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HomeMy WebLinkAbout20170117INT to Staff Redacted Amended 178.pdfWILLIAMS · BRADBURY ATTO R NEYS A T LAW January 17, 2017 Ms. Diane Hanian Idaho Public Utilities Commission 4 72 West Washington Post Office Box 83720 Boise, Idaho 83720-0074 Re: Intermountain Gas Company, IPUC Case No. INT-G-16-02 Amended Response to Staff Request No. 178 Dear Ms. Hanian: REC EIV ED .. ' ' ., Enclosed for filing with the Commission are one original and three conformed copies of Intermountain Gas Company's Amended Response to Staffs Eighth Production, Request No. 178. By separate and confidential CD, please find additional information regarding Request No. 178 that is confidential and proprietary. If you should have comments or questions regarding this filing, please contact Michael P. McGrath (377-6168) or me (344-6633). Sincerely, A Wt 1,v W"- Ronald L. Williams Williams Bradbury, P.C. Attorney for Intermountain Gas Company cc: Michael P. McGrath Enclosure 1015 W. Hays Street -Boise, ID 83702 Phone: 208-344-6633 -www.williamsbradbury.com Ronald L. Williams, ISB No. 3034 Williams Bradbury, P.C. 1015 W. Hays St. Boise, ID 83 702 Telephone: (208) 344-6633 Email: ron@williamsbradbury.com Attorneys for Intermountain Gas Company REC EIV ED 7r , l 1 :; i ! I 7 r •. ID= '-4 -V,. "", ,l I J 4 BEFORE THE IDAHO PUBLIC UTILITES COMMISSION IN THE MATTER OF INTERMOUNT AIN GAS ) COMPANY'S APPLICATION TO CHANGE ) ITS RA TES AND CHARGES FOR NATURAL ) GAS SERVICE ) ) ) _________________ ) Case No. INT-G-16-02 AMENDED RESPONSE OF INTERMOUNTAIN GAS COMPANY TO REQUEST NO. 178 OF THE COMMISSION STAFF COMES NOW, Intermountain Gas Company, and amends its response to Request No. 178 of the Commission Staff to Intermountain Gas Company dated January 17, 2017, herewith submits the following information: AMENDED RESPONSE TO REQUEST NO. 178: The attached amended Exhibits includes Exhibit No. 12, Page 1; Exhibit No. 13, Pages 1, 2, 5 and 6; Exhibit No. 14, Page 1; Exhibit No. 15, Pages 24 and 25; and Exhibit No. 16, Page 1. These amended Exhibits correct for errors discovered after the filing of the Company's original response to Staff's Production Request No. 178. The Company made adjustments to the Exhibits referenced above to correct for an accounting error pertaining to the Commission approved depreciable lives for the following asset classes: 391 -Office Furniture and Equipment, 394 -Tools, Shop, Garage Equipment, and 397 -Communication Equipment. The error originated in January 2015, was discovered in late October 2016 and was corrected for in December 2016. The resulting adjustments to plant-in- service, accumulated depreciation, cash working capital, accumulated deferred income taxes, depreciation expense, and income tax expense can be seen on the above mentioned Exhibits. Please note that the adjustment to the Company 's rate base corrects test year-end rate base for the cumulative impact of the error, however, the adjustment to depreciation expense reflects only that amount of overstated depreciation that occurred during the test year of 2016. In addition to the above corrections, the Company has also made adjustments to correct for an inconsistency between Exhibit No. 15, Pages 24 and 25 and the Company's books and records. When Exhibit No. 15, Pages 24 and 25 were originally produced, the Company inadvertently included the effect of Idaho Investment Tax Credits ("ITCs'') in the calculation of its state current income tax expense. The