20241106Direct Michael Louis.pdf

RECEIVED
Wednesday, November 6, 2024 12.04.07 PM
IDAHO PUBLIC
UTILITIES COMMISSION
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE )
APPLICATION OF IDAHO POWER ) CASE NO. IPC-E-24-07
COMPANY TO INCREASE RATES )
FOR ELECTRIC SERVICE TO )
RECOVER COSTS ASSOCIATED )
WITH INCREMENTAL CAPITAL )
INVESTMENTS AND CERTAIN )
ONGOING OPERATIONS AND )
MAINTENANCE EXPENSES )
DIRECT TESTIMONY OF MICHAEL LOUIS
IDAHO PUBLIC UTILITIES COMMISSION
NOVEMBER 6, 2024

1 Q. Please state your name and business address for
2 the record.
3 A. My name is Michael Louis . My business address
4 is 11331 W. Chinden Blvd. , Ste . 201-A, Boise, ID 83714 .
5 Q. By whom are you employed and in what capacity?
6 A. I am employed by the Idaho Public Utilities
7 Commission ("Commission") as the Staff Engineering Program
8 Manager overseeing the Engineering Department within the
9 Utilities Division.
10 Q. What is your educational and professional
11 background?
12 A. My educational background and professional
13 experience are provided in Exhibit No . 101 .
14 Q. What was your role in this case?
15 A. My role was to provide overall coordination of
16 Staff' s review of this case and to make policy decisions
17 in coordination with other Commission Staff ("Staff")
18 members regarding Staff' s positions .
19 Q. What is the purpose of your testimony in this
20 proceeding?
21 A. The purpose of my testimony is to provide a
22 summary of Staff' s recommendations and introduce Staff' s
23 witnesses in this case . I will also discuss the overall
24 basis used for Staff' s positions as it relates to the
25 limited set of issues proposed by Idaho Power, Inc . ("Idaho
CASE NO. IPC-E-24-07 LOUIS, M. (Di) 1
11/06/24 STAFF

I Power" or "Company") , specifically the recovery of labor
2 expenses and capital investments that have occurred since
3 the Company' s last general rate case ("2023 GRC") , Case
4 No . IPC-E-23-11, the results of which were authorized
5 through Commission Order Nos . 36042 and 36067 with rates
6 effective on January 1, 2024 . My testimony is outlined as
7 follows :
8 I . Introduction of Staff' s Witnesses
9 II . Summary of Staff' s Recommendations
10 III . Company' s Incremental Approach
11 IV. August Average of Monthly Averages ("AMA") Rate
12 Base Adjustment
13
14 Q. Are you sponsoring any Exhibits in your
15 testimony?
16 A. Yes . Exhibit 101 provides a summary of my
17 education and professional background.
18
19 I . Introduction of Staff' s Witnesses
20 Q. Please identify Staff' s witnesses that are
21 testifying in this case and the topics they will cover in
22 their testimony.
23 A. Mr. James Chandler is employed as an Auditor II
24 for the Commission. His testimony covers the calculation
25 of Staff' s recommended revenue requirement incorporating
CASE NO. IPC-E-24-07 LOUIS, M. (Di) 2
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I Staff' s rate base, salary expense, and revenue adjustments .
2 Mr. Jason Talford is employed by the Commission as a
3 Utilities Analyst II . His testimony addresses proposed
4 rate base adjustments related to the prudence of Battery
5 Energy Storage Systems ("BESS") and the cost of
6 interconnecting them to the Company' s system that the
7 Company included for recovery in its proposed incremental
8 revenue requirement .
9 Ms . Kimberly Loskot is employed by the Commission as
10 a Utilities Analyst II . Her testimony covers proposed
11 adjustments to rate base related to the prudence of several
12 miscellaneous capital additions the Company included for
13 recovery in this case .
14 Ms . Laura Conilogue is employed by the Commission as
15 an Auditor II . Her testimony will address Staff' s
16 adjustments to salary expense included in the Company' s
17 proposed revenue requirement increase .
18 Mr. Michael Eldred is employed by the Commission as a
19 Utilities Analyst II . His testimony covers Cost-of-
20 Service, Rate Design, adjustments to the revenue used to
21 offset the revenue requirement, and the amount of sales
22 that is the basis for the billing determinants needed to
23 calculate the Company' s rates .
