20241218Direct Donn English.pdf

RECEIVED
Wednesday, December 18, 2024 2:47:01 PM
IDAHO PUBLIC
UTILITIES COMMISSION
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE )
APPLICATION OF ROCKY ) CASE NO. PAC-E-24-04
MOUNTAIN POWER FOR )
AUTHORITY TO INCREASE ITS )
RATES AND CHARGES IN IDAHO )
AND APPROVAL OF PROPOSED )
ELECTRIC SERVICE SCHEDULES )
AND REGULATIONS )
DIRECT TESTIMONY OF DONN ENGLISH
IN SUPPORT OF THE STIPULATION
AND SETTLEMENT
IDAHO PUBLIC UTILITIES COMMISSION
DECEMBER 18, 2024

I Q. Please state your name and business address?
2 A. My name is Donn English. My business address is
3 11331 W. Chinden Blvd. , BLDG 8, STE 201-A, Boise, Idaho
4 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 a Program Manager overseeing
8 the Accounting and Finance Department in the Utilities
9 Division.
10 Q. Please describe your educational background and
11 professional experience .
12 A. I was hired by the Commission in 2003 and I have
13 provided testimony and recommendations in numerous
14 proceedings . My educational background and professional
15 experiences are provided in Exhibit No . 101 .
16 Q. What is the purpose of your testimony in this
17 proceeding?
18 A. The purpose of my testimony is to describe Rocky
19 Mountain Power' s ("Rocky Mountain" or "Company")
20 Application to increase its rates and charges for electric
21 service in Idaho, describe the proposed Settlement
22 Stipulation ("Settlement") reached by the parties in this
23 case, and explain Staff' s support for the proposed
24 Settlement .
25 Q. How is your testimony organized?
CASE NO. PAC-E-24-04 ENGLISH, D. (Stip) 1
12/18/2024 STAFF

I A. My testimony is organized under the following
2 headings :
3 Background Page 2
4 Staff Investigation Page 4
5 Settlement Evaluation Page 6
6 Settlement Overview Page 7
7 Background
8 Q. Please describe Rocky Mountain' s Application.
9 A. Rocky Mountain made its original filing with the
10 Idaho Public Utilities Commission on May 31, 2024,
11 requesting authority to increase its revenue by $92 . 4
12 million, or approximately 26 . 8 percent . The Company
13 requested to mitigate the proposed increase by phasing in
14 the base net power cost increase over two years . The
15 first-year increase of $66 . 7 million, or 19 . 4 percent,
16 would be effective on January 1, 2025, while a second
17 increase of $25 . 7 million, or 7 . 4 percent, would take
18 effect on January 1, 2026 . The Company' s proposed increase
19 was based on a historical twelve-month period ending
20 December 31, 2023, adjusted for known and measurable
21 changes through December 31, 2024 . The Company proposed a
22 hypothetical capital structure with 50 . 0 percent equity and
23 a return on equity of 10 . 3 percent, for an overall weighted
24 average cost of capital of 7 . 69 percent .
25 The Company' s Application reflected net power
CASE NO. PAC-E-24-04 ENGLISH, D. (Stip) 2
12/18/2024 STAFF

