SMITH.docx

1 (The following proceedings were
2 had in open hearing.)
3 (Staff Exhibit Nos. 101 through
4 106 were marked for identification.)
5 COMMISSIONER KJELLANDER: Oh. And
6 117?
7 MS. NORDSTROM: 117 through 119.
8 COMMISSIONER KJELLANDER: 117 through
9 119, okay, and those are accompanied by the
10 rebuttal. Thank you. Hearing no objection, shall
11 be done.
12 (Staff Exhibit Nos. 117 through
13 119 were marked for identification.)
14 MS. NORDSTROM: Thank you. And I
15 tender this witness for cross-examination by
16 Mr. Cobott.
17 COMMISSIONER KJELLANDER: Thank you.
18 Mr. Cobott.
19
20 CROSS-EXAMINATION
21
22 BY MR. COBOTT:
23 Q. In your testimony, Bob, you made a
24 comment that I thought was really cheap, that I did
25 not present you with time cards for myself prior to
27
HEDRICK COURT REPORTING SMITH (X)
P.O. BOX 578, BOISE, ID Staff
1 PUC involvement or after PUC involvement, or for
2 Larry. Now, what makes you think that an
3 owner/operator needs to have a time card on
4 himself? Isn't this a little ridiculous?
5 A. The comment was not to indicate that
6 you should retain those kind of records on yourself,
7 necessarily. However, it was to indicate that I
8 could not find anything -- it was to indicate I
9 could not locate any form of written documentation
10 in support of the time.
11 Q. Well, prior to PUC being involved, I
12 knew nothing about PUC, I'd never heard of PUC
13 before, so what makes you think that I was going to
14 keep documents or records? In other words, what
15 you're saying is what I said was a lie. You don't
16 accept anything that I said when it comes down --
17 COMMISSIONER KJELLANDER: Mr. Cobott,
18 one question at a time, please, and allow the
19 witness to respond.
20 MR. COBOTT: Okay.
21 THE WITNESS: No, as a matter of fact,
22 Mr. Cobott, what I was trying to indicate was that
23 through the interviews that I had with you in August
24 of last year and followed up with a couple of other
25 meetings, that in discussions with you, you
28
HEDRICK COURT REPORTING SMITH (X)
P.O. BOX 578, BOISE, ID Staff
1 estimated the time that you were spending operating
2 and maintaining the system, and I relied upon your
3 spoken word as to what kind of time was being spent
4 to operate and maintain this system. And that was
5 the basis of my recommendations based upon those
6 interviews.
7 Q. BY MR. COBOTT: Wasn't the time, if
8 I'm not mistaken, wasn't it $750 a week to start
9 with? Wasn't there paperwork that I brought to
10 Boise, didn't it state $750 a week?
11 A. Mr. Cobott, when you came to Boise and
12 brought me your paperwork, I believe that was in
13 March of this year.
14 Q. No.
15 A. Or February of this year possibly.
16 Q. Yeah, I came in March 31st or
17 something like that with my boxes of paperwork.
18 A. That's correct --
19 Q. And I gave you --
20 A. -- you did.
21 Q. -- a typed-out form stating certain
22 things like profit for the Company, wages, so on and
23 so forth, and the wages that I set at that time was
24 $750 per month. After reviewing my expenses and
25 reviewing my time and what have you, 750 doesn't
29
HEDRICK COURT REPORTING SMITH (X)
P.O. BOX 578, BOISE, ID Staff
1 cover it, but it was not -- it definitely wasn't
2 $80, or $320 a month.
3 COMMISSIONER KJELLANDER: Mr. Cobott,
4 is there a question? This is your opportunity to
5 ask questions in cross-examination. Do you have a
6 question for Mr. Smith?
7 Q. BY MR. COBOTT: My question is how do
8 you come up with the $80 a week?
