20240809Staff 155-174 to PAC - Redacted.pdf

RECEIVED
Friday, August 9, 2024 12:53.05 PM
IDAHO PUBLIC
UTILITIES COMMISSION
ADAM TRIPLETT
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 10221
Street Address for Express Mail:
11331 W CHINDEN BLVD, BLDG 8, SUITE 201-A
BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )
OF ROCKY MOUNTAIN POWER FOR ) CASE NO. PAC-E-24-04
AUTHORITY TO INCREASE ITS RATES )
AND CHARGES IN IDAHO AND APPROVAL ) REDACTED NINTH
OF PROPOSED ELECTRIC SERVICE ) PRODUCTION REQUEST OF
SCHEDULES AND REGULATIONS ) THE COMMISSION STAFF
TO ROCKY MOUNTAIN
POWER
Staff of the Idaho Public Utilities Commission,by and through its attorney of record,
Adam Triplett, Deputy Attorney General, requests that PacifiCorp d/b/a Rocky Mountain Power
("Rocky Mountain Power" or the "Company")provide the following documents and information
as soon as possible,but no later than FRIDAY,AUGUST 23, 2024.1
This Production Request is to be considered as continuing, and the Company is requested
to provide, by way of supplementary responses, additional documents that it, or any person
acting on its behalf, may later obtain that will augment the documents or information produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name,job title, and telephone number of
1 Staff is requesting an expedited response. If responding by this date will be problematic,please call Staff s
attorney at(208)334-0318.
NINTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 1 AUGUST 9, 2024

the person preparing the documents. Please also identify the name,job title, location, and
telephone number of the record holder.
In addition to the written copies provided as response to the requests, please provide all
Excel spreadsheets and electronic files with formulae intact and enabled.
REQUEST NO. 155: Please describe any changes made to the incentive amount,
dispatch parameters, or any other program design element for each of the Company's Demand
Response ("DR")programs for the past five years or since the beginning of the program,
whichever is first.
REQUEST NO. 156: For each of the Company's DR offerings,please describe the
process the Company uses to propose and implement program changes for Commission review.
REQUEST NO. 157: Please provide the following information for the "APIM-Asset
Performance and Investment Mg"project referenced in Production Request No. 15 response
from the Company. Please include any available workpapers with formulas intact. If any of the
information requested below cannot be provided or is not available, please explain why it is not
available or cannot be provided.
a. Please provide a detailed explanation for the need of the project including the analysis
justifying the need.
b. Please provide a list of all the potential alternatives the Company considered to fulfill
the need and explain why the project was selected among the alternatives supported
by the Company's economic analysis (costs and benefits) comparing them.
c. If a Request for Proposal ("RFP") or Request for Quote ("RFQ") was submitted,
please provide the following:
i. A copy of the RFP or RFQ that was submitted;
ii. A detailed explanation of the selection process including the scorecard and list
of the criteria used to select the project;
iii. The short-list bidder scorecard; and
iv. A copy of the winning bid.
d. Please provide the approved Initial Project Plan including the following:
NINTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 AUGUST 9, 2024

i. Initial project scope;
ii. Initial project budget;
iii. Initial proposed schedule; and
iv. Evidence that the Initial Project Plan and budget were approved at the
appropriate level.
e. Please provide the following for the Baseline Construction Project:
i. Baseline project scope;
ii. Baseline project budget broken down by Work-Breakdown Structure
("WBS");
iii. Baseline project schedule broken down by WBS;
iv. If the baseline construction project scope, budget, and/or schedule deviated
from the Initial Project Plan,please explain the differences, explain the reason
for the change, and provide evidence that the changes were approved at the
appropriate level;
V. Project status reports and action items; and
vi. Contractor change orders.
f. Please provide the following related to completion of the project:
i. Baseline construction budget-to-actual comparison by WBS and by year;
ii. Baseline construction schedule-to-actual comparison by WBS;
iii. For any budget-to-actual cost overages by major WBS category that is over
5%, please explain the reason for the differences and provide evidence that the
amount was approved at the appropriate level; and
iv. Please explain any slips in schedule from the baseline construction schedule.
REQUEST NO. 158: Please provide the following information for the "Monarch PAC6
Upgrade and HW TOM"project referenced in Production Request No. 15 response from the
Company. Please include any available workpapers with formulas intact. If any of the
information requested below cannot be provided or is not available, please explain why it is not
available or cannot be provided.
a. Please provide a detailed explanation for the need of the project including the analysis
justifying the need.
NINTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 3 AUGUST 9, 2024