corrected Exhibit 1) removes the effect of Idaho ITCs to match the Company's accounting treatment on its books and records and, 2) updates the estimated ITC amortization to reflect actual ITC amortization, net of recapture amortization and federal tax effect. The net effect of the above adjustments is a lowering of the Company 's Revenue Requirement. Please see confidential Disk "Amended Exhibits 12-16 Selected pages.xlsx " Record Holder: Mike McGrath, 208-377-6000 Location: 555 S Cole Rd, Boise, ID 83707 Sponsor/Preparer: Ted Dedden, 208-377-6000 Sponsor/Preparer: Jacob Darrington, 208-377-6000 DATED at Boise, Idaho, this 17th day of January, 2017. Respectfully submitted, Ronald L. Williams Williams Bradbury, P.C. Attorneys for Intermountain Gas Company Line No. 2 3 4 5 6 7 8 9 10 lntermountain Gas Company Rate Base -13-Month Average For the Test Year Ending December 31 , 2016 September Company Update Retirement Adjusted Descrietion Rate Base[1J Adjustment[2l Rate Base (a) (b) (c) (d) Gas Plant in Service: Original Cost13l $ 594,848,972 $ (143,029) $ 594,705,943 Less Accumulated Depreciation14l {307,142,320) 189,090 {306,953,230) Net Gas Plant in Service 287,706,652 46,061 287,752,713 Materials & Supplies Inventory 3,195,291 3,195,291 Liquid Natural Gas Storage Inventory 3,225,344 3,225,344 Cash Working Capital15l 1,137,743 6,245 1,143,988 Accumulated Deferred Income Taxes16l (49,961,992) (14,431) (49,976,423) Advances in Aid of Construction {8,022,512) {8,022,512) Rate Base $ 237,280,526 $ 37,875 $ 237,318,401 NOTES [1] These amounts match the Company's updated rate base and revenue requirement which was filed in response to IPUC Staff Production Request No. 178. [2] This adjustment corrects for an accounting error pertaining to the Commission approved depreciable lives for the following asset classes: 391 -Office Furniture and Equipment, 394 -Tools, Shop, Garage Equipment, and 397 - Communication Equipment. The error originated in January 2015, was discovered in late October 2016 and was corrected in December 2016. This adjustment corrects test year-end rate base for the cumulative impact of the error. [3] See Amended Exhibit No. 13, Page 1. [4] See Amended Exhibit No. 13, Page 2. [5] See Amended Exhibit No. 13, Page 5. [6] See Amended Exhibit No. 13, Page 6. Amended Response to IPUC Staff Production Request No. 178 Amended Exhibit No. 12 Case No. INT-G-16-02 J. Darrington, IGC Page 1 of 2 Line No. 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 lntermountain Gas Company Gas Plant in Service -Original Cost For the Test Year Ending December 31 , 2016 September Update Gas Plant in Service Retirement Month End Average Month a/c 1010 and 106d11 Adjustment121 Total Balance (a) (b) (c) (d) (e) December 2015 $ 581 ,612,364 $ -$ 581,612,364 $ 582,450,330 January 2016 583,288,295 583,288,295 584,396,744 February 585,505,193 585,505,193 586,421 ,185 March 587,337,177 587,337,177 588,017,818 April 588,698,458 588,698,458 589,680,774 May 590,663,089 590,663,089 592,015,774 June 593,368,458 593,368,458 593,922,583 July 594,476,707 594,476,707 595,622,740 August 596,768,773 596,768,773 599,501,069 September 602,233,364 602,233,364 604,679,980 October 607,126,595 607,126,595 608,487,967 November 609,849,338 609,849,338 611 ,274,342 December 616,132,049 (3,432,704) 612,699,345 Total $ 7,136,471,306 Divided by 12 Average Balance $ 594,705,942 NOTES (1] These amounts match the Company's updated rate base and revenue requirement which was filed in response to