9 A. The management fee that I included
10 there was based upon my interviews with you,
11 Mr. Cobott, over a period of months beginning in
12 August of last year when we had our first meeting
13 here in Sandpoint. Based upon the information you
14 provided me, I came to the conclusion that you were
15 spending approximately four hours a week on doing
16 the administrative work on the water system. That
17 was based upon the information you, yourself,
18 provided me in our interviews.
19 Q. Well, unless I'm mistaken, I didn't
20 provide you any other information other than the 750
21 per week.
22 But my other question is -- which I
23 just lost -- well, we'll get back to that if I think
24 about it.
25 Is every -- these water systems that
30
HEDRICK COURT REPORTING SMITH (X)
P.O. BOX 578, BOISE, ID Staff
1 you go out and you audit that you refer to in your
2 testimony, is every one of these water systems,
3 including mine, are we all identical?
4 A. Certainly not.
5 Q. Well then how can you compare one to
6 the other? Every water system -- doesn't every
7 water system have its own set of problems and
8 conditions?
9 A. They certainly do.
10 Q. Do you take any of that into
11 consideration?
12 A. Absolutely.
13 Q. How can you take it into consideration
14 when you know nothing about it? It's obvious you
15 don't know anything about it or you wouldn't make
16 the statements that you do.
17 You're not going to have an answer for
18 it because there is no answer for it.
19 COMMISSIONER KJELLANDER: Mr. Cobott,
20 you have to ask a question for which he can provide
21 an answer; and if you have a question there that you
22 think he can provide an answer to, certainly please
23 address him in that fashion.
24 Q. BY MR. COBOTT: You state in there
25 about my -- about the 12-percent return?
31
HEDRICK COURT REPORTING SMITH (X)
P.O. BOX 578, BOISE, ID Staff
1 A. That's correct.
2 Q. Yeah. Now, that 12-percent return
3 covers my investment, my profit, and anything to do
4 with having to get a mortgage to finance the loan.
5 The mortgage interest alone is 11.74 percent, so how
6 do you come up with 12 percent? Am I not going to
7 get any return on my money or any profit, is that
8 how that works?
9 A. Mr. Cobott, that 12 percent is a
10 return on equity, a number that this Commission has
11 used for a number of years for small water
12 companies. It normally is a rate that is higher
13 than would be allowed for a large, publicly-traded
14 public utility like Avista Corporation that trades
15 stock on the market, recognizing that a small water
16 company is inherently more risky for the owner than
17 is a stock company. The 12 percent is to provide a
18 return on the capital invested in the physical
19 assets for which you earn a return, and it is
20 intended to cover all of your costs of capital.
21 Q. In your previous statements, you said
22 that the mortgage amount that I applied for to be
23 reimbursed, you said that was covered in the 12
24 percent. You disallowed it, all of it.
25 Now, if you're disallowing all of it,
32
HEDRICK COURT REPORTING SMITH (X)
P.O. BOX 578, BOISE, ID Staff
1 how come other water companies can get a loan and
2 have it paid for over a seven-year period, including
3 interest and the principal, but I'm not allowed
4 this?
5 A. Mr. Cobott, based upon your question,
6 if the mortgage loan were added in, that would
7 represent a double recovery of the same costs.
8 Q. Where does a double recovery come
9 from? What are you talking about?
10 A. What I am referring to is the five
11 thousand -- whatever it was -- dollars that you have
12 included to make your mortgage payments would
13 duplicate 12-percent return that is allowed you on
14 the assets for which you borrowed the money to make
15 the investment to begin with; therefore, it would be
16 a double recovery of the -- on the same investment.
17 Q. Well, how do you figure that when the
18 12 percent only amounts to $3,000 and the mortgage
19 is over 5,000? That's only the part that I used for
20 the water system. What about the profit? What
21 about my capital gains on my investment, my 100-plus
22 or close to $200,000 that I have invested? Where
23 does that return come from? Am I just supposed to
24 sit back and forget it?