b. Please provide a list of all the potential alternatives the Company considered to fulfill
the need and explain why the project was selected among the alternatives supported
by the Company's economic analysis (costs and benefits) comparing them.
c. If a RFP or RFQ was submitted, please provide the following:
i. A copy of the RFP or RFQ that was submitted;
ii. A detailed explanation of the selection process including the scorecard and list
of the criteria used to select the project;
iii. The short-list bidder scorecard; and
iv. A copy of the winning bid.
d. Please provide the approved Initial Project Plan including the following:
i. Initial project scope;
ii. Initial project budget;
iii. Initial proposed schedule; and
iv. Evidence that the Initial Project Plan and budget were approved at the
appropriate level.
e. Please provide the following for the Baseline Construction Project:
i. Baseline project scope;
ii. Baseline project budget broken down by WBS;
iii. Baseline project schedule broken down by WBS;
iv. If the baseline construction project scope,budget, and/or schedule deviated
from the Initial Project Plan,please explain the differences, explain the reason
for the change, and provide evidence that the changes were approved at the
appropriate level;
V. Project status reports and action items; and
vi. Contractor change orders.
f. Please provide the following related to completion of the project:
i. Baseline construction budget-to-actual comparison by WBS and by year;
ii. Baseline construction schedule-to-actual comparison by WBS;
M. For any budget-to-actual cost overages by major WBS category that is over
5%, please explain the reason for the differences and provide evidence that the
amount was approved at the appropriate level; and
NINTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 4 AUGUST 9, 2024

iv. Please explain any slips in schedule from the baseline construction schedule.
REQUEST NO. 159: Please provide the following information for the "VMWare ELA"
project referenced in Production Request No. 15 response from the Company. Please include
any available workpapers with formulas intact. If any of the information requested below cannot
be provided or is not available, please explain why it is not available or cannot be provided.
a. Please provide a detailed explanation for the need of the project including the analysis
justifying the need.
b. Please provide a list of all the potential alternatives the Company considered to fulfill
the need and explain why the project was selected among the alternatives supported
by the Company's economic analysis (costs and benefits) comparing them.
c. If a RFP or RFQ was submitted, please provide the following:
i. A copy of the RFP or RFQ that was submitted;
ii. A detailed explanation of the selection process including the scorecard and list
of the criteria used to select the project;
iii. The short-list bidder scorecard; and
iv. A copy of the winning bid.
d. Please provide the approved Initial Project Plan including the following:
i. Initial project scope;
ii. Initial project budget;
iii. Initial proposed schedule; and
iv. Evidence that the Initial Project Plan and budget were approved at the
appropriate level.
e. Please provide the following for the Baseline Construction Project:
i. Baseline project scope;
ii. Baseline project budget broken down by WBS;
iii. Baseline project schedule broken down by WBS;
iv. If the baseline construction project scope,budget, and/or schedule deviated
from the Initial Project Plan,please explain the differences, explain the reason
for the change, and provide evidence that the changes were approved at the
appropriate level;
NINTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 5 AUGUST 9, 2024

