20160928INT to Staff 25-34.pdf

WILLIAMS BRADBURY
ATTO R NEYS AT LAW RECE IVED
201& SEP 28 P 3: l}2
September 28, 2016
Jean D. Jewell
Commission Secretary
Idaho Public Utilities Commission
472 W. Washington Street
Boise, ID 83 702
RE: IGC Response to Staff's Second Request for Production -Case No. INT-G-16-02
Dear Ms. Jewell:
Enclosed for filing with the Commission are one original and two conformed copies of
Intermountain Gas Company's Corrected Response to Staffs Second Request for Production,
and one CD-ROM that contains the answers and attachments.
By separate confidential CD, please find the responses to staff request No. 33.
Please direct any questions related to the transmittal of this filing to Mike McGrath at 208-
377-6168.
Sincerely,
Ronald L. Williams
Attorney at Law
RLW
1015 W. Hays Street -Boise, ID 83702
Phone: [phone] -Fax: [phone] -www.williamsbradbury.com
Ronald L. Williams, ISB No. 3034
Williams Bradbury, P.C.
1015 W. Hays St. ?1J1(, ('.,...,J ?8 P~1 3: '-2 "·' 1u '"·'-~I c.. 1 r y.
Boise, ID 83702
Telephone: [phone]
Email: [e-mail]
Attorneys for Intermountain Gas Company
BEFORE THE IDAHO PUBLIC UTILITES COMMISSION
IN THE MATTER OF INTERMOUNTAIN GAS )
COMPANY'S APPLICATION TO CHANGE )
ITS RA TES AND CHARGES FOR NATURAL )
GAS SERVICE )
)
)
_________________ )
Case No. INT-G-16-02
RESPONSE OF INTERMOUNTAIN
GAS COMPANY TO SECOND
PRODUCTION REQUEST OF THE
COMMISSION STAFF
COMES NOW, Intermountain Gas Company, and in response to the Second Production
Request of the Commission Staff to Intermountain Gas Company dated September 7, 2016,
herewith submits the following information:
REQUEST NO. 25: Please provide a detailed explanation for the difference between the
Total RS Margin of $60,988,492 on line 6 of Exhibit No. 27, and the $56,830,872 Distribution
Revenue Requirement found on page 4 of Exhibit No. 20.
RESPONSE TO REQUEST NO. 25:
As the following table illustrates, the differences between the total RS Margin on Exhibit No.
27 and the Distribution Revenue Requirement found on page 4 of Exhibit No. 20, result from the
fact that more than just Distribution Revenue Requirement is being included in the RS Margin on
Exhibit No. 27. The Distribution Revenue Requirement only addresses the revenue necessary to
cover expenses associated with moving gas from the city gate or farm taps of Northwest Pipeline or
RESPONSE OF IGC TO SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF Page I
Intermountain 's own larger diameter transmission pipelines. See Hart Gilchrist's testimony
beginning on page 3 and Exhibit No. 2, p. 2 for a more in depth description of Intermountain 's
distribution system.
Transmission Revenue Requirement addresses the costs necessary to move natural gas on
Intermountain 's large diameter transmission pipelines. Storage Revenue Requirement seeks to
recover the costs associated with Intermountain 's LNG facility at Nampa and satellite LNG facility
in Rexburg. Other Revenue is also removed from the required revenue, as seen on Exhibit No. 20,
p . 2, Line 14. All of these items are included in the RS Margin on Exhibit No. 27.
Line Description Reference
1 Total RS Margin Exhibit No. 27, Line 6
2 Distribution Revenue Requirement Exhibit No. 20, p. 4
3 Transmission Revenue Requirement Exhibit No. 20, p. 4
4 Storage Revenue Requirement Exhibit No. 20, p. 4
s Other Revenue Exhibit No. 20, p. 2, Line 14
6 Total Revenue Requirement
7 Difference
8 Difference from Rate Design Exhibit 24, p. 4, Line 133
Record Holder: ---=-M-=i=k-=-e -=M=c~G=r=at=h~; ~2~0-=-8--=-3~7~7~-6'--'0-=-0-=-0 __
Location: -----=5=5-=-5--=S=---=C-=-o=le--=R=-d=,c..:cBcc..co=i=se=, """ID=---a8=3--'-7-=-0-=--7--
Sponsor/Preparer: Lori Blattner; 208-377-6000
Amount
$ 60,988,492
$ 56,830,872
3,866,972
2,338,038
(2,048,327)
$ 60,987,555
$ 937
$ 937
REQUEST NO. 26: Please describe in detail the components of the capacity, customer,
and commodity related revenue requirements for the storage, transmission, distribution and gas
functional groups shown on page 4 of Exhibit No. 20.