1 costs ("NPC") of $2 . 382 billion on a total-Company basis
2 and $136 . 7 million on an Idaho jurisdictional basis . The
3 Company also requested a modification to the sharing band
4 in the Energy Cost Adjustment Mechanism ("ECAM") so that 95
5 percent of the NPC variances will be passed through the
6 mechanism and the remaining five percent of the NPC
7 variances will be excluded. Additionally, the Company
8 proposed to remove the REC revenue adjustment from the ECAM
9 calculation and instead offer a new voluntary renewable
10 energy credit option tariff and new REC revenue adjustment
11 tariff.
12 Finally, the Company requested approval of two
13 proposals it claimed would help position itself to respond
14 to financial risk posed by the increasing frequency and
15 severity of wildfires impacting its service territory. The
16 first proposal was for an Insurance Cost Adjustment ("ICA")
17 to recover the costs for excess liability insurance through
18 a separate surcharge . The second proposal was to begin
19 recovery of a Catastrophic Fire Fund to create a multi-
20 state risk pool for potential catastrophic events where
21 third-party liabilities are in excess of the Company' s
22 insurance coverage .
23 Q. How was the case processed after the Company' s
24 Application was received?
25 A. The Commission issued a combined Notice of
CASE NO. PAC-E-24-04 ENGLISH, D. (Stip) 3
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1 Application and Notice of Intervention Deadline on June 20,
2 2024 . The Notice established an Intervention Deadline of
3 July 11, 2024 . Intervenor status was subsequently granted
4 to the Idaho Irrigation Pumpers Association, Inc. ("IIPA") ,
5 P4 Production L.L.C. an affiliation of Bayer Corporation
6 ("Bayer") , and Pacificorp Idaho Industrial Customers
7 ("PIIC") . The Idaho Conservation League also intervened,
8 but later withdrew from the case .
9 The Company, Staff, IIPA, Bayer, and PIIC
10 (collectively the "Parties") participated in two in-person
11 settlement conferences and several virtual meetings, and on
12 December 6, 2024, a comprehensive Settlement Stipulation
13 was filed with the Commission, signed by all parties .
14 Staff Investigation
15 Q. What type of investigation did Staff conduct to
16 evaluate the Company' s rate increase request?
17 A. Staff' s approach in any general rate case is to
18 extensively review the Company' s Application and associated
19 testimony, attachments, exhibits, and workpapers; identify
20 adjustments to its revenue requirement, revenue
21 normalization, rate spread, and rate design; and prepare to
22 file testimony for a fully litigated proceeding. There
23 were 18 Staff members analyzing this case, including
24 auditors, engineers, utility analysts, and consumer
25 investigators, and supervisors . Staff auditors reviewed
CASE NO. PAC-E-24-04 ENGLISH, D. (Stip) 4
12/18/2024 STAFF

1 the Company' s 2023 results of operations, 2024 capital
2 budgets, capital spending trends, operations and
3 maintenance ("0&M") expenses and trends and verified all of
4 the Company' s calculations and assumptions regarding the
5 overall revenue requirement . The auditors reviewed
6 thousands of transactions, selected samples, and performed
7 transaction testing in accordance with standard audit
8 practices . Staff reviewed the Company' s labor expense,
9 incentive plans, and employee benefits to ensure the
10 appropriate level of expenditures are included in rates .
11 Staff reviewed both completed and proposed
12 Company investments to determine the prudence of capital
13 additions . Expenditures including pension expense,
14 salaries, and 0&M expense were also examined.
15 Additionally, Staff evaluated the Company' s cost of
16 capital, capital structure, class cost of service, rate
17 spread, and revenue normalization. In total, Staff
18 propounded 286 production requests, performed onsite audits
19 in Portland and Salt Lake City, and held several virtual
20 meetings with Company personnel as a part of its
21 comprehensive investigation. Staff also reviewed the
22 Company' s responses to 198 production requests submitted by
23 intervening parties . Based on its investigation, Staff was
24 prepared to defend over 81 proposed adjustments to the
25 Company' s revenue requirement in testimony and at hearing.
CASE NO. PAC-E-24-04 ENGLISH, D. (Stip) 5
12/18/2024 STAFF

I Settlement Evaluation
2 Q. How did Staff determine that the overall
3 Settlement was reasonable?
4 A. In every settlement evaluation, Staff and other
5 parties must examine the risks of losing positions at
6 hearing and determine if the settlement agreement is a
7 better overall outcome . Staff must evaluate each
8 individual adjustment and determine the likelihood of the
9 Commission accepting or rejecting Staff' s rationale for the
10 adjustment . Ultimately, Staff' s intent in every settlement
11 conference is to negotiate the best possible outcome for
12 customers .
13 Q. Does Staff support the proposed Settlement as
14 reasonable?
15 A. Yes . After a comprehensive review of the
16 Company' s Application, thorough audit of the Company' s
17 books and records, and extensive negotiations with the
18 Parties to the case, Staff supports the proposed
19 Settlement . The proposed settlement is the result of
20 extensive negotiations with and compromises by of all the
21 Parties who often have conflicting interests . The proposed
22 Settlement offers a reasonable balance between the
23 Company' s opportunity to earn a reasonable return on its
24 investment and affordable rates for customers . Staff
25 believes the proposed Settlement, supported by the Parties,
CASE NO. PAC-E-24-04 ENGLISH, D. (Stip) 6
12/18/2024 STAFF

