipality presumably would not earn a retum.
Furthermore, United Water would pay taxes on its earning, as well as pay property taxes, while
the City is tax exempt. All other costs of ownership, including operation and maintenance,
should be the same regardless of who owns the hydrants.
Proposed Accounting Issues
1. Year-end rate base
United Water has requested (Wyatt, direct, p. 6, lines 8-10) that the fire hydrants that are
the subject of this case be included in rate base at full investment and not at a l3-month average
rate base as ordered in Case No. UWI-W-04-4. Staff agrees with this proposal only for fire
hydrants because they are neither revenue producing nor expense reducing. In Case No. UWI-
W-04-4, the Commission ordered a 13-month average rate base where the rate base average
reduces the expense/revenue mismatch identified by the Commission that occurs when the costs
of plant adjustments are added as if they were in place for a whole year without adding any
benefits. Hydrants do not create this mismatch and therefore Staff does not oppose United
Water's proposal to account for hydrants with an end-of-year rate base instead of the 13-month
average ordered in Case No. UWI-W-04-4.
2. Allowance for Funds Used Durine Construction (AFUDC)
United Water has requested "the Commission allow the Company to continue the
calculation and accrual of post-closing AFUDC on the investments anticipated by the Agrcement
until such time as those investments are fully accounted for and included in rates in subsequent
general rate case determinations over the life of the Agreement." (Wyatt, direct, p. 6, lines 12-
l6). Staff recommends that the Commission deny United Water's request for post-closing
STAFF COMMENTS t2 ruLY 23,2015
AFUDC. AFUDC is an accounting mechanism, to recognize capital costs associated with
financing construction. Generally, the capital costs recognized by AFUDC include interest
charges on borrowed funds and the cost of equity funds used by a utility for purposes of
construction. The main purposes of AFUDC are to capitalize with each project the costs of
financing that construction; separate the effects of the construction program from current
operations; and to allocate current capital costs to future periods when these capital facilities are
in service, used and useful. AFUDC represents the cost of funds used during the construction
period before plant goes into service. When it is placed in service, the entire cost of the plant,
including AFUDC, is capitalized and is depreciated over the life of the plant. United Water, in
the next general rate case, can request that the hydrant plant earn arate of return. United Water
characterizes "these investments to be, in effect, stranded, without earning any kind of return
between general rate cases." (Wyatt, p.7, lines 8-9).
Staff opposes AFUDC in this case. The filing of rate cases is entirely at the discretion of
the utility. Here the parties executed their agreement in July 2014 but did not file this case until
April 10, 2015. There was ample time to include the costs of this case in the Company's general
rate case filed May 21,2015. The time period between future general rate cases without earning
any kind of return is regulatory lag. In addition, this treatment is consistent with the treatment of
other investments and not unreasonable.
Conclusions
Both the City and United Water will realize benefits if the Application is approved.
Boise will relieve itself of the obligation to maintain and replace hydrants in the future, and the
City will be able to eliminate its hydrant replacement budget and re-direct frrnds for another
purpose. United Water will benefit because new hydrants will be added to the Company's rate
base upon which the Company will earn an increasing return.
Customers of United Water however will realize little or no benefit, but will be
responsible for significantly higher costs. Staff does not believe there will be any noticeable
benefits to customers or be commensurate with the cost. Put another way, customers will pay
higher costs for little or no noticeable difference in service.
STAFF COMMENTS l3 JULY 23,2015
STAFF' RECOMMENDATIONS
Staff recommends that the joint Application of United Water and the City of Boise not be
approved. Staff believes ratepayers of United Water will see very little benefit through United
Water ownership, but will pay considerably more for many years to come. The franchise fees
collected from United Water are more than adequate to defray the City's costs of installing and
maintaining fire hydrants. Staff does not believe that the benefits would be sufficient to justiff
the costs.
However, in the event that the Commission does choose to approve the Application, Staff
agrees with United Water's proposed end-of-year rate base when these hydrants are included in
rate base. Staff disagrees with post-closing AFUDC and recommends the Commission not
approve such treatment of these investments.
Respectfully submitted this *'L day of July 2ots.
Technical Staff: Rick Sterling
Patricia Harms
i :umisc/comments/uwiwl 5.2bkrpsph comments
STAFF COMMENTS l4 ruLY 23,2015
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 23'd DAY OF ruLY 2015,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN
CASE NO. UWI-W.15.02, BY MAILING A COPY THEREOF, POSTAGE PREPAID,
TO THE FOLLOWING:
DEAN J MILLER
MoDEVITT & MILLER LLP
42OW BANNOCK
BOISE ID 83702
E-MAIL: [e-mail]
DOUGLAS K STRICKLING
BOISE CITY ATTORNEY'S OFFICE
PO BOX 500
BOISE ID 83701
E-MAIL: [e-mail]
CERTIFICATE OF SERVICE