V. Project status reports and action items; and
vi. Contractor change orders.
f. Please provide the following related to completion of the project:
i. Baseline construction budget-to-actual comparison by WBS and by year;
ii. Baseline construction schedule-to-actual comparison by WBS;
Ili. For any budget-to-actual cost overages by major WBS category that is over
5%, please explain the reason for the differences and provide evidence that the
amount was approved at the appropriate level; and
iv. Please explain any slips in schedule from the baseline construction schedule.
REQUEST NO. 160: Please provide the following information for the "LCT Open
Office Plan"project referenced in Production Request No. 15 response from the Company.
Please include any available workpapers with formulas intact. If any of the information
requested below cannot be provided or is not available,please explain why it is not available or
cannot be provided.
a. Please provide a detailed explanation for the need of the project including the analysis
justifying the need.
b. Please provide a list of all the potential alternatives the Company considered to fulfill
the need and explain why the project was selected among the alternatives supported
by the Company's economic analysis (costs and benefits) comparing them.
c. If a RFP or RFQ was submitted, please provide the following:
i. A copy of the RFP or RFQ that was submitted;
ii. A detailed explanation of the selection process including the scorecard and list
of the criteria used to select the project;
iii. The short-list bidder scorecard; and
iv. A copy of the winning bid.
d. Please provide the approved Initial Project Plan including the following:
i. Initial project scope;
ii. Initial project budget;
iii. Initial proposed schedule; and
NINTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 6 AUGUST 9, 2024

iv. Evidence that the Initial Project Plan and budget were approved at the
appropriate level.
e. Please provide the following for the Baseline Construction Project:
i. Baseline project scope;
ii. Baseline project budget broken down by WBS;
Ili. Baseline project schedule broken down by WBS;
iv. If the baseline construction project scope,budget, and/or schedule deviated
from the Initial Project Plan,please explain the differences, explain the reason
for the change, and provide evidence that the changes were approved at the
appropriate level;
V. Project status reports and action items; and
vi. Contractor change orders.
f. Please provide the following related to completion of the project:
i. Baseline construction budget-to-actual comparison by WBS and by year;
ii. Baseline construction schedule-to-actual comparison by WBS;
iii. For any budget-to-actual cost overages by major WBS category that is over
5%, please explain the reason for the differences and provide evidence that the
amount was approved at the appropriate level; and
iv. Please explain any slips in schedule from the baseline construction schedule.
REQUEST NO. 161: For rate design for Schedule I and Schedule 36,please answer the
following for each class and provide any associated workpapers. Additionally, if different for
each rate year,please explain.
a. Please explain how the Company determined the differential between the summer and
winter seasons energy charges;
b. For Schedule 1, please explain how the Company determined the differential between
energy charges for the first 700/1,000 kWh and all additional kWh in the summer and
the winter;
c. For Schedule 36, please explain how the Company determined the On-Peak and Off-
Peak differentials for summer and winter; and
NINTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 7 AUGUST 9, 2024

d. For Schedule 36, please explain how the Company determined its On-Peak and Off-
Peak times in the summer and winter seasons.
REQUEST NO. 162: Please explain how the Company determines its summer and
winter seasons for rate design. Please provide any associated workpapers supporting the
Company's proposal.
REQUEST NO. 163: Please provide the number and percentage of Idaho residential
customers whose primary heating source is electric.
REQUEST NO. 164: Please provide the monthly average energy usage for Idaho
residential customers for the summer season, winter season, and annually for each year from
2018 through 2023.
REQUEST NO. 165: Please provide the minimum requirements a contractor must meet
to perform work for the Company.
REQUEST NO. 166: Please provide supporting documentation for the Company's
adjustment to fly ash revenue shown in adjustment No. 3.6.
REQUEST NO. 167: Please provide the monthly coal inventory by both dollars and
tons in 2024 for the following plants:
a. Jim Bridger;
b. Craig;
c. Hunter;
d. Huntington; and
e. Dave Johnston.
NINTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 8 AUGUST 9, 2024