24 Finally, Ms . Jolene Bussard is employed as a Utilities
25 Compliance Investigator and will testify on customer-
CASE NO. IPC-E-24-07 LOUIS, M. (Di) 3
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1 related issues .
2
3 II . Summary of Staff' s Recommendations
4 Q. Please summarize Staff' s recommendations in this
5 case .
6 A. Staff recommends a revenue requirement increase
7 of 0 . 66% that will result in approximately $8 . 9 million of
8 additional revenue for the Company. These amounts compare
9 to the Company' s requested 7 . 31% increase that would result
10 in $99 . 29 million of additional revenue . For illustrative
11 purposes, I have included a summary of Staff' s proposed
12 revenue requirement adjustments relative to the Company' s
13 proposed increase in the table below.
14
15 Item Description (million $) Rev.Rgmt. Adjust. Increase$ Increase %
16 Company Proposal $99.3 7.31%
17 August 2024 AMA Rate Base Adjustment ($74.7) $24.6 1.81%
18 Rate Base Prudence Adjustments ($4.4) $20.2 1.49%
19 Salary Expense Adjustments ($10.0) $10.2 0.75%
20 Revenue Adjustment ($1.3) $8.9 0.66%
21 The Company limited its case to proposed increases to
22 capital additions and labor expense that are projected to
23 occur during calendar year 2024 using authorized amounts
24 from its 2023 GRC, as a baseline . As discussed below, Staff
25 based all of its adjustments using actual data and
CASE NO. IPC-E-24-07 LOUIS, M. (Di) 4
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1 information that was available using an August 31, 2024,
2 cutoff date . Information available past that date was
3 either forecasted or did not provide Staff with sufficient
4 time to conduct an adequate review.
5 Staff' s recommendations include an adjustment to rate
6 base reducing the Company' s proposed revenue requirement
7 by $74 . 7 million using Staff' s AMA treatment of rate base,
8 and using a July 31, 2023, through August 31, 2024, test
9 year. I will provide the basis for this treatment later
10 in my testimony, while Staff Witness Chandler will testify
11 about the details .
12 Staff also recommends $4 . 0 million of additional rate
13 base adjustments for plant additions the Company provided
14 as closed to plant-in-service through discovery on or prior
15 to August 31, 2024 . Staff' s adjustments are either based
16 on the prudence of those investments or because Staff
17 believes they should have not been closed to plant-in
18 service prior to the cutoff date. Staff witnesses Loskot
19 and Talford will discuss these specific adjustments in
20 their testimony.
21 Staff recommends $10 million of adjustments to salary
22 expense using actual January 1, 2024, through August 31,
23 2024, 0&M labor data. Staff witness Conilogue discusses
24 these adjustments in her testimony.
25 Staff' s last recommended adjustment to the revenue
CASE NO. IPC-E-24-07 LOUIS, M. (Di) 5
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1 requirement includes a $1 . 3 million adjustment to the
2 Company' s Incremental Revenue Growth Offset . ' Staff' s
3 adjustment is based on a 1 . 04% growth in actual kilowatt-
4 hour ("kWh") normalized sales using the same cutoff of
5 August 31, 2024, as compared to the amount of normalized
6 sales authorized in the 2023 GRC over the same months .
7 Because the Incremental Revenue Growth adjustment is based
8 on the growth in sales, Staff also recommends the billing
9 determinants be adjusted to coincide with Staff' s Revenue
10 Growth Offset adjustment . The Incremental Revenue Growth
11 adjustment and billing determinants are discussed in Staff
12 Witness Eldred' s testimony.
13
14 III . Company' s Incremental Approach
15 Q. Please explain the Company' s overall approach to
16 its "Limited Issues" rate case .
17 A. The Company filed its 2023 GRC on May 31, 2023,
18 which was resolved through a Settlement and was
19 subsequently approved by the Commission in Order Nos . 36042
20 and 36067 in December of 2023 .
21 In this case, the Company proposed to use the 2023
22 GRC as a baseline while seeking to recover 2024 capital
23
1 The Incremental Revenue Growth Offset represents the
24 incremental amount of revenue from the revenue authorized
25 in the 2023 GRC 2024 that is associated with labor and
rate base .