RESPONSE OF JGC TO SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF Page 2
RESPONSE TO REQUEST NO. 26:
All of Intermountain 's costs are assigned to one of three classifications based on the
characteristics of the cost. These classifiers are capacity, customer and commodity. Both Exhibit
Nos. 21 and 22 show how each account has been assigned to these three different classifications.
Customer costs are costs that are incurred to extend service to a customer, attach the customer to
the distribution system, meter any gas usage and maintain the customer 's account. Examples of
costs classified as customer related include the Rate base account Distribution Meters and the
O&M account Maintenance of Meters/House Regulators.
Capacity costs are those costs associated with a plant that is designed, installed and
operated to meet maximum hourly or daily gas flow requirements. Examples of costs classified as
capacity include Rate base account Transmission Mains, and the O&M account Maintenance of
Mains.
Commodity costs are those costs that vary with the throughput sold to, or transported for,
customers. These costs are not addressed in the general rate case, but are ruled on each year as
part of Intermountain 's PGAfilings.
Record Holder: Mike McGrath; 208-377-6000
Location: 555 S Cole Rd, Boise, ID 83707
Sponsor/Preparer: Lori Blattner 208-377-6000
REQUEST NO. 27: Please provide the data and workpapers used to develop the regression
equations described on pages 3-5 of Ms. Blattner' s testimony.
RESPONSE OF IGC TO SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF Page 3
RESPONSE TO REQUEST NO. 27:
The regression equations used for weather normalization and described on pages 3-5 of Ms.
Blattner 's testimony follow the methodology outlined in lntermountain 's previous weather
normalization case, U-1034-134.
The data used in developing the models can be found on the attached CD under the PR 27
folder \Data. The files are:
PR 27 RSI data.xlsx
PR 27 RS2 data.xlsx
PR 27 GS data.xlsx
The workpapers used in developing and selecting the final models are included in the PR 27
folder \Workpapers. The file "PR 27 Model Test.xlsx " includes notes on the statistical validity of
the models, as well as a review of how the models would have performed under actual weather
conditions measured against actual usage for the previous five year period. It is also important to
test the models against data that was not included in the model development. This workbook shows
that test for the first four months of 2015. Additionally, the Company reviewed how well the models
normalized data for the first six months of 2016 in preparation for filing this case. That analysis is
shown in the file "PR 27 Weather Normalization Reconciliation.xlsx ".
The weather normalization models and methodology are regularly reviewed by Ph.D.
statisticians to ensure that the methods follow accepted statistical practice as well as the process
approved in case U-1034-134, and that they are appropriate for weather normalization. The
opinion letter resultingfrom that review was included in the case as Exhibit No. 18. Included here
are the items sent to the consultants (in addition to the items provided above) that assisted them in
their analysis (See "PR Consultant Review.pd/''). Also included as "PR 27 Final Models.pd/'' are
the final models used by lntermountain for weather normalization.
RESPONSE OF IGC TO SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF Page 4
Record Holder: Mike McGrath; 208-377-6000
Location: 555 S Cole Rd, Boise, ID 83707
Sponsor/Preparer: Lori Blattner; 208-377-6000
REQUEST NO. 28: Please describe the method and provide the workpapers used to weigh
customer weather data described on page 4 of Ms. Blattner's testimony.
RESPONSE TO REQUEST NO. 28:
The data used to weight the weather data by customers (which is referred to in this response
as "Rate Study ") is stored in a clustered Sq/Server database. Data is imported and processed by
Sq/Server jobs running on the production server. All code used by Rate Study is stored on the
secured production server. The code consists of stored procedures, functions and views.
Sq/Server Jobs to collect external data:
Rate Study -Import Actual Temps
Rate Study -Import Billing Data
The section highlighted by dashed lines in Chart I on the following page represents the
stored procedure that calculates the normalized temperatures. The weighting is calculated through
a series of database views (SQL code) using billing data and normalized temperature data. The
final weighted weather is weighted by the proportion of customers in each weather region and
billing cycle.