1 is in the public interest; fair, just, and reasonable; and
2 should be approved by the Commission.
3 Settlement Overview
4 Revenue Requirement
5 Q. Would you please describe the terms of the
6 proposed Settlement?
7 A. The proposed Settlement provides a reduction in
8 the Company' s requested revenue requirement . Instead of
9 the Company' s proposed base rate increase of $92 . 4 million,
10 or 26 . 8 percent, over two years, Idaho base rates would
11 increase by $57 . 94 million, or 16 . 8 percent, effective
12 January 1, 2025, with no additional base rate increase for
13 2026 . Additionally, the Parties agree to an estimated
14 $32 . 5 million reduction to the Company' s recovery of
15 deferred power costs in the SCAM effective simultaneously
16 with the base rate increase, for a net increase of $25 . 44
17 million, or 7 . 4 percent .
18 Q. How was the final revenue requirement determined?
19 A. The final revenue requirement was agreed upon
20 through intense negotiations with the Parties . The
21 derivation of the final revenue requirement is shown below:
22
23
24
25
CASE NO. PAC-E-24-04 ENGLISH, D. (Stip) 7
12/18/2024 STAFF

I (millions)
2 Requested Increase per Application $ 92 . 40
3 Change to Rate of Return - 7 . 250 $ (6 . 90)
4 Remove Catastrophic Fire Fund $ (11 . 10)
5 Reduce Net Power Costs $ (8 . 46)
6 Remove Susp. /Cancelled Projects $ (0 . 70)
7 Unspecified Adjustment $ (7 . 30)
8 Total Adjustments $ (34 . 46)
9 Total Revenue Requirement Change $ 57 . 94
10 Reduction to ECAM Recovery (est. ) $ (32 . 50)
11 Net Rate Change Jan 1 , 2025 (est. ) $ 25 . 44
12
13 Q. Please describe how the Settlement treats the
14 Company' s capital structure and rate of return .
15 A. The Settlement reduces the Company' s overall rate
16 of return from the proposed 7 . 69 percent to 7 . 25 percent .
17 The capital structure, cost of debt, and return on equity
18 are not specified in the Settlement . This adjustment
19 reduces the Company' s Application by $6 . 9 million.
20 Q. Please describe the provisions in the Settlement
21 as they relate to the Company' s rate base .
22 A. The Parties agree that the revenue increase in
23 the Settlement does not represent agreement or acceptance
24 by any Party on any specific revenue requirement
25 methodology. The Settlement is explicitly silent on the
CASE NO. PAC-E-24-04 ENGLISH, D. (Stip) 8
12/18/2024 STAFF

1 use of an average rate base methodology or a terminal
2 (year-end) methodology.
3 With regards to specific capital projects included in
4 the Settlement revenue requirement, the Parties agree that
5 the base rate includes recovery of the Gateway South and
6 Gateway West transmission projects, as well as the Rock
7 River I, Foot Creek II-IV, and Rock Creek I wind projects .
8 The Company agrees to file an attestation that the
9 transmission projects are in service prior to the rate
10 effective date . The Parties also agree that the Company' s
11 revenue requirement should be reduced by approximately
12 $700, 000 for projects included in the Company' s Application
13 that were either suspended or cancelled during 2024 .
14 The Parties reserve the right to review and provide
15 recommendations to the Commission in the Company' s next
16 general rate case on the recovery of capital costs
17 associated with a large transmission level line extension
18 in Oregon (Project Specialized) .
19 Lastly, the Parties agree to reduce the revenue
20 requirement proposed in the Company' s Application by $7 . 3
21 million for an unspecified ("black box") adjustment to
22 account for remaining issues in which no agreement was
23 explicitly reached, but rather as a compromise for all
24 Parties to accept the Settlement .
25 Q. Please describe the adjustment for the
CASE NO. PAC-E-24-04 ENGLISH, D. (Stip) 9
12/18/2024 STAFF