CASE NO. IPC-E-24-07 LOUIS, M. (Di) 6
11/06/24 STAFF

1 additions and labor costs incremental to the revenue
2 requirement approved in the 2023 GRC. All other revenue
3 requirement items in this limited issue rate case were
4 considered "out-of-scope" by maintaining the amounts
5 embedded in current base rates approved through the
6 Settlement, including the 7 . 274% overall rate of return
7 approved by the Commission.
8 Consistent with the Company' s approach of using the
9 2023 GRC as a baseline, the Company utilizes the cost-of-
10 service and rate design approved in the 2023 GRC to develop
11 its proposed base rates; however, the Company adjusted the
12 billing determinants to determine the proposed rates
13 reflecting the amount of sales the Company forecasted to
14 occur over the 2024 calendar year.
15 Q. Do you agree with the Company' s incremental
16 approach to adjust base rates in this case?
17 A. I generally agree with the Company' s approach.
18 The Company has taken an incremental approach by limiting
19 its proposed increase to capital additions and salary
20 increases occurring in 2024 using Commission-approved
21 amounts from the 2023 GRC as a baseline . Because the 2023
22 GRC occurred just last year, the costs and revenues of the
23 "out-of-scope" revenue requirement items should reasonably
24 reflect current Company operations since they were recently
25 developed and vetted through the 2023 GRC.
CASE NO. IPC-E-24-07 LOUIS, M. (Di) 7
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1 The Company also relies on the class cost-of-service
2 methodology and rate-design parameters that were agreed
3 upon through the Settlement in the 2023 GRC by the same
4 parties intervening in this case .
5 Finally, I believe the Company' s method of isolating
6 the amount of incremental revenue associated with the labor
7 expense and capital additions is reasonable; however, Staff
8 disagrees with the amount of Sales used as an input to
9 derive the amount of incremental revenue, discussed in
10 greater detail in Staff Witness Eldred' s testimony.
11
12 IV. August AMA Rate Base Adjustment
13 Q. Does Staff agree with the Company' s use of an end-
14 of-period rate base method?
15 A. No . The Company' s method would add approximately
16 $731 million of additional capital projects to rate base
17 using projected plant balances through the 2024 calendar
18 year. Instead, Staff recommends using an AMA rate base
19 method with actual plant additions that have occurred for
20 a test year from August 31, 2023, through August 31, 2024 .
21 This adjustment alone results in a $614 . 3 million reduction
22 in rate base and a $74 . 7 million reduction in the Company' s
23 proposed revenue requirement increase .
24 Q. Please explain the Company' s proposed rate base
25 treatment .
CASE NO. IPC-E-24-07 LOUIS, M. (Di) 8
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1 A. The Company' s proposal includes actual cost of
2 capital additions closed to plant-in-service as of January
3 31, 2024, with projected amounts through December 31, 2024 .
4 Under the Company' s proposal, 100% of the Company' s
5 proposed actual and projected amounts through the end of
6 December would be included in rate base .
7 Q. Please explain why Staff proposes to use an AMA
8 method for valuing rate base instead of the Company' s
9 proposed end-of-period method.
10 A. An AMA rate base method calculates the value of
11 plant-in-service based on the month that it is placed into
12 service during the test year. Using the Company' s January
13 through December 2024 test year, plant included for January
14 would be included at its full value . Plant placed into
15 service in December would be included in rate base at 1/12
16 of its value . Using this method corrects for mismatches
17 between when an investment is placed into service and when
18 the Company receives revenue that the investment generates .
19 It also corrects for mismatches with expenses since new
20 plant-in-service creates efficiencies associated with
21 reduced 0&M expense, which are "out-of-scope" in this case .
22 Q. Has the Commission ruled on the use of an AMA rate
23 base method in past cases?
24 A. Yes, in every litigated general rate case since
25 2003, except one, the Commission ordered or approved the
CASE NO. IPC-E-24-07 LOUIS, M. (Di) 9
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1 use of AMA rate base treatment . For example, in Case No .
2 IPC-E-03-13, the Commission stated:
3 We generally believe that including
investment in the calculation of average-year
4 rate base as it were in service the entire
year when it was not, as proposed by Idaho
5 Power in this case, creates a mismatch between
6 test year revenue and expenses .
The Commission expects all utilities to
7 identify expense savings and revenue producing
effects when proposing rate base adjustments
8 for major plant additions . It is unfair to
ratepayers to assume that the investment in
9 these plants will not increase Company
revenues or decrease Company expenses in the
10 future . Further, it is unreasonable to expect
11 the Commission to allow full recovery of plant
investment as if the plant has been in
12 operation the full year without a
corresponding adjustment to revenues and
13 expenses .