The following flowchart shows the weighting process:
RESPONSE OF IGC TO SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF Page 5
PR#28 Chart 1
Calculate Nonna! Weather c1s::J
ruk:ulate_normal_temps_ev<~_d.Jt•-1----------------
Bll.L LEAP YEARS DATES
• ~ BILL DATE YEARS V
tmtmpll(l'mal )-H ~•::mM BJLL ----1 )----. BJLL
DATA VIEW DATAS\JMMAR'f_Y -NORMAi. TEMPS with dates -cldtespatch
I I •
ln!i tmpnormat \ TMP NORMAL TEMPS VIEW -J wtlH DATES <'Ide dote
1 1 _____ ----------------------------
BJLL TMP NORMAL TEMPS
DATA Wf(GKTED_Y CYCLE DA.Tr
I VlE\V I
1
TMP NORMAL TEMPS
WEIGTEO CYQ.E 1------1 VIEW )----. DATf_V
Record Holder: ---=M=ik=e--=-M=c-=--G=r=a=th=;-'2-=--0-=8-'-3'-'7--'-7--6-=--0'-'0'-"-0 __
Location: -----=5=5-=-5--"S"----=Co=lec...:R=d=,..:B=...:o==i=se=,-=ID=---=8=3_,_7_,,_0--'--7-
Sponsor/Preparer: --'L=-o=-=rc.=...i =B-=la=tt=n=e=r ,...__2=-0-=--8~-~3~77~--=6-'-0~00~--
NORMAL TEMPS
WEIGTED_V
REQUEST NO. 29: The Company provides different customer counts in its Application
and throughout the testimony of several witnesses. Please explain the following discrepancies,
particularly how any corrections might impact the proposed rates:
• Application at pg. 2 334,650
• Kivisto Direct at 2, ln. 14 339,000
• Madison Direct at 2, ln. 9 334,650
• Gilchrist Direct at 5, Ins. 2, 3 334,650
• Gaske Direct at 4, ln. 13 320,000
• Blattner Workpaper No. 8 338,798
RESPONSE OF IGC TO SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF Page 6
RESPONSE TO REQUEST NO. 29:
The different customer counts provided in the Application and direct testimony of several
Company witnesses were for illustrative purposes (see excerpts of the Company 's Application and
testimonies below) and none of the numbers referenced on the previous page were used in the
determination of the Company 's proposed rates. The Company used fore casted 2016 customer
counts in the determination of its proposed rates.
The customer count of 3 3 4,650 cited in the Application and in the testimony of Company
witnesses Madison and Gilchrist is the average number of customers at December 31, 2015. Ms.
Kivisto 's reference to 339,000 customers is taken from the Company 's average customer count at
the end of the first quarter of 2016. Mr. Gaske 's customer count reference of 320,000 was an
approximation used to make a general comparison with the proxy companies in his analysis. The
customer count of 338, 798 attributed to Ms. Blattner is from Workpaper No. 8 of the Company 's
October 1, 2016 Purchased Gas Cost Adjustment filing and represents actual residential and
commercial customers as of January 31, 2016.
As mentioned previously, the determination of the proposed rates are not affected by the
different customers counts mentioned above. The Company used 2016 annualforecasted customer
counts in the determination of its revenue requirement, cost of service, rate design, and Fixed Cost
Collection Mechanism.
The Company apologizes for any confusion that may have been caused by referencing
different customer counts used for illustrative purposes as noted below.
Excerpts from Application and Testimony:
Application, p. 2: "lntermountain provides natural gas service in southern Idaho to 75 communities
in Idaho and approximately 334,650 customers."
RESPONSE OF IGC TO SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF Page 7
Kivisto, p.2: "The rate increase of$10.2 million being requested in this filing is necessary for the
Company to continue to provide quality service to its 339,000 customers in Idaho and to improve
service by investing in new and replacement infrastructure. "
Madison, p.2: "lntermountain provides natural gas distribution services to 75 communities in
Idaho, with 243 dedicated employees. During 2015, lntermountain had an average of 334,650
customers in Idaho and the Company's headquarters are located in Boise, Idaho. "
Gilchrist, p. 5: "The Company 's current customer base consists of 302, 790 residential customers
and 31,860 commercial customers."