REQUEST NO. 168: For the coal plants listed in Request No. 167 above, please
provide the measurement by month and assumptions to determine the tons of coal needed for to
have the following supply:
a. 3 0-day;
b. 45-day;
c. 60-day; and
d. 75-day.
REQUEST NO. 169: Please provide a schedule showing the costs for EIM Board of
State Regulators ("BOSR"), Western Resource Adequacy Program("WRAP"), and Committee
of State Regulators ("COSR") for 2022, 2023 and 2024. Please include the invoices for those
expenses.
REQUEST NO. 170: Please provide the supporting documentation for the forecasted
BOSR, WRAP and COSR expenses.
REQUEST NO. 171: Please provide the following information for all capital projects
included for recovery that have closed through June of 2024 in spreadsheet format. Please treat
this as a continuing request by appending to the spreadsheet for project closes each succeeding
month.
a. List of projects by project name, description, and project identifier;
b. Actual capital cost vs budgeted cost by project and by project element (work
breakdown structure);
c. Actual in-service dates vs planned in-service dates by project;
d. For any cost element(work breakdown structure) over budget by 5%, please provide
a detailed explanation for the cause of the overage; and
e. If the in-service date of the project went past the planned in-service date, please
provide a detailed explanation of the cause(s).
REQUEST NO. 172: Please provide the following information for the Foote Creek II-
IV("FC") wind project referenced by Hemstreet, DI at 4. Please include any available
NINTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 9 AUGUST 9, 2024

workpapers with formulas intact. If any of the information requested below cannot be provided
or is not available, please explain why it is not available or cannot be provided.
a. According to Hemstreet at 18, the repowering efforts (such as replacing the existing
wind turbines, infrastructure, etc.) do not increase the overall system capacity of the
FC plant. Based on that, please explain the Company's position in need of
repowering the FC plant instead of reusing the existing plant structures (from
previous owner, Terra-Gen).
b. According to Burns, DI at 21, the Company is forecasting yearly system load and
peak load increase during 2023 —2040 timeframe. Please explain how the FC plant
contribute to mitigating the increasing system and peak load if the repowering efforts
do not increase the plant's overall capacity.
c. An explanation with necessary justifications, cost-benefits analysis, and necessary
documentation on reusing the existing infrastructure of the FC plant.
d. A list of all the potential alternatives the Company considered to fulfill the need of
repowering and explain why the project was selected from the alternatives supported
by the Company's economic analysis (costs and benefits) comparing them.
e. An explanation why the repowered FC plant is. overbuilt at the capacity of■
. if the grid curtailment asserts the interconnection limit at
Confidential Exhibit 38 at 26.
f. An explanation with necessary documentation on how the Company accounted for
the cost of removing 64 Wind Turbine Generators ("WTGs") and associated
infrastructure,previously owned by Terra-Gen.
g. A copy of the Large Generator Interconnection Agreement("LGIA") associated with
the FC plant.
h. A copy of the Build Transfer Agreement ("BTA") associated with the FC plant.
i. Please provide the following information regarding all RFPs or RFQs associated with
the development and construction of the FC plant:
i. A copy of the RFP or RFQ that was submitted;
ii. A detailed explanation of the selection process including the scorecard and list
of the criteria used to select the project;
iii. The short-list bidder scorecard; and
NINTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 10 AUGUST 9, 2024

iv. A copy of the winning bid.
j. Please provide the approved Initial Project Plan including the following:
i. Initial project scope;
ii. Initial project budget;
iii. Initial proposed schedule; and
iv. Evidence that the Initial Project Plan and budget were approved at the
appropriate level.
k. Please provide the following for the Baseline Construction Project:
i. Baseline project scope;
ii. Baseline project budget broken down by WBS;
iii. Baseline project schedule broken down by WBS;
iv. If the baseline construction project scope,budget, and/or schedule deviated
from the Initial Project Plan,please explain the differences, explain the reason
for the change, and provide evidence that the changes were approved at the
appropriate level;
V. Project status reports and action items; and
vi. Contractor change orders.
1. Please provide the following related to completion of the project:
i. Baseline construction budget-to-actual comparison by WBS and by year;
ii. Baseline construction schedule-to-actual comparison by WBS;
M. For any budget-to-actual cost overages by major WBS category that is over
5%, please explain the reason for the differences and provide evidence that the
amount was approved at the appropriate level; and
iv. Please explain any slips in schedule from the baseline construction schedule.
REQUEST NO. 173: Please provide the following information for the Rock River I
("RR")wind project referenced by Hemstreet, DI at 5. Please include any available workpapers
with formulas intact. If any of the information requested below cannot be provided or is not
available,please explain why it is not available or cannot be provided.
a. According to Hemstreet at 18, the repowering efforts (such as replacing the existing
wind turbines, infrastructure, etc.) do not increase the overall system capacity of the
NINTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER I I AUGUST 9, 2024