25 A. Mr. Cobott, according to your own
33
HEDRICK COURT REPORTING SMITH (X)
P.O. BOX 578, BOISE, ID Staff
1 records, all of your initial investment in that
2 water company has been fully depreciated and you
3 have recovered that cost already.
4 Q. That is not an acceptable answer. I
5 want to know where my money is. I spent a lot of
6 time -- 16 years -- investing money in this company,
7 and you've got it down as 126,000. There's many,
8 many more thousands of dollars. Did you research it
9 all the way back to 1986 and see how much money was
10 invested?
11 A. I asked you initially when we met last
12 August for documentation to support your
13 investments. You provided me the information in
14 March of this year, some of the information you
15 provided me, which amounted to an invoice for the
16 construction of your new well.
17 The note where you originally
18 purchased the water system was available through
19 County records, that was not provided by you, the
20 $100,000 original purchase contract.
21 Q. If I'm not mistaken, I brought you a
22 copy of the purchase agreement, didn't I, at that
23 meeting?
24 A. I don't believe you did. I do,
25 however, have a copy of that purchase agreement, and
34
HEDRICK COURT REPORTING SMITH (X)
P.O. BOX 578, BOISE, ID Staff
1 I believe it's an exhibit in this case.
2 Q. It is. Okay, getting back to my wages
3 now: What happens if I spend more than four hours a
4 week on the water system? Do I just work the rest
5 of the hours for free or how does that work, in your
6 opinion, in your -- in your opinion?
7 A. The way rates are set for a company is
8 to establish what appears to be a normal pattern of
9 operation and provide a revenue stream that will
10 support the operation of the company under those
11 normal circumstances. As you stated yourself a
12 moment ago, every company may have its own
13 particular peculiarities. The same is true of any
14 company from year to year may experience more or
15 less need to devote time to the operation of the
16 company. We try and take that into consideration so
17 that the years when there is little labor
18 requirement on the system is offset by those years
19 when there is a lot of labor required to operate the
20 system. And it is a, quote, normalized approach to
21 setting rates.
22 Q. Who? You said "we" take this under
23 consideration. As far as I know, you're the only
24 one that takes any of this under consideration. You
25 make the determination yourself, wholly.
35
HEDRICK COURT REPORTING SMITH (X)
P.O. BOX 578, BOISE, ID Staff
1 A. I do not operate in a vacuum,
2 Mr. Cobott. I work with peers in my office. My
3 testimonies are reviewed by my supervisor. My
4 testimonies are reviewed by other persons in the
5 office who do similar work that I do on other
6 companies, and we try and share information back and
7 forth and be consistent from company to company,
8 from industry to industry.
9 Q. Wouldn't it make more sense for an
10 owner/operator to be on a salary? I mean, here he
11 is, our owner/operator, and I have to be on a wage,
12 on an hourly wage and hours? Wouldn't it make more
13 sense for an owner/operator to be on a salary?
14 Sure, some weeks you might only spend six or eight
15 hours; other weeks you might spend 20 hours. The
16 overall picture is what we have to go for here. I
17 can't believe that you expect an owner/operator to
18 be on a hourly wage, especially four hours a week.
19 That's ludicrous and I will not accept that in any
20 shape, way, or -- any shape, way that this
21 Commission wants to present it or wants to accept it
22 or whatever. It will not be accepted by me, I want
23 to make that quite clear.
24 COMMISSIONER KJELLANDER: Mr. Cobott,
25 is there a question?
36
HEDRICK COURT REPORTING SMITH (X)
P.O. BOX 578, BOISE, ID Staff
1 Q. BY MR. COBOTT: Yes. I asked him my
2 question about the salary.
3 COMMISSIONER KJELLANDER: Could you
4 restate that so that he can respond?
5 Q. BY MR. COBOTT: Wouldn't it make more
6 sense to be on a salary because nothing -- like he
7 says, nothing in this particular type business,
8 nothing is true to form. It's not like going to an
9 8:00-to-5:00 job, doing such and such for eight
10 hours and going home. Some weeks it's going to be
11 more than other weeks depending on situations that
12 happen, letters that have to be written, all kinds
13 of numerous things. I know: I've been doing this
14 for 16 years.