IPUC Staff Production Request No. 178. [2] This adjustment corrects for an accounting error pertaining to the Commission approved depreciable lives for the following asset classes: 391 -Office Furniture and Equipment, 394 -Tools, Shop, Garage Equipment, and 397 Communication Equipment. The error originated in January 2015, was discovered in late October 2016 and was corrected in December 2016. This adjustment corrects test year-end rate base for the cumulative impact of the error. Amended Response to IPUC Staff Production Request No. 178 Amended Exhibit No. 13 Case No. INT-G-16-02 J. Darrington, JGC Page 1 of 7 Line ~ 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 lntermountain Gas Company Accumulated Depreciation -Gas Plant in Service For the Test Year Ending December 31 , 2016 September Update Accumulated Provision for Depreciation Retirement Month End Average Month ale 1080 and 1110111 Adjustment121 Total Balance (a) (b) (f) (g) (h) December 2015 $ (299,741,040) $ -$ (299,741,040) $ (300,208,766) January 2016 (300,676,492) (300,676,492) (301,742,662) February (302,808,832) (302,808,832) (303,439,469) March (304,070,105) (304,070,105) (304,685,687) April (305,301,268) (305,301 ,268) (305,868,253) May (306,435,237) (306,435,237) (306,864,044) June (307,292,850) (307,292,850) (307,539,625) July (307,786,400) (307,786,400) (307,963,527) August (308,140,654) (308,140,654) (309,149,761) September (310,158,868) (310,158,868) (311,062,619) October (311,966,370) (311 ,966,370) (312,883,641) November (313,800,912) (313,800,912) (312,030,698) December (314,798,647) 4,538,163 (310,260,484) Total $ (3,683,438,752) Divided by 12 Average Balance $ (306,953,229) NOTES [1] These amounts match the Company's updated rate base and revenue requirement which was filed in response to IPUC Staff Production Request No. 178. (2] This adjustment corrects for an accounting error pertaining to the Commission approved depreciable lives for the following asset classes: 391 -Office Furniture and Equipment, 394 -Tools, Shop, Garage Equipment, and 397 - Communication Equipment. The error originated in January 2015, was discovered in late October 2016 and was corrected in December 2016. This adjustment corrects test year-end rate base for the cumulative impact of the error. Amended Response to IPUC Staff Production Request No. 178 Amended Exhibit No. 13 Case No. INT-G-16-02 J. Darrington, IGC Page 2 of 7 Line No. Description (a) REVENUES Revenues at Proposed Rates 2 Plus Franchise Tax 3 Plus Interest Expense 4 (Less) Uncollectibles 5 (Less) Depreciation and Amortization 6 (Less) Return on Equity 7 TOTAL -REVENUES EXPENSES 8 Employee Benefits 9 Payroll and Wrthholdings 10 PGA Expense lntermountain Gas Company Cash Working Capital For the Test Year Ending December 31 , 2015111 $ $ $ Test Year Revenues and Expenses at Proposed Rates (b) 264,745,726 6,773,679 5,861 ,765 (1 ,117,843) (20,868,936) (17,609,108) 237,785,283 299,655 27,673,347 169,187,048 Revenue Lag/ Expense (Leads) (c) 44.96 44.96 44.96 44.96 44.96 44.96 (9.24) (13.82) (41 .29) ewe Factor (d) 12.32% $ 12.32% 12.32% 12.32% 12.32% 12.32% $ -2.53% $ -3.79% -11.31% Cash Working Capital Requirement (e) 32,609,050 834,322 722,001 (137,686) (2,570,452) (2,168,935) 29,288,300 (7,584) (1,047,769) (19,137,475) 11 Other Operations and Maintenance (less uncollectibles) 15,990,168 (31.74) -8.69% (1,390,314) 12 13 14 15 16 17 18 Payroll Taxes 1,649,612 (24.70) -6.77% (111 ,648) Property Taxes 3,191,226 (131.88) -36.13% (1,152,994) Franchise Tax 6,773,679 (169.50) -46.44% (3,145,574) Interest Expense 5,861 ,765 (87.68) -24.02% (1,408,107) Income Tax 7,158,783 (37.88) -10.38% (742,846) TOTAL EXPENSES $ 237,785,283 $ (28,144,311) CASH WORKING CAPITAL REQUIREMENT $ 1,143,988 NOTES (1] The Cash Working Capital amount reflects the adjustment explained on the Amended Exhibit 12, footnote [2]. Amended Response to IPUC Staff Production Request No. 178 Amended Exhibit No. 13 Case No. INT-G-16-02 J. Darrington, IGC Page 5 of 7 Line No. 