RR plant. Based on that,please explain the Company's position in need of
repowering the RR plant instead of reusing the existing plant structures (from
previous owner, Shell).
b. According to Burns, DI at 21, the Company is forecasting yearly system load and
peak load increase during 2023 —2040 timeframe. Please explain how the RR plant
contributes to mitigating the increasing system and peak load if the repowering efforts
do not increase the plant's overall capacity.
c. An explanation with necessary justifications, cost-benefits analysis, and necessary
documentation on reusing the existing infrastructure of the RR plant.
d. A list of all the potential alternatives the Company considered to fulfill the need of
repowering and explain why the project was selected from the alternatives supported
by the Company's economic analysis (costs and benefits) comparing them.
e. An explanation why the repowered RR plant is- overbuilt at the capacity of
— if the grid curtailment asserts the interconnection limit at_
Confidential Exhibit 39 at 23.
f. An explanation with necessary documentation on how the Company accounted for
the cost of removing 50 WTGs and associated infrastructure,previously owned by
Shell.
g. Please provide a copy of the LGIA associated to the RR plant.
h. A copy of the BTA associated with the RR plant.
i. Please provide the following information regarding all RFPs or RFQs associated with
the development and construction of the RR plant:
i. A copy of the RFP or RFQ that was submitted;
ii. A detailed explanation of the selection process including the scorecard and list
of the criteria used to select the project;
iii. The short-list bidder scorecard; and
iv. A copy of the winning bid.
j. Please provide the approved Initial Project Plan including the
i. Initial project scope;
ii. Initial project budget;
iii. Initial proposed schedule; and
NINTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 12 AUGUST 9, 2024

iv. Evidence that the Initial Project Plan and budget were approved at the
appropriate level.
k. Please provide the following for the Baseline Construction Project Plan including the
following:
i. Baseline project scope;
ii. Baseline project budget broken down by WBS;
iii. Baseline project schedule broken down by WBS;
iv. If the baseline construction project scope,budget, and/or schedule deviated
from the Initial Project Plan,please explain the differences, explain the reason
for the change, and provide evidence that the changes were approved at the
appropriate level;
V. Project status reports and action items; and
vi. Contractor change orders.
1. Please provide the following related to completion of the project
i. Baseline construction budget-to-actual comparison by WBS and by year;
ii. Baseline construction schedule-to-actual comparison by WBS;
iii. For any budget-to-actual cost overages by major WBS category that is over
5%, please explain the reason for the differences and provide evidence that the
amount was approved at the appropriate level; and
iv. Please explain any slips in schedule from the baseline construction schedule.
REQUEST NO. 174: Please provide the following information for the Rock Creek I
("RC")wind project referenced by Wagner, DI at 2. Please include any available workpapers
with formulas intact. If any of the information requested below cannot be provided or is not
available,please explain why it is not available or cannot be provided.
a. Please provide a list of all the potential alternatives the Company considered to fulfill
the need and explain why the project was selected from among the alternatives
supported by the Company's economic analysis (costs and benefits) comparing them.
b. Please provide the following information regarding all RFPs or RFQs associated with
the development and construction of the RC plant:
i. A copy of the RFP or RFQ that was submitted;
NINTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 13 AUGUST 9, 2024