15 COMMISSIONER KJELLANDER: Mr. Cobott.
16 And do you have the question squarely
17 understood, Mr. Smith?
18 THE WITNESS: I think I understand the
19 question. I'm looking for a reference in my
20 testimony. I can't put my hands on it right now,
21 but in my testimony, my direct testimony that was
22 prefiled on June 7th, I discussed that issue and I
23 explained that what we put together for these
24 purposes is somewhat akin to a budget in coming up
25 with a revenue requirement.
37
HEDRICK COURT REPORTING SMITH (X)
P.O. BOX 578, BOISE, ID Staff
1 And, no, you must not stick line item
2 by line item to the items that we've got in here;
3 that once a revenue requirement is set, it is at
4 your discretion, Mr. Cobott, as the owner, to
5 determine how to distribute those revenues you
6 collect to pay your costs, whether it's paying
7 Mr. Fairfax to do work, whether it's paying yourself
8 to do work, whether it's to pay your operating
9 expenses. The only thing we want you to do is use
10 that money prudently.
11 Q. If that's the case, then why did we
12 even put the wage thing in there? Why insult me?
13 A. It is not intended to be an insult --
14 an insult, excuse me. What it is intended to be is
15 a stepping stone to build a ladder, so to speak, to
16 come up with a total revenue number. You have to
17 base that on some kind of foundation. You cannot
18 just pick a revenue number out of the air. We
19 can't, the Commission Staff, cannot just pick a
20 revenue number out of the air and say, That looks
21 like a good number. We have to build it up to show
22 where those dollars would be prudently expended.
23 Q. Then why on your estimate of wages,
24 why did you say it was arbitrary? You must have had
25 some doubts.
38
HEDRICK COURT REPORTING SMITH (X)
P.O. BOX 578, BOISE, ID Staff
1 A. Oh, certainly it's arbitrary in that
2 there is no record.
3 Q. It wasn't fact, it was arbitrary, it
4 was just a figure you brought out. Is that correct?
5 A. Now which factor are you referring
6 to?
7 Q. I'm talking about my wages. You made
8 a comment on the paperwork and said it was
9 arbitrary.
10 A. The -- the dollar value assigned to
11 that was, yes, but as I recall in the testimony, I
12 indicated that we recognize that the responsibility
13 of being the owner/operator/manager of the system
14 should receive a higher rate of pay than a
15 maintenance person would receive for having the
16 responsibility. So, yes, it was somewhat arbitrary,
17 but it's based upon a fair feeling, knowledge of
18 what's going on in the workplace, what wages are and
19 what kind of responsibilities are expected of an
20 owner/operator company.
21 Q. Well, I disagree with that statement
22 you just made because I have commented on that with
23 letters many times to the Commission on the wages,
24 and to this day, it's still four hours a week at $20
25 an hour and it says "arbitrary." Now, "arbitrary,"
39
HEDRICK COURT REPORTING SMITH (X)
P.O. BOX 578, BOISE, ID Staff
1 as far as I'm concerned, means could be, may be,
2 should be, could be. You don't really know.
3 A. No, sir, I don't, and obviously I
4 attempted to try and get that kind of information.
5 We could not get documentation in support,
6 therefore --
7 MS. NORDSTROM: Mr. Chairman, I'd like
8 to recommend that we move on to a different issue.
9 Sounds like we've exhausted this one. If there are
10 any other questions that Mr. Smith can answer in
11 regard to wages, I'm sure he'd be more than happy
12 to, but I think we'd all agree that they're somewhat
13 arbitrary and that's been thoroughly explored.
14 COMMISSIONER KJELLANDER: Why don't we
15 allow the completion of the response that Mr. Smith
16 was on, and then we'll go back to see what his line
17 of questioning was.
18 MR. SMITH: I'm not sure I can
19 remember where I was at.