14 Order No . 29505
15
In the most recent fully litigated case, Case No . VEO-
16 W-22-02, the Commission stated:
The Commission continues to believe that
17 including plant investment in the calculation
of rate base as if it were in service the entire
18 year creates a mismatch between test year
19 revenue and expenses, and it is unreasonable
to expect the Commission to allow full recovery
20 of plant investment as if the plant has been
in operation the full year without a
21 corresponding adjustment to revenues and
expenses .
22
Order No . 35762 at 23
23
24 Q. Did the Company authorize a revenue requirement
25 using an end-of-period rate base in the 2023 GRC?
CASE NO. IPC-E-24-07 LOUIS, M. (Di) 10
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1 A. Yes . However, the 2023 GRC was resolved through
2 a Settlement by the parties in the case and was not resolved
3 through a fully litigated case .
4 Q. Please explain why that matters .
5 A. A settlement is based upon a negotiation by all
6 the parties and Staff' s decision to settle is based upon
7 the overall result. Staff will give up on some positions
8 in exchange for others to achieve a fair and reasonable
9 outcome for all parties and for the Company' s customers .
10 However, when a case is fully litigated, every aspect
11 of a case is examined individually and where there is
12 disagreement, the Commission will render a decision. The
13 Commission' s decisions are based on the evidence placed in
14 the record and presented by the parties in the case . The
15 Commission' s rationale behind its decisions included in
16 its orders provides insight as to the Commission' s thinking
17 and the basis for the decision can be used by parties to
18 evaluate future cases .
19 Q. How much weight did Staff give to the one litigated
20 general rate case that used an end-of-period rate base
21 method since 2003?
22 A. The case was Case No . IPC-E-08-10 and Staff gave
23 it little weight . The case was litigated 16 years ago with
24 different Staff and Commissioners . This Commission has
25 consistently ruled on valuing rate base using the AMA
CASE NO. IPC-E-24-07 LOUIS, M. (Di) 11
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1 method and Staff does not believe the circumstances of this
2 case rise to the level that warrant a departure from those
3 rulings .
4 Q. Please explain some of the circumstances preventing
5 Staff from considering a departure of AMA in this case .
6 A. First, consideration of a departure from AMA should
7 only occur in a comprehensive general rate case . The impact
8 of such a change on other aspects normally considered in a
9 general rate case would be very difficult to ascertain and
10 adjust for, especially if those impacts fall into areas
11 that are considered "out-of-scope" in a limited issue rate
12 case .
13 Second, the Company did not propose any corresponding
14 adjustments to revenue or expense causing a mismatch
15 between the cost of the proposed investments and the 0&M
16 savings or associated revenue they generate . Since 0&M
17 expense is "out-of-scope, " for this case, the Company' s
18 proposal does not account for any efficiencies generated
19 by the new plant .
20 For an example related to revenue, because the Company
21 proposed a December 31, 2024, end-of-period rate base, all
22 the Company' s proposed investments in BESS, most of which
23 are not projected to go into service until the latter part
24 of 2024, would go into rate base at the full amount.
25 However, those investments were made to serve new customer
CASE NO. IPC-E-24-07 LOUIS, M. (Di) 12
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1 load that would occur in 2025 and beyond. It would be
2 improper to allow the full cost of those investments for
3 recovery using a December 31, 2024, end-of-period rate base
4 without considering the corresponding revenue from the
5 increased load that is projected to occur in the future .
6 Doing so would result in an over-inflated rate increase
7 since the amount of the increase would essentially be the
8 difference between a revenue requirement that includes the
9 full cost of the investments and a revenue that does not
10 include the additional revenue that those investments would
11 generate .
12 Finally, the Company has communicated to Staff, that
13 it plans to file another rate case next year. This will
14 enable the Company to recover the full prudently incurred
15 cost of its proposed investments in this case matched with
16 corresponding revenue and expense .
17 Q. Please explain why Staff recommends using August
18 31, 2024, as the cutoff date for the test year.
19 A. The August 31, 2024, cutoff date is realistically
20 the latest date that allowed Staff to adequately review
21 the prudence of final actual cost of the Company' s capital
22 projects prior to developing positions and filing its
23 testimony. It also allowed Staff to effectively
24 incorporate actual booked costs without having to speculate
25 on what may or may not happen. Establishing a cutoff date
CASE NO. IPC-E-24-07 LOUIS, M. (Di) 13
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1 is consistent with prior Commission orders . In Case No .