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Month (a) December 2015 January 2016 February March April May June July August September October November December NOTES lntermountain Gas Company Deferred Income Taxes For the Test Year Ending December 31, 2016 September Update Accumulated Deferred Income Taxes Retirement ale 2820[11 Adjustment[2l Total (b) U) (k) $ (50,189,245) $ -$ (50,189,245) (50,161,278) (50,161,278) (50,099,181) (50,099,181) (50,078,857) (50,078,857) (49,995,634) (49,995,634) (49,919,808) (49,919,808) (50,021,034) (50,021 ,034) (49,994,205) (49,994,205) (49,934,289) (49,934,289) (49,852,271) (49,852,271) (49,780,400) (49,780,400) (49,758,479) (49,758,479) (49,707,686) (346,332) (50,054,018) Total Divided by Average Balance Average Balance (I) $ (50,175,262) (50,130,230) (50,089,019) (50,037,246) (49,957,721) (49,970,421) (50,007,620) (49,964,247) (49,893,280) (49,816,336) (49,769,440) (49,906,249) $ (599,717,071) 12 $ (49,976,423) [1] These amounts match the Company's updated rate base and revenue requirement which was filed in response to IPUC Staff Production Request No. 178. [2] This adjustment corrects for an accounting error pertaining to the Commission approved depreciable lives for the following asset classes: 391 -Office Furniture and Equipment, 394 -Tools, Shop, Garage Equipment, and 397 - Communication Equipment. The error originated in January 2015, was discovered in late October 2016 and was corrected in December 2016. This adjustment corrects test year-end rate base for the cumulative impact of the error. Amended Response to IPUC Staff Production Request No. 178 Amended Exhibit No. 13 Case No. INT-G-16-02 J. Darrington, IGC Page 6 of7 Line ..!:!2'.... Description (a) Gas Operating Revenues 2 Other Revenues 3 Total Operating Revenue 4 Operating Expenses 5 Cost of Gas 6 Operation & Maintenance Production 7 8 9 10 11 12 13 14 Natural Gas Storage, Terminaling, and Processing Transmission Distribution Customer Accounts Customer Service and Informational Sales Administrative and General 15 Other 16 Depreciation 17 Payroll Taxes 18 Property Taxes 19 Franchise Taxes 20 Interest Expense 21 Total Operating Expense 22 Before Income Taxes 23 Income Taxes 24 Total Operating Expenses 25 Net Operating Income NOTES lntermountain Gas Company Statement of Operating Income with Adjustments For the Test Year Ending December 31, 2016 $ September Update Company Unadjusted Direcil'1 (b) 252,430,742 $ 2 963,369 255,394,111 169,187,048 82,819 1,205,914 454,928 18,916,816 9,542,629 195,479 1,217,728 13,413,537 21,438,620 1,649,612 3,191,226 240,496,356 3,032 985 Company Adjustments (c) (569,684) ,,1 (569,684) 423 288 1'1 243,529,341 (146,396) 11864770 ~$ ___ ___;1~46~·~396;:.:. $ Company Direct Present (d) 252,430,742 $ 2 963,369 255,394,111 169,187,048 82,819 1,205,914 454,928 18,916,816 9,542,629 195,479 1,217,728 13,413,537 20,868,936 1,649,612 3,191,226 239,926,672 3,456,273 243,382,945 12 011166 $ Proposed Revenue Deficiency (Over