1 Catastrophic Fire Fund and any provisions in the Settlement
2 for Insurance Premiums?
3 A. In its application, the Company included $11 . 10
4 million for recovery through a surcharge for Idaho' s
5 participation in a proposed Catastrophic Fire Fund. The
6 Catastrophic Fire Fund would assist the Company with the
7 growing risk of wildfire liability and would be available
8 for the Company to pay large claims that exceed the
9 Company' s insurance coverage . In the Settlement, the
10 Company withdrew its proposal, and the stipulated revenue
11 requirement removes the $11 . 10 million from the Company' s
12 Application. However, the Company reserves the right to
13 propose the mechanism in a future proceeding.
14 Although there is no specific revenue requirement
15 adjustment for insurance premiums in the Settlement, the
16 Settlement creates an Insurance Cost Adjustment which will
17 allow the Company to recover the costs for excess liability
18 insurance . The Company will begin recovery of
19 approximately $9 . 8 million of excess liability insurance
20 premium costs and an additional $2 . 6 million of annual
21 deferred insurance premium amortization through the ICA.
22 Q. Please explain the adjustment to the Company' s
23 NPC .
24 A. The Company' s Application included total Net
25 Power Costs of $1 . 382 billion on a total system basis, or
CASE NO. PAC-E-24-04 ENGLISH, D. (Stip) 10
12/18/2024 STAFF

1 approximately $136 . 7 million on an Idaho-allocated basis,
2 which represents an increase of $1 . 015 billion, or 74
3 percent, compared to the NPC currently embedded in rates .
4 The NPC included in the Settlement updates the Company' s
5 total NPC based on the September 2024 Official Forward
6 Price Curve and completely removes costs associated with
7 the Washington Climate Commitment Act ("CCA") from base
8 rates . During the Company' s next ECAM filing, Staff will
9 review the SCAM deferral balance to ensure that Idaho
10 customers will not pay increased rates encumbered by the
11 CCA.
12 The total NPC agreed upon in the Settlement is
13 approximately $2 .228 billion on a system basis or $128 .24
14 million allocated to Idaho, which is a reduction to the
15 Company' s case of $8 . 46 million.
16 Q. Please explain the Reduction to ECAM Recovery
17 used to offset the base rate increase .
18 A. The Parties agree that the Company will reduce
19 the recovery of 2023 deferred SCAM balance approved in
20 Order No . 36207, Case No . PAC-E-24-05, by 50 percent to
21 offset the base rate increase in this case . The remaining
22 balance as of June 1, 2025, will be included with the 2024
23 ECAM balance and amortized and recovered over two years,
24 beginning June 1, 2025 .
25 Rate Spread and Rate Design
CASE NO. PAC-E-24-04 ENGLISH, D. (Stip) 11
12/18/2024 STAFF

1 Q. Please explain the rate spread and rate design
2 contained in the Settlement .
3 A. The Parties agreed to the rate spread provided in
4 Attachment B to the Settlement . The Parties agreed to use
5 the Company' s proposed class cost of service study, with a
6 cap of 110 percent and a floor of zero percent applied to
7 the base rate increase prior to the application of the ICA
8 and SCAM rate changes . No class of customer will see an
9 increase greater than 110 percent of the overall average
10 base rate increase, and no customer class will see a
11 decrease .
12 Q. Why does Staff support the proposed cap and floor
13 in the Settlement?
14 A. The Settlement was a compromise amongst all
15 Parties . The proposed cap and floor in the Settlement
16 provide for gradual movement towards cost of service while
17 also maintaining the balance necessary to achieve buy in
18 from all Parties . While other Parties may have been more
19 supportive of a uniform percentage increase, it was
20 important to Staff that rates move towards cost of service,
21 and the Settlement provides that movement .
22 Q. Are there any rate design issues in the
23 Settlement that you would like to discuss?
24 A. The Settlement accepts the Company' s proposed
25 rate design for all Schedules except Schedule 1
CASE NO. PAC-E-24-04 ENGLISH, D. (Stip) 12
12/18/2024 STAFF