20 In coming up with the total labor
21 costs for this company, I attempted to -- to
22 separate the various responsibilities, the
23 functions, if you will, between management
24 responsibility and operation and maintenance
25 responsibility, recognizing that the management
40
HEDRICK COURT REPORTING SMITH (X)
P.O. BOX 578, BOISE, ID Staff
1 responsibility should be reimbursed at a rate
2 greater than or compensated at a rate greater than
3 operation and maintenance would be compensated.
4 Based upon our interviews and our
5 discussions, I came to the conclusion that you were
6 spending approximately four hours a week doing the
7 administrative part of running this company;
8 therefore, at four hours a week, assigned a value on
9 that that is greater than an operation and
10 maintenance wage and salary limit.
11 Q. BY MR. COBOTT: I want to know how you
12 came up with those figures. You had nothing from
13 me.
14 A. Only your word, Mr. Cobott.
15 Q. My word? I never said anything about
16 four hours a week. I never said -- I would never
17 say anything about four hours a week. No -- I'm not
18 stupid.
19 COMMISSIONER KJELLANDER: Mr. Cobott,
20 let's get to a question.
21 Q. BY MR. COBOTT: Did you read my
22 testimony, my direct testimony?
23 A. I did.
24 Q. So do you agree with it?
25 A. No.
41
HEDRICK COURT REPORTING SMITH (X)
P.O. BOX 578, BOISE, ID Staff
1 Q. Okay. You don't agree with mine; I
2 don't agree with yours. End of story.
3 Why don't you agree with mine?
4 A. That's what my rebuttal testimony was
5 all about, Mr. Cobott.
6 Q. Tell me in your words why you don't
7 agree with it.
8 A. It is duplicative of ours, it appears
9 to count several of the functions independently that
10 should be accomplished simultaneously and comes up
11 with artificially high numbers.
12 Q. So you know exactly how the business
13 runs? You're here watching me run it 12 months out
14 of the year, 52 weeks out of the year? You see what
15 I have to do and you know all that? You're that
16 intelligent that you know all of this? My testimony
17 is my testimony, and it will stand.
18 COMMISSIONER KJELLANDER: Is there a
19 question, Mr. Cobott?
20 MR. COBOTT: Yes. I want to know why
21 he makes these determinations and why he has the
22 right to make these determinations and why the
23 Commission believes what he says. I want to know
24 these answers. This is my -- this is my business
25 here. I have the right to defend my business and I
42
HEDRICK COURT REPORTING SMITH (X)
P.O. BOX 578, BOISE, ID Staff
1 will defend it.
2 MS. NORDSTROM: I'd like to request
3 that Mr. Cobott pick one question at a time for him
4 to answer so that he answers all your questions
5 thoroughly. Which one would you like him to answer
6 first? You mentioned several.
7 MR. COBOTT: On my testimony.
8 COMMISSIONER KJELLANDER: Could you
9 restate that specific question?
10 Q. BY MR. COBOTT: I want to know why you
11 don't believe my testimony. You have called me a
12 liar before.
13 A. Mr. Cobott, I have never referred to
14 you as a "liar."
15 Q. Well, maybe you never said I was a
16 "liar."
17 COMMISSIONER KJELLANDER: Mr. Cobott,
18 this is argumentative. This isn't going to get us
19 any further down the path. If you have a direct
20 question for Mr. Smith in relation to his testimony,
21 please ask that question so we can move forward on
22 this.
23 MR. COBOTT: Well, it looks like to me
24 here that this is a one-sided question and answer.
25 No matter what I say, I don't get recognition.
43
HEDRICK COURT REPORTING SMITH (X)
P.O. BOX 578, BOISE, ID Staff
1 Mr. Smith here, whatever he says --
2 COMMISSIONER KJELLANDER: Mr. Cobott.
3 MR. COBOTT: No, I'm going to state my
4 statement.