2 UWI-W-04-4, the Commission stated that, " [i] t simply is
3 not possible to carefully review investment cost figures
4 and information that are provided close to or at the time
5 of hearing. " Order No . 29838 at 6 . The Commission also
6 stated:
To facilitate adequate review, Company data
7 should be provided in time to incorporate the
8 information in the prefiled testimony of Staff
and other parties . This will facilitate the
9 hearing and decision processes by having
similar time periods and information for the
10 Staff and intervenor prefiled testimony, the
Company' s rebuttal, and at the hearing. Using
11 recent actual data for the hearing will reduce
12 if not eliminate the need to argue over
forecasts . To this end, the Commission
13 suggests rate cases be filed with no more than
six months of forecast data. Not only with
14 the data be known and measurable by the time
other parties prefile testimony and for the
15 hearing, it will be more convenient and
16 administratively easier for all parties .
Id. at 7
17 Q. Did the Company provide projected or forecasted
18 capital project information in its Application?
19 A. Yes . The Company provided estimated close
20 amounts and projected timing for eight projects over $8
21 million. For projects less than $8 million, the Company
22 estimated the amount it believed it would close to plant-
23 in-service using a historical 5-year average of year-to-
24 year close ratios .
25 Q. How did you instruct Staff to review capital
CASE NO. IPC-E-24-07 LOUIS, M. (Di) 14
11/06/24 STAFF

I projects over $8 million?
2 A. Staff was instructed to review all the projects
3 over $8 million included in the Company' s Application.
4 Tf through subsequent discovery requests a project was
5 shown to close on or before August 31, 2024, Staff was to
6 first verify whether it was in-service and then whether
7 the project costs were prudent . If a project was not yet
8 in service, the entire cost of the project was
9 recommended to be removed from the revenue requirement as
10 a separate adjustment . Similarly, if a project incurred
11 costs that were not prudent, a separate adjustment was
12 recommended for the imprudent amount .
13 For projects that did not close to plant-in-service
14 by August 31, 2024, Staff was instructed to review
15 projected costs and timing. However, over the course of
16 the review, Staff did not believe it could recommend
17 recovery of any of these projects due to the uncertainty
18 of the projected or forecasted information. Staff did not
19 believe it could credibly recommend the Company' s
20 forecasted project costs until actual final project costs
21 were known and when Staff had sufficient time to
22 adequately review them.
23 Q. How was Staff instructed to review the projects
24 under $8 million?
25 A. For projects under $8 million that the Company
CASE NO. IPC-E-24-07 LOUIS, M. (Di) 15
11/06/24 STAFF

1 closed to plant-in-service prior to August 31, 2024,
2 Staff was instructed to examine a representative sample
3 of those projects to first verify whether they were in
4 service and then whether the project costs were prudent .
5 If a project was not yet in service or the project costs
6 incurred were not prudent, separate adjustments were
7 made .
8 For projects under $8 million that did not close to
9 plant-in-service by August 31, 2024, the Company was not
10 able to provide any individual project information for
11 Staff to review since the amounts were based on
12 simplistic forecasting methods using historic ratios as
13 discussed earlier. Because these project costs and
14 timing were neither known nor measurable, Staff was
15 instructed to recommend completely removing them through
16 Staff' s August 2024 AMA adjustment .
17 Q. Does this conclude your testimony in this
18 proceeding?
19 A. Yes, it does .
20
21
22
23
24
25
CASE NO. IPC-E-24-07 LOUIS, M. (Di) 16
11/06/24 STAFF

Professional Qualifications
Of
Michael Louis
Program Manager - Engineering
Idaho Public Utilities Commission
EDUCATION
Mr. Louis received his B. S . and M. S . degrees in Industrial
Engineering with concentrations in manufacturing systems and
engineering economics from Purdue University in 1985 and 1992,
respectively. He also received his Masters in Public Policy and
Administration at Boise State University in 2005 . In addition
to his formal education, Mr. Louis has attended Michigan State
University Institute of Public Utilities Annual Regulatory
Studies Program, NARUC Utility Rate School, and Electricity Grid
School .