Collection) (e) 9,351 ,615 $ 9,351 ,615 33,610 17,553 51,163 3,702 510 Company Direct Proposed (f) 261,782,357 2 963,369 264,745,726 169,187,048 82,819 1,205,914 454,928 18,916,816 9,576,239 195,479 1,217,728 13,431,090 20,868,936 1,649,612 3,191,226 239,977,835 7 158,783 3,753 673 247,136 618 5,597,942 _$ ___ 1~7_60_9~,1_0_8 (1] These amounts match the Company's updated rate base and revenue requirement which was filed in response to IPUC Staff Production Request No. 178. (2] This adjustment corrects for an accounting error pertaining to the Commission approved depreciable lives for the following asset classes: 391 -Office Furniture and Equipment, 394 - Tools, Shop, Garage Equipment, and 397 -Communication Equipment. The error originated in January 2015, was discovered in late October 2016 and was corrected in December 2016 The adjustment to depreciation expense reflects only that amount of overstated depreciation that occurred during the test year of 2016. (3] See Amended Exhibit No. 15, Page 25, Line 78. Amended Response to IPUC Staff Production Request No. 178 Amended Exhibit No. 14 Case No. INT-G-16-02 J. Darrington, IGC Page 1 of 2 lntermountain Gas Company Income Tax Calculation For the Test Year Ending December 31, 20Hf'l Line ~----------~D~•~sc_r~i _tio~n __________ _ September Updatel1l (b) Company Adjustments Proforma Amount (a) Total Operating Revenue 2 Total Operating Expenses Before Interest Expense and Income Taxes 121 Interest Charges131 Pre-Tax Income Permanent Tax Adjustments: 6 401 K Dividend Deduction 50% Meals and Entertainment Club Dues Lobbying Expenses 10 Total Permanent 11 Temporary Tax Adjustments: 12 Accrued 401 K Pension 13 Bad Debt Expenses 14 Charitable Contributions 15 Customer Advances 16 Deferred Compensation -Officers 17 Incentive Compensation 18 LNG Sales Deferred Revenue 19 Payroll Taxes -Incentive Compensation 20 Postretirement Benefit Costs 21 SISP/SERP Expense -Current 22 SISP/SERP Expense Officers 23 SISP/SERP Expense Officers -PBO 24 Unamortized Loss on Reacquired Debt 25 Uniform Capitalization 26 Vacation Pay 27 AFUOC Debt -CWIP 28 AFUOC Equity -CWIP 29 Capitalized Interest -CW1P 30 Contribution in aid of construction -CWIP 31 Plant Temporary Differences Federa1121 32 Total Temporary 33 Total Tax Adjustments 34 T axabte income before state income taxes 35 state Current Income Tax Calculation: 36 Taxable income before state income taxes 37 Bonus Modification 38 state taxable income 39 state tax rate 40 State income tax (expense)/benefit before adjustments 41 state Net Operating Loss 42 State Tax Credits 42 Permanent Building Fund 42 Investment tax credit recapture 141 43 Investment tax creditl4l 44 Return and other adjustments 45 Total State Current Income Taxes (expense)/benefrt 255.394, 111 240,496,356 5,860,829 9,036,926 (123,189) 74,546 (48,643) (5,508) (39,018) (428,577) 652.655 37.236 (235,697) 72.216 595,027 38,692 1,358.182 2,045.208 1,996,565 11,033,491 11,033,491 (5,580,075) 5,453,416 7.40% (403,553) (10) (18,856) 201,777 (220,642) (C) (569,684) 936 568,748 (569,684) (569,684) (569,684) (936) (936) (936) 7.40% 69 18,856 (201,777) (182,852) (d) 255,394.111 239,926,672 5,861,765 9.605.674 (123,189) 74,546 (48,643) (5,508) (39,018) (428,577) 652,655 37,236 (235,697) 72.216 595,027 38.692 788,498 1,475.524 1,426,881 11,032,555 11,032,555 (5,580,075) 5,452,480 7.40% (403,484) (10) (403,494) Amended Response to IPUC Staff Production Request No. 178 Amended Exhibit No. 15 Case No. INT-G-16-02 J. Darrington, IGC Page 