Gaske, p.4: "lntermountainprovides natural gas distribution service to approximately 320,000
customers in 75 communities in Southern Idaho, operating 290 miles of transmission lines and
6,216 miles of distribution mains. "
Blattner, Workpaper No.8: This is from the Company 's October 1, 2016 Purchased Gas Cost
Adjustment filing.
Record Holder: ----=-M=1=·k=-e--=-M=c=...cG=r=a=th=-; ---'2~0-=-8---'-3C...C.7--'-7--6"-'0'-"0--=-0-­
Location: ------'-5~5~5~S_C_o_l_e_R_d~, _8_01_· s_e,~I_D_8_3_7_0_7 __
Preparer: _ ____,J=a=c-=-ob=-=D--"a=rr=in=g=to-=n=,c...=2'--"0-=-8~-3~7~7--6~0~0'--'0 ___ _
Sponsor:_-----'M=ik=e::....:M=c..::c:G=ra=t=h;'-=2-"-'08=----=-3-'--77-'----=-6-=-00"-'0=--------
REQUEST NO. 30: Hart Gilchrist suggests in his testimony that the Infrastructure Cost
Recovery Mechanism (ICRM) would be a better way to fund and replace pipeline infrastructure.
Please explain how the ICRM mechanism would have changed the Company's pipeline
replacement practices incorporated into this case. Gilchrist Direct at 15, lines 5-7.
RESPONSE OF JGC TO SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF Page 8
RESPONSE TO REQUEST NO. 30:
An ICRM would not have changed the Company 's pipeline replacement practices prior to or
during the pendency of this case. Current Company pipeline replacement practices are in keeping
with Industry best practices. However, with an ICRM, the Company would be able to implement an
accelerated pipeline replacement program. As it currently stands, identified pipeline replacement
projects under DIMP take precedence and may delay other important capital projects in the capital
budgeting process.
With an ICRM, pipeline replacement would be independent of the Company 's capital budget
and would allow the Company to work with the IP UC to gain approval for designated pipeline
replacements. Additionally, ICRM would facilitate an accelerated pipeline replacement program
identified by DIMP.
Record Holder: Mike McGrath; 208-377-6000 ----"'-'=~~~~~~~~~~--
Location: -----=5:....::5--=-5-=S=---=C--=-o=le-=R=d=,c...=B=c..coc...=i=se=,-=ID=-.,8:....::3-'--7-=-0-'---7 __
Sponsor/Preparer: -~H=a~rt~G_il_c_hr_i_st~, _20_8_-_3_77_-_6_0_00 __ _
REQUEST NO. 31: Hart Gilchrist states in his testimony that " ... Intermountain is using
a systematic approach to identify the elevated risk pipe segments .... " Please describe the
Company's approach to prioritizing pipeline replacements. Gilchrist Direct at 15, lines 17-18.
RESPONSE TO REQUEST NO. 31:
The Company utilizes a GIS based risk model through its Distribution Integrity
Management Program (DIMP) where various "likelihood of failure " and consequence factors
are used to identify and assign risk to all of the Company 's distribution pipelines. The calculated
risk values are then used to help prioritize what specific sections of pipe are planned for
replacement. The Company then uses performance measures to help identify the effectiveness of
the replacement program and makes adjustments to the program as necessary. Adjustments may
RESPONSE OF IGC TO SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF Page 9
include increasing the amount of annual footage being replaced or adjusting the risk model
algorithms.
Record Holder: ___ M_1_·k_e_M_c_G_r_a_th~; _2_0_8_-3_7_7_-6_0_0_0 __
Location: ____ _,5~5~5_S~C~o~le~R~d=,~B~o~i~se~,~I~D_8~3~7~0-'-7 __
Sponsor/Preparer: _ _,H=art~G=il=-=c=hr=-=i=st;...., =2..::;_08=--~3-'-7-'---7-_e:6;...::;0-=-0..::...0 __ _
REQUEST NO. 32: David Swenson states in his testimony that the Company educates
customers regarding the economic and operational value of properly setting the Maximum Daily
Firm Quantity (MDFQ). Please describe how the Company educates customers about MDFQ and
include any applicable publications, instructions, or other documentation. Swenson Direct at 8,
lines 10-13.