5 COMMISSIONER KJELLANDER: You will
6 have an opportunity to present your statement, your
7 facts, at that appropriate time. Once the Staff has
8 put on its case, you will then have your opportunity
9 for your comments. The only purpose of
10 cross-examination at this point is for you to ask
11 questions of the witnesses that you feel may be in
12 opposition to your viewpoint. Your opportunity for
13 a statement will come later. It's not as if we're
14 tying to rule you out from having that opportunity,
15 but this is not the appropriate time for that.
16 That's why I keep coming back to would you like to
17 ask him a direct question in cross-examination. You
18 will have an opportunity when you're sworn in to
19 provide your testimony.
20 MR. COBOTT: I'm going to let Larry --
21 is it all right if I let Larry Fairfax ask a couple
22 questions?
23 COMMISSIONER KJELLANDER: Mr. Fairfax.
24 MR. COBOTT: Or you want me to finish
25 up?
44
HEDRICK COURT REPORTING SMITH (X)
P.O. BOX 578, BOISE, ID Staff
1 COMMISSIONER KJELLANDER: Do you have
2 other questions or are they related to this?
3 MR. FAIRFAX: They're related to the
4 hourly wages he has down here.
5 COMMISSIONER KJELLANDER: Without
6 objection, we'll go ahead and allow Mr. Fairfax to
7 ask questions --
8 MS. NORDSTROM: That's fine. Staff
9 has no objection.
10 COMMISSIONER KJELLANDER: -- along the
11 same line. So, Mr. Fairfax, please proceed.
12
13 CROSS-EXAMINATION
14
15 BY MR. FAIRFAX:
16 Q. All I've got is a couple other
17 questions.
18 You've got down here you called the
19 Labor Department and got some wages quoted to you on
20 this sheet. Did you call anybody else, any actual
21 plumbers?
22 A. No, I only got this testimony of
23 Mr. Cobott --
24 Q. "No" is fine. That's all I needed, a
25 "yes" or "no."
45
HEDRICK COURT REPORTING SMITH (X)
P.O. BOX 578, BOISE, ID Staff
1 Have you ever had any plumbing work
2 done in your house, just simple "yes" or "no"?
3 A. Yes.
4 Q. Did you pay them $15 an hour, "yes" or
5 "no"?
6 A. No.
7 Q. Okay. How much did you pay?
8 A. I believe the service call the last
9 time I -- I do most of my own plumbing. I believe
10 the last time I used a plumber has probably been 20
11 years ago. I don't know, 20, $25 at that time.
12 Q. Okay. Have you ever had any
13 excavating work done with a backhoe, cat, grader,
14 anything along that line?
15 A. I've never hired it done, no.
16 Q. And you didn't call anybody on that
17 neither, other than the Labor Department?
18 A. That's correct.
19 Q. Did you ask him what the minimum state
20 wage was or did you ask him what the wage was at
21 that time?
22 A. When I called the Department of Labor?
23 Q. Right.
24 A. I asked for the going wages for
25 various occupations as shown on my Exhibit No. I
46
HEDRICK COURT REPORTING SMITH (X)
P.O. BOX 578, BOISE, ID Staff
1 believe it's 117.
2 Q. Right.
3 A. Yes.
4 Q. Now, on, I don't know, this page here
5 on your rebuttal where your figures come up --
6 COMMISSIONER KJELLANDER: Could you
7 refer to a --
8 Q. BY MR. FAIRFAX: -- you've got me down
9 here --
10 COMMISSIONER KJELLANDER: What page
11 number? Could you refer to a page number?
12 Q. BY MR. FAIRFAX: Sure. Where are they
13 at on here?
14 A. Should be in the bottom, right-hand
15 corner.
16 Q. Okay. On 118, on line 19, you've got
17 Fairfax Monthly Schedule, Coliform test, and I
18 notice you -- you've got that down at 2.5 hours.
19 Okay. And then you say I duplicate this same thing
20 down here on line 21, two lines down.