24 of 27 lntermountain Gas Company Income Tax Calculation For the Test Year Ending December 31, 201 &11 Line ~ ----------~D~•-=-•c~r~i "'tio~"~------------~F~o~r•-=-c•~•~te"d~---'-'Ad"'j~us~tm-"e"'n"'ts'----~P-'--,o"'fo"'r""m"'a-'--A"'m'-'o-=-un"'t­ (a) 46 State Deferred Income Tax Calculation 47 Deferred Gas Cost and SERP timing differences 48 State deferred tax rate 49 State NOL 50 State Deferred Income Taxes (expense)/benefrt 51 Total State Income Taxes (expense)/benefrt 52 Federal Current Income Tax Calculation: 53 Taxable income before state income taxes 54 State income tax -Current year 55 Federal taxable income 56 Federal tax rate 57 Federal income tax (expense)benefrt before adjustments 58 Federal Net Operating Loss 59 State Net Operating Loss 60 Federal Tax Credits 61 State Tax Credits 62 FIN 48 Adjustments 63 Return and other adjustments 64 Total Federal Current Income Taxes (expense)/benefit 65 Federal Deferred Income Tax Calculation 66 Non fixed asset & CWIP timing differences 67 Federal deferred tax rate 68 Deferred taxes 69 Deferred Gas Cost & SERP timing differences 70 Federal deferred tax rate 71 Deferred taxes 72 Utility fixed asset timing differences 73 Federal deferred tax rate 7 4 Deferred taxes 75 Federal Deferred Income Taxes (expense)/benefit 76 Total Federal Income Taxes (expense)/benefit 77 ITC Amortization151 78 Total tax (expense)/benefrt llilill (b) 7.40% (220,642) 11,033,491 (220,642) 10,812,849 35.00% (3,784,497) (3,784,497) 687,026 35.00% 240,459 32.41% 1,358,182 31.33% 425,508 665,967 (3,118,530) 306,187 (3,032,985) (c) (d) 7.40% 7.40% (182,852) (403,494) (936) 11,032,555 (182,852) (403,494) (183,788) 10,629.061 35.00% 35.00% 64,326 (3,720,171) 64,326 (3,720,171) 687,026 35.00% 35.00% 240,459 32.41% 32.41 % (569,684) 788,498 31.33% 31.33% (178,478) 247,030 (178,478) 487,489 (114,152) (3,232,682) (126,284) 179,903 $ (423,288) (3,456,273) [1) These amounts match the Company's updated rate base and revenue requirement which was filed in response to IPUC Staff Production Request No. 178. [2] This adjustment corrects for an accounting error pertaining to the Commission approved depreciable lives for the following asset classes: 391 • Office Furniture and Equipment. 394 -Tools, Shop, Garage Equipment, and 397 · Communication Equipment. The error originated in January 2015, was discovered in late October 2016 and was corrected in December 2016. The adjustment to depreciation expense reflects only that amount of overstated depreciation that occurred during the test year of 2016. [3] Interest expense is calculated by multiplying total rate base by the weighted average cost of debt. This adjustment is the result of the Retirement Adjustment explained in footnote [2] above. [4] In the creation of this tax schedule, the Company inadvertently included the effect of Idaho Investment Tax Credits ("ITCs") in the calculation of its state current income tax expense. This adjustment removes the effect of Idaho ITCs to match the Company's correct accounting treatment on its books and records. [5) This adjustment is updates the estimated ITC amortization to reflect actual ITC amortization. net of recapture amortization and federal tax effect. Amended Response to IPUC Staff Production Request No. 178 Amended Exhibit No. 15 Case No. INT-G-16-02 J. Darrington, IGC Page 25 of 27 Line No. 1 2 3 4 5 6 7 8 lntermountain Gas Company Deficiency in Operating Revenue For the Test Year Ending December 31 , 2016 September Company Descrietion Update[1l