ii. A detailed explanation of the selection process including the scorecard and list
of the criteria used to select the project;
iii. The short-list bidder scorecard; and
iv. A copy of the winning bid.
c. Please provide the approved Initial Project Plan including the following:
i. Initial project scope;
ii. Initial project budget;
iii. Initial proposed schedule; and
iv. Evidence that the Initial Project Plan and budget were approved at the
appropriate level.
d. Please provide the following for the Baseline Construction Project Plan:
i. Baseline project scope;
ii. Baseline project budget broken down by WBS;
iii. Baseline project schedule broken down by WBS;
iv. If the baseline construction project scope,budget, and/or schedule deviated
from the Initial Project Plan,please explain the differences, explain the reason
for the change, and provide evidence that the changes were approved at the
appropriate level;
V. Project status reports and action items; and
vi. Contractor change orders.
e. Please provide the following related to completion of the project:
i. Baseline construction budget-to-actual comparison by WBS and by year;
ii. Baseline construction schedule-to-actual comparison by WBS;
iii. For any budget-to-actual cost overages by major WBS category that is over
5%, please explain the reason for the differences and provide evidence that the
amount was approved at the appropriate level; and
iv. Please explain any slips in schedule from the baseline construction schedule.
NINTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 14 AUGUST 9, 2024

DATED at Boise, Idaho, this 91h day of August 2024.
-�//-u P, 14
Adam Triplett
Deputy Attorney General
Technical Staff. Ty Johnson
1:\Utility\UM1SC\PRDREQ\PAC-E-24-04 PR#9 Redacted.docx
NINTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 15 AUGUST 9, 2024

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS �AY OF AUGUST 2024,
SERVED THE FOREGOING REDACTED NINTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO ROCKY MOUNTAIN POWER, IN CASE NO. PAC-E-24-
04, BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
MARK ALDER JOE DALLAS
ROCKY MOUNTAIN POWER CARLA SCARSELLA
1407 WEST NORTH TEMPLE STE 330 ROCKY MOUNTAIN POWER
SALT LAKE CITY UT 84116 825 NE Multnomah, Suite 2000
E-MAIL: mark.alder(c-�pacificorp.com Portland, OR 97232
E-MAIL: Loseph.dallas(2pacificorp.com
carla.scarsell a(ai),paci fi corp.com
DATA REQUEST RESPONSE CENTER
E-MAIL ONLY:
datarequest(�paci fi corp.com
ERIC L OLSEN LANCE KAUFMAN PhD
ECHO HAWK& OLSEN PLLC 2623 NW BLUEBELL PLACE
PO BOX 6119 CORVALLIS OR 97330
POCATELLO ID 83205 E-MAIL: lance a,ae isg insi h
E-MAIL: elo('Z,echohawk.com
MATTHEW NYKIEL BRAD HEUSINKVELD
ID CONSERVATION LEAGUE ID CONSERVATION LEAGUE
710 N 6TH STREET 710 N 6TH STREET
BOISE ID 83702 BOISE ID 83702
E-MAIL: matthew.nykiel(cDgmail.com E-MAIL:
heusinkveld(c'vidahoconservation.org
THOMAS J BUDGE BRIAN C COLILINS
RACINE OLSON PLLP GREG MEYER
PO BOX 1391 BRUBAKER& ASSOCIATES
POCATELLO ID 83204-1391 16690 SWINGLEY RIDGE RD #140
E-MAIL: ti(c4racineolson.com CHESTERFIELD MO 63017
E-MAIL: bcollins a,consultbai.com
gme era,consultbai.com
Electronic Service Only: RONALD L WILLIAMS
KEVIN HIGGINS BRANDON HELGESON
NEAL TOWNSEND HAWLEY TROXELL ET AL
ENERGY STRATEGIES LLC 877 W MAIN ST
E-MAIL: khiggins a,energystrat.com BOISE ID 83701
ntownsend(&energystrat.com E-MAIL: rwilliamsahawleytroxell.com
[e-mail]
CERTIFICATE OF SERVICE Page 1 of 2

Electronic Service Only: Electronic Service Only:
BRADLEY MULLINS VAL STEINER
MW ANALYTICS ITAFOS CONDA LLC
E-MAIL: brmullinsnmwanalytics.com E-MAIL: Val.steiner(abitafos.com
Electronic Service Only:
KYLE WILLIAMS
BYU Idaho
E-MAIL: williamsk u,bni.edu
PATRICIA JORDAN, SECRETARY
CERTIFICATE OF SERVICE Page 2 of 2