1 (Residential) and Schedule 36 (Residential Optional Time of
2 Day) . Because the monthly Customer Service Charges are
3 subject to the Residential Rate Modernization Plan approved
4 in Order No . 35802, Case No . PAC-E-22-15, no additional
5 changes are proposed in the Settlement . The residential
6 monthly service charge will increase on June 1 each year of
7 the plan with commensurate decreases in Energy Charges .
8 Additional Settlement Terms
9 Q. Will you please describe the provisions contained
10 in the Settlement for the Rock Creek II wind project?
11 A. The Settlement provides a deferral for the
12 revenue requirement of the 400 MW Rock Creek II wind
13 project expected to be completed in September 2025 . In
14 lieu of filing a general rate case in 2025, the Parties
15 agree to allow the Company to defer into a regulatory asset
16 for later recovery the depreciation expense and return on
17 the project . The Rock Creek II project will create
18 production tax credits ("PTC") that will flow through the
19 ECAM to benefit customers . However, the Company will track
20 the PTCs associated with the project so they can offset any
21 potential disallowance on recovery of the deferral in a
22 future general rate case .
23 Q. Are there any other provisions in the Settlement
24 you would like to discuss?
25 A. While the Settlement contains many provisions
CASE NO. PAC-E-24-04 ENGLISH, D. (Stip) 13
12/18/2024 STAFF

1 that I did not discuss in detail, the Parties worked
2 collaboratively to pave a way forward on several
3 outstanding issues, including modifications to the SCAM,
4 the Company' s current hedging practices, and the treatment
5 of transmission level voltage line extensions .
6 The Company proposed to modify the ECAM sharing band
7 in its Application. While the Settlement maintains the
8 current 90/10 percent sharing band, the Parties agree to
9 host workshops to evaluate and explore alternative risk
10 sharing and incentive mechanisms .
11 The Company will also hold workshops with Staff and
12 other interested parties on the Company' s risk management
13 and hedging practices prior to the Company' s next general
14 rate case . Additionally, the Company will perform a study
15 on the costs and revenues associated with transmission
16 level voltage line extensions serving large individual
17 customers . Staff is concerned that transmission level
18 voltage lines used to serve individual customers or pockets
19 of customers are system-allocated when those line function
20 as distribution lines . The proposed study will help inform
21 Staff positions in future rate cases .
22 Q. Do you have any other comments on the proposed
23 Settlement?
24 A. Yes . Staff has reviewed Attachments A and B to
25 the Settlement and verified they are consistent with the
CASE NO. PAC-E-24-04 ENGLISH, D. (Stip) 14
12/18/2024 STAFF

1 agreement . The agreed upon rate design will offer the
2 Company a reasonable opportunity to recover the proposed
3 revenue requirement . As implied throughout this testimony,
4 the Settlement represents a fair, just, and reasonable
5 compromise of the positions put forth by all Parties and is
6 in the public interest . Therefore, Staff recommends the
7 Commission approve the Settlement without material changes
8 or modifications .
9 Q. Does this conclude your testimony?
10 A. Yes, it does .
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CASE NO. PAC-E-24-04 ENGLISH, D. (Stip) 15
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Professional Qualifications
of
Donn English
Program Manager - Accounting and Finance
Idaho Public Utilities Commission
EDUCATION
Mr. English graduated from Boise State University in 1998 with a
Bachelor of Business Administration degree in Accounting. His
studies concentrated on corporate finance and taxation. He was
a member of the Alpha Beta Psi honor society for Accounting
students . He completed the Annual Regulatory Studies Program,
the Advanced Regulatory Studies Program, and the Accounting and
Ratemaking Course offered through the Institute of Public
Utilities at Michigan State University. Additionally, he
regularly attends meeting and conferences sponsored by the
National Association of Regulatory Commissioners (NARUC) and the
Society of Utility and Regulatory Financial Analysts .
In 2001, Mr. English became a designated member of the American
Society of Pension Professionals and Actuaries (ASPPA) and was
awarded the professional designation of Qualified Pension
Administrator (QPA) and Qualified 401 (k) Administrator (QKA) .
Mr. English was also a member of the Association of Certified
Fraud Examinators .
BUSINESS EXPERIENCE
Prior to joining the Idaho Public Utilities Commission (IPUC) ,
Mr. English was a Trust Accountant with a pension
administration, actuarial, and consulting firm in Boise, Idaho .
In 1999, he was promoted to Pension Administrator, and in 2001
he was promoted to Pension Consultant . In that capacity, Mr.
English performed actuarial calculations and the required non-
discrimination calculations for hundreds of qualified retirement
plans . He completed and filed Form 5500s and represented
clients during audits by the Department of Labor and the
Internal Revenue Service . He also participated on the task
force that wrote questions for the ASPPA administrator and
actuarial exams .
Exhibit No. 101
Case No. PAC-E-24-04
D. English, Staff
12/18/2024 Page 1 of 2
2