Adjustments Total (a) (b) (c) (d) Rate Base $ 237,280,526 $ 37 ,875 $ 237,318,401 Operating Income at Present Rates 11 ,864,770 146,396 12,011 ,166 Earned Rate of Return 5.000% 0.061% 5.061% Cost of Capital 7.420% 0.000% 7.420% Operating Income at Proposed Rates 17,606,215 2,810 17,609,025 Operating Income Deficiency 5,741 ,445 (143,586) 5,597,859 Gross Revenue Conversion Factor 1.67057 1.67057 Deficiency in Operating Revenue $ 9,591,486 $ (239,871) $ 9,351,615 NOTES [1] These amounts match the Company's updated rate base and revenue requirement which was filed in response to IPUC Staff Production Request No. 178. Amended Response to IPUC Staff Production Request No. 178 Amended Exhibit No. 16 Case No. INT-G-16-02 J. Darrington, IGC Page 1 of 2 CERTIFICATE OF DELIVERY I HEREBY CERTIFY that on this 17th day of January, 2017, I caused to be served a true and correct copy of the Amended Response of Intermountain Gas Company to Request No. 178 of the Commission Staff upon the following individuals in the manner indicated below: Hand Delivery: (original and 3 copies) Diane Hanian 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: Mike.McGrath@intgas.com Brad M. Purdy 2019 N. 17th Street Boise, ID 83702 E-Mail: bmpurdy@hotmail.com Attorney for Community Action Partnership Association of Idaho (CAP Al) Benjamin J. Otto Idaho Conservation League 710 N. 61h Street Boise, ID 83 702 E-Mail: botto@idahoconservation.org F. Diego Rivas NW Energy Coalition 1101 81h Avenue Helena, MT 59601 E-Mail: diego@nwenergy.org Edward A. Finklea Northwest Industrial Gas Users (NWIGU) 545 Grandview Drive Ashland, OR 97520 E-Mail: efinklea@nwigu.org D Hand Delivery D US Mail (postage prepaid) D Facsimile Transmission D Federal Express ~ Electronic Transmission D Hand Delivery D 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 D 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: cstokes@cablehuston.com tbrooks@cablehuston.com Attorneys for NWIGU Electronic service only: Michael C. Creamer Givens Pursley LLP E-Mail: mcc@givenspursley.com Attorneys for NWIGU Scott Dale Blickenstaff The Amalgamated Sugar Company LLC 1951 S. Saturn Way, Ste. 100 Boise, ID 83 702 E-Mail: sblickenstaff@amalsugar.com Peter Richardson Gregory M. Adams Richardson Adams, PLLC 515 N. 27th Street Boise, ID 83 702 E-Mail: peter@richardsonadams.com greg@richardsonadams.com Attorneys for The Amalgamated Sugar Company LLC Ken Miller Snake River Alliance 223 N. 6th St., Ste. 317 P.O. Box 1731 Boise, ID 83701 E-Mail: kmiller@snakeriveralliance.org 2 D Hand Delivery IZ! US Mail (postage prepaid) D Facsimile Transmission D Federal Express IZ! Electronic Transmission IZ! Electronic Transmission D Hand Delivery IZ! US Mail (postage prepaid) D Facsimile Transmission D Federal Express IZ! Electronic Transmission D Hand Delivery IZ! US Mail (postage prepaid) D Facsimile Transmission D Federal Express IZ! Electronic Transmission D Hand Delivery D US Mail (postage prepaid) D Facsimile Transmission D Federal Express IZ! Electronic Transmission Andrew J. Unsicker Lanny L. Zieman Natalie A. Cepak Thomas A. Jernigan Ebony M. Payton AFLOA/JA-ULFSC 139 Barnes Drive, Suite 1 Tyndall AFB, FL 32403 E-Mail: Andrew.unsicker@us.af.mil Lanny .zieman. l @us.af.mil N atalie.cepak.2@us.af.mil Thomas.jernigan.3@us.af.mil Ebony. payton. ctr@us.af.mil Attorneys for Federal Executive Agencies (FEA) 3 D Hand Delivery D US Mail (postage prepaid) D Facsimile Transmission D Federal Express ~ Electronic Transmission Ronald L. Williams