21 A. Okay, yes, I see those.
22 Q. If you would have checked with me, I
23 would have explained to you there's more than just
24 one test that's done on the water system. There's
25 several, matter of fact 20-some tests that have to
47
HEDRICK COURT REPORTING SMITH (X)
P.O. BOX 578, BOISE, ID Staff
1 be done throughout the year, not including the
2 coliform test.
3 A. I'm quite familiar with the testing
4 requirements.
5 Q. Okay. So there's no duplicate there
6 where you're indicating a duplicate test.
7 A. I wasn't referring to duplicate
8 testing there, Mr. Fairfax, as I was duplicate time
9 required to take the water samples.
10 Q. Well, each test takes a matter of time
11 to do it, and if you follow that line over you've
12 got $3.33 for doing that test?
13 A. I believe that's three hours and 33
14 minutes, times the rate.
15 Q. Under "Cost"? That's not a dollar
16 figure under "Cost"?
17 A. Oh, I was on the other line. I'm
18 sorry.
19 Q. Where did you get that figure?
20 A. It is the .33 hours times $10.
21 Q. Where did you get that figure?
22 A. Based upon the data that was provided
23 in your testimony and Mr. Cobott's testimony.
24 Q. In this right here?
25 A. I can't see it very well from here.
48
HEDRICK COURT REPORTING SMITH (X)
P.O. BOX 578, BOISE, ID Staff
1 Q. It's the sheet I supplied to you for
2 the hours that I do during the week.
3 A. Correct.
4 Q. And semi-annually?
5 A. Correct.
6 Q. So what you're saying is you've cut my
7 wages from $20 an hour down to $10 an hour just off
8 of your own knowledge of operating the water system?
9 A. This exhibit was not put together to
10 set your salary or Mr. Cobott's salary. It was put
11 together to be indicative of what it would cost to
12 pay someone at the going wage and salary rates
13 quoted to me by the Department of Labor.
14 Q. This one was?
15 A. The one I put together, correct.
16 Q. Not the one I supplied you with what I
17 would charge?
18 A. That's correct.
19 Q. Okay. And you also talked to some
20 water systems and confirmed that your prices were
21 right?
22 A. Which prices are you referring to?
23 Q. The one -- obviously you have a lot
24 lower wages than what I put down on here, a lot less
25 time, so you must have talked to another water
49
HEDRICK COURT REPORTING SMITH (X)
P.O. BOX 578, BOISE, ID Staff
1 system and found out that it takes less time to take
2 this test and do the book work?
3 A. I am quite familiar with the amount of
4 labor that other water systems are reporting to our
5 Commission in their annual reports. I have an
6 exhibit in my direct testimony that draws those
7 comparisons.
8 Q. With one system or more than one?
9 A. With about seven or eight, I believe.
10 Q. Okay. And you actually came out and
11 went with me and did the tests?
12 A. No.
13 Q. So you actually -- you're just
14 guessing that that's how long it takes?
15 A. I'm basing it upon fairly intimate
16 knowledge with what is going on in the field. I'm
17 aware of what kind of tests are required, and I'm
18 also aware that the time to take those tests, to
19 take the samples, because you're not doing the test
20 yourself --
21 Q. Well, actually we do do the daily
22 tests ourselves.
23 A. You do the chlorine test.
24 Q. Correct.
25 A. On a daily basis.
50
HEDRICK COURT REPORTING SMITH (X)
P.O. BOX 578, BOISE, ID Staff
1 Q. Correct.
2 A. Which is a fairly simple process.
3 Q. Is it?
4 A. The other labs tests, the coliform
5 bacteria, the SOCs, VOCs, et cetera, have to be
6 taken to a State-licensed laboratory.
7 Q. Okay. Well, this test that's so
8 simple, this chlorine test, why don't you explain it
9 to us, how it's done?
10 A. I believe you just simply --
11 Q. You believe or you know for sure?
12 A. I've never taken one myself.
13 Q. But you just stated to this committee
14 that you knew it was a very simple test?