Mr. English joined the IPUC in 2003 as a Staff Auditor. In
2016, he was promoted to Audit Team Lead, and in 2018 he became
the Program Manager for the Accounting and Finance Department
within the Utilities Division. From September 2020 - March
2022, Mr. English also accepted the responsibility of
supervising the Technical Analysis and Energy Efficiency team
and was the Program Manager for that team until 2022 . At the
Commission, Mr. English has audited numerous utilities including
electric, water, and natural gas companies, and provided
comments and testimony in numerous cases that deal with general
rates, tax issues, pension issues, depreciation and other
accounting issues, and other regulatory policy decisions . Mr.
English participates in the Energy Efficiency Advisory Groups
and External Stakeholder Advisory Committees for Idaho Power,
Avista Utilities, Rocky Mountain Power, and Intermountain Gas
Company. He is a member of several of the National Association
of Regulatory Utility Commissioners (NARUC) working groups
including the NARUC State Working Group on Performance-Based
Regulation, the NARUC State Working Group on Electric Vehicles,
and the NARUC State Working Group on Grid-Interactive Efficient
Buildings in collaboration with the National Association of
State Energy Officials (NASEO) . Mr. English is the Chair of the
NARUC Staff Subcommittee on Education and Research and the Vice
Chair of the NARUC Staff Subcommittee of Accounting and Finance .
Mr. English is also a faculty member of NARUC Rate School .
Exhibit No. 101
Case No. PAC-E-24-04
D. English, Staff
12/18/2024 Page 2 of 2
2

CERTIFICATE OF SERVICE
-N."I HEREBY CERTIFY THAT I HAVE THIS �1 OF DECEMBER 2024,
SERVED THE FOREGOING DIRECT TESTIMONY OF DONN ENGLISH IN
SUPPORT OF THE STIPULATION AND SETTLEMENT, 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.aldernpacificorp.com Portland, OR 97232
E-MAIL: josgph.dallas(cTpacificorp.com
carla.scarsella(&Pacificorp.com
DATA REQUEST RESPONSE CENTER
E-MAIL ONLY:
datareg uestApaci 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: lancekae isinsi hg t.com
E-MAIL: elo rr,echohawk.com
BRAD HEUSINKVELD
ID CONSERVATION LEAGUE
710 N 6TH STREET
BOISE ID 83702
E-MAIL:
heusinkveld(ccidahoconservation.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(&racineolson.com CHESTERFIELD MO 63017
E-MAIL: bcollinskeonsultbai.com
gmeyerA 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: khigginsAenergystrat.com BOISE ID 83701
ntownsend(c4)energystrat.com E-MAIL: rwilliams(&hawleytroxell.com
bhel eson lhawleytroxell.com
CERTIFICATE OF SERVICE Page 1 of 2

Electronic Service Only: Electronic Service Only:
BRADLEY MULLINS VAL STEINER
MW ANALYTICS ITAFOS CONDA LLC
E-MAIL: [e-mail] E-MAIL: Val.steiner&itafos.com
Electronic Service Only:
KYLE WILLIAMS
BYU Idaho
E-MAIL: williamsk@byg1.x u
PATRICIA JORDA CRETARY
CERTIFICATE OF SERVICE Page 2 of 2