RESPONSE TO REQUEST NO. 32:
Taking steps to educate the large volume customers relative to their MDFQ not only helps
those customers ensure they obtain their needed level of peak day capacity but, at the same time,
affords the Company opportunity to more efficiently manage its finite delivery capacity resource
therefore lowering costs for all customers.
Whether by email, telephone or in person, Intermountain takes advantage of opportunities to
educate customers about the importance of the customer 's MDFQ. Attachment PR32-l shows an
example of an email exchange with a customer and the customer 's Marketer relating to the
customer 's MDFQ (note: all identifying information has been redacted). It is difficult to specifically
identify the many face-to-face discussions or telephone discussions but the following will outline the
general process for educating the customer as to their contracted MDFQ and will also identify
some tools used in this process.
RESPONSE OF IGC TO SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF Page 10
lntermountain makes efforts to remind customers of the purpose of the MDFQ and has
developed several tools to help both the company and the customer to accurately project peak day
usage. One of those tools is the "Customer Load Summary" or CLS (see file labeled PR#32-
Customer Load Summary) and it is particularly valuable when dealing with new customers or
existing customers anticipating changes in loads due to additional or replacement equipment.
The CLS solicits customer input relating to all gas-fired equipment. Once the company
analyzes and validates the provided CLS data, it can determine an estimate of the maximum amount
of natural gas a customer can use on an hourly or daily basis. The Company also utilizes actual
peak day data when establishing the customer 's contract MDFQ. For new customers, where actual
data is unavailable, the CLS data is utilized to help set the initial contract MDFQ.
In the included CD, file name PR#32-3-Customer Analysis Sample is an actual analysis
shared with a customer (customer identification removed) reflecting the customer 's contract MDFQ
vs. their actual historical usage. This type of analysis helps the customer visualize any difference
between current and desired MDFQ and tends to result in mutually determined outcomes.
Large volume customers have an interest in making sure the MDFQ is correct and this
interest has heightened since the Company 's proposed demand charge. Jntermountain has,
therefore, prepared an analysis that compares billing under current and proposed general case
prices which is particularly effective in showing the financial effect of an MDFQ that does not
reflect the customer 's actual natural gas needs. The Company believes that basing the demand
charge on the customer 's MDFQ will ensure that customers and the Company are equally
committed to contract negotiations and this analysis helps the customers understand the financial
and operational impact that the MDFQ will have on its business.
Record Holder: Mike McGrath; 208-377-6000 --~=~~~~~~~~~~--
Location: -----=5:...::5--=5-=S:;__.=C--=o=le'-'R=-=d=,'--=BCC....o=-=i=-se""",--=I=D---'8=3--'-7--=0-'--7 __
RESPONSE OF JGC TO SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF Page 11
Sponsor/Preparer: __ D==av-'-1=· d:....:S=--w'-'--=en=s:..=o=n"-, =20-=-8=---..::c3-'-7-'-7-=-6'--"0:....::0=0 __
REQUEST NO. 33: Lori Blattner's testimony references a Cost of Meters Study in her
testimony. Please provide the Cost of Meters Study in executable electronic format with formulas
intact. Blattner Direct at 13, lines 4, 5.
RESPONSE TO REQUEST NO. 33:
Please see detailed response included in the CD-File Name PR#33-2015 Meter Study. Responses
to this request involve confidential and proprietary information of Intermountain and are contained
on a CD identified as such.
Record Holder: ---=-M-=-1=·k-'-e_M_c_G_r_a_th=; --'2~0-=-8-=-3--'7_7_-6~0~0-'-0 __
Location: ____ ....:::.5..:..5.=c..5-=S_C=--o=l-=-e =-R=d"-, B=o1=· s~e,<-=I=D_8=3'-'-7-=-0-'-7 __
Sponsor/Preparer: _....:.L=o=rc.:...i =B=la=tt=n=e=r,-=2=0=8-=-3::....:7--'-7--6"'-'0""'0'-"0'-----
REQUEST NO. 34: Lori Blattner's Exhibit No. 19 references a 2015 Mains Study. Please
provide a copy of the 2015 Mains Study in executable electronic format with formulas intact.
RESPONSE TO REQUEST NO. 34:
Please see detailed response included in the CD-File Name PR #34-2015 Main Study.