BUSINESS EXPERIENCE
Mr. Louis is currently the Staff Engineering Program
Manager over the Engineering Section at the Idaho Public
Utilities Commission where he has supervised Staff and worked on
a variety of cases to regulate electric, natural gas, and water
utilities . His assignments and responsibilities include cases
involving prudence determination of major utility investments
and power supply cost, integrated resource plans, cost
adjustment mechanisms, reviews of power purchase agreements and
customer special contracts, demand-side management, sales of
utilities and their assets, avoided cost ratemaking for PURPA,
class and jurisdictional cost allocation using cost of service
principles, rate design, and a variety of engineering studies
involving the design and operation of public utility systems . I
have also served as the supervising lead in two General Rate
Cases .
Mr. Louis' work experience also includes 18 years of
industrial/commercial practice at General Motors, Hewlett-
Packard, Jabil Circuit, and Albertsons Companies developing,
managing, and improving manufacturing systems and operations,
planning processes, and supply chains . He has also spent six
years at Boise State University where he administrated and
conducted energy policy research as the Assistant Director of
the Energy Policy Institute and taught classes in program and
project management and Energy Policy in the Department of Public
Policy and Administration.
Exhibit No. 101
Case No. IPC-E-24-07
M. Louis, Staff
11/6/24

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS �+- DAY OF NOVEMBER 2024,
SERVED THE FOREGOING DIRECT TESTIMONY OF MICHAEL LOUIS, IN CASE
NO. IPC-E-24-07, BY &MAILING A COPY THEREOF TO THE FOLLOWING:
LISA D. NORDSTROM TIMOTHY TATUM
DONOVAN E WALKER CONNIE ASCHENBRENNER
MEGAN GOICOECHEA ALLEN MATT LARKIN
IDAHO POWER COMPANY IDAHO POWER COMPANY
PO BOX 70 PO BOX 70
BOISE ID 83707-0070 BOISE ID 83707-0070
E-MAIL: lnordstrom aidahopower.com E-MAIL: ttatumg
Jdahopower.com
dwalker a,idahopower.com caschenbrenneridahopower.com
mgoicoecheaallen(aidahopower.com mlarkin(cuidahopower.com
dockets Laidahopower.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 Lae isinsi hg t.com
E-MAIL: elo�echohawk.com
PETER J RICHARDSON DR DON READING
RICARDSON ADAMS PLLC 280 S SILVERWOOD WAY
515 N 27TH STREET EAGLE ID 83616
BOISE ID 83702 E-MAIL: dreading Lamindspring com
E-MAIL: peter xichardsonadams.com
BRAD HEUSINKVELD
ID CONSERVATION LEAGUE
710 N 6TH STREET
BOISE ID 83702
E-MAIL:
heusinkveld a idahoconservation.org
PETER MEIER EMILY W MEDLYN
US DEPT OF ENERGY US DEPT OF ENERGY
1000 INDEPENDENCE AVE SW 1000 INDEPENDENCE AVE SW
WASHINGTON DC 20585 WASHINGTON DC 20585
E-MAIL: peter.meier c hq.doe.gov E-MAIL: Emily.medlyn(c—v,hq.doe.gov
CERTIFICATE OF SERVICE

JIM SWIER AUSTIN RUESCHHOFF
MICRON TECHNOLOGY INC THORVALD A NELSON
8000 S FEDERAL WAY AUSTIN W JENSEN
BOISE ID 83707 KRISTINE A.K. ROACH
E-MAIL: jswierkmicron.com HOLLAND &HART LLP
555 17TH ST STE 3200
DENVER CO 80202
E-MAIL: darueschhoff(c�hollandhart.com
tnel son(c.,hollandhart.com
awjensen,hollandhart.com
karoach c,hollandhart.com
aclee(a hol l andhart.com
mamcmillen(cthollandhart.com
ED JEWELL STEVEN HUBBLE
DEPUTY CITY ATTORNEY BOISE CITY DEPT OF PUBLIC WORKS
BOISE CITY ATTORNEY'S PO BOX 500
PO BOX 500 BOISE ID 83701-0500
BOISE ID 83701-0500 E-MAIL: shubblegcityofboise.org
E-MAIL: etewellLa cityofboise.org
boisecityattorneyL,cityo fboise.org
n'd'o A
PATRICIA JORDAN, SjZRETARY
CERTIFICATE OF SERVICE