15 A. It's my understanding from people I
16 have talked with that do these kind of things that
17 it's a very simple test.
18 Q. Okay. So explain how it's done.
19 A. It's my understanding that it's simply
20 a matter of taking a water sample and putting it
21 into a beaker or a bottle and adding a chemical
22 additive to it, and comparing the color change with
23 a chart.
24 Q. Okay. So you're saying you just turn
25 on the tap, fill up the test tube in your case, and
51
HEDRICK COURT REPORTING SMITH (X)
P.O. BOX 578, BOISE, ID Staff
1 it's done. Right?
2 A. That's my -- I believe that in a very
3 small nutshell, that does it, yes.
4 Q. Right. For your information, that is
5 incorrect 100 percent. So what you should do -- I
6 don't know if I'm out of line for saying this, but
7 if you should go and meet with us and went out and
8 took a test so you knew for sure what was going on
9 on a test like this before you put down here that
10 it's only worth $3.33 to take that test. Do you
11 understand?
12 COMMISSIONER KJELLANDER: Is there a
13 question there?
14 MR. FAIRFAX: Nope. He answered the
15 question when he said he didn't know what he was
16 doing.
17 COMMISSIONER KJELLANDER: I think that
18 was his response. Do you have a question?
19 Q. BY MR. FAIRFAX: Okay. You have down
20 here yearly annual certification class takes one
21 hour?
22 A. This is a monthly estimate, sir.
23 Q. So that would be one hour every single
24 month?
25 A. That is the 12 hours required annually
52
HEDRICK COURT REPORTING SMITH (X)
P.O. BOX 578, BOISE, ID Staff
1 spread over 12 months.
2 Q. Okay. That's my next question. Okay,
3 that's it.
4 COMMISSIONER KJELLANDER: Thank you.
5 Are there further questions, Mr. Cobott?
6 MR. COBOTT: Not at this time. I
7 might want to -- I might want to get some answers
8 from you later in this proceeding if possible, but
9 right now, I better calm down.
10 COMMISSIONER KJELLANDER: Okay. And
11 the witness will be available and if there is an
12 opportunity for that, we'll deal with it in the
13 appropriate fashion at that time if there are any
14 objections to further questions at that point.
15 Let's look now at moving towards
16 redirect. Oh, Commission questions first. Are
17 there questions from the Commission? And I think I
18 just have one that I'd like to get to.
19
20 EXAMINATION
21
22 BY COMMISSIONER KJELLANDER:
23 Q. Mr. Smith, do you have your testimony
24 with you?
25 A. I do.
53
HEDRICK COURT REPORTING SMITH (Com)
P.O. BOX 578, BOISE, ID Staff
1 Q. Okay. On the bottom of page 7,
2 lines 21 through 25, and the top of page 8, lines 1
3 through 4, I think that may be the testimony that
4 you were indirectly referring to in Mr. Cobott's
5 questioning. I was wondering if you might just sort
6 of give me a quick evaluation of that answer and
7 actually elaborate on what that means for the
8 Company in regards to some flexibility that may
9 provide them with regards to how they deal with and
10 pay for individuals?
11 A. Can I have just a moment to read back
12 through that?
13 Q. Certainly.
14 A. All right, sir, I think I can respond
15 to that.
16 Q. Thank you.
17 A. As I responded to Mr. Cobott to one of
18 his questions, when the Staff makes a recommendation
19 for a total revenue requirement, we have to do it on
20 the basis of some building blocks. You have to
21 build up to what a reasonable revenue requirement
22 is. Those building blocks include reasonable
23 expenses for testing, reasonable expenses for
24 electricity, reasonable compensation for labor, for
25 the various functions of labor. Management labor,
54
HEDRICK COURT REPORTING SMITH (Com)
P.O. BOX 578, BOISE, ID Staff
1 as I indicated to Mr. Cobott, certainly carries a
2 higher compensation level than does normal, everyday
3 operation and maintenance of the physical plant. We