Record Holder: __ ....:::.M=1=·k=e-=-M=-c=--G=r=a=th=;-=2=-=0c..=8-=-3:....:7-'-7_-6::....:0:....::0=0-­
Location: ----~5=5..:::..5...:::S'--'C=o=l=e-=-R=d:.,_, =B=o=is=e,'-"I=D'--'8=3:....:7-..:::0-'-7 __
Sponsor/Preparer: ---'L=or=i-=B=l=at=tn=e=r~, =20-=-8=----=-3-'-7-'-7-=-6:....:0:....::0-=-0 __ _
RESPONSE OF IGC TO SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF Page 12
DATED at Boise, Idaho, this 2f> day of September, 2016.
Ronald L. Williams
Williams Bradbury, P.C.
Attorneys for Intermountain Gas Company
RESPONSE OF IGC TO SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF Page 13
CERTIFICATE OF DELIVERY
I HEREBY CERTIFY that on this 28th day of September, 2016, I caused to be served a
true and correct copy of the Response of Intermountain Gas Company to Second Production
Request of the Commission Staff upon the following individuals in the manner indicated below:
Hand Delivery: (original and 2 copies)
Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
472 W. Washington Street
Boise, ID 83 720
Michael P. McGrath
Intermountain Gas Company
555 S. Cole Road
Boise, ID 83 707
E-Mail : [e-mail]
Brad M. Purdy
2019 N. 17th Street
Boise, ID 83 702
E-Mail : [e-mail]
Attorney for Community Action
Partnership Association of Idaho (CAP Al)
Benjamin J. Otto
Idaho Conservation League
710 N. 6th Street
Boise, ID 83 702
E-Mail: [e-mail]
F. Diego Rivas
NW Energy Coalition
1101 8th A venue
Helena, MT 59601
E-Mail: [e-mail]
Edward A. Finklea
Northwest Industrial Gas Users (NWIGU)
545 Grandview Drive
Ashland, OR 97520
E-Mail: [e-mail]
D Hand Delivery
~ US Mail (postage prepaid)
D Facsimile Transmission
D Federal Express
~ Electronic Transmission
D Hand Delivery
~ US Mail (postage prepaid)
D Facsimile Transmission
D Federal Express
~ Electronic Transmission
D Hand Delivery
~ US Mail (postage prepaid)
D Facsimile Transmission
D Federal Express
~ Electronic Transmission
D Hand Delivery
~ US Mail (postage prepaid)
D Facsimile Transmission
D Federal Express
~ Electronic Transmission
D Hand Delivery
~ US Mail (postage prepaid)
D Facsimile Transmission
D Federal Express
~ Electronic Transmission
,-----------------------------·----·--·-·
Chad M. Stokes
Tommy A. Brooks
Cable Huston LLP
1001 SW Fifth Avenue, Ste. 2000
Portland, OR 97204-1136
E-Mail: [e-mail]
[e-mail]
Attorneys for NWIGU
Michael C. Creamer
Givens Pursley LLP
601 W. Bannock Street
Boise, ID 83702
E-Mail: [e-mail]
Attorneys for NWIGU
Scott Dale Blickenstaff
The Amalgamated Sugar Company LLC
1951 S. Saturn Way, Ste. 100
Boise, ID 83 702
E-Mail: [e-mail]
Peter Richardson
Gregory M. Adams
Richardson Adams, PLLC
515 N. 27th Street
Boise, ID 83 702
E-Mail: [e-mail]
[e-mail]
Attorneys for The Amalgamated Sugar
CompanyLLC
Ken Miller
Snake River Alliance
223 N. 6th St., Ste. 317
P.O. Box 1731
Boise, ID 83701
E-Mail: [e-mail]
D Hand Delivery
~ US Mail (postage prepaid)
D Facsimile Transmission
D Federal Express
~ Electronic Transmission
D Hand Delivery
~ US Mail (postage prepaid)
D Facsimile Transmission
D Federal Express
~ Electronic Transmission
D Hand Delivery
~ US Mail (postage prepaid)
D Facsimile Transmission
D Federal Express
~ Electronic Transmission
D Hand Delivery
~ US Mail (postage prepaid)
D Facsimile Transmission
D Federal Express
~ Electronic Transmission
D Hand Delivery
~ US Mail (postage prepaid) D Facsimile Transmission
D Federal Express
~ Electronic Transmission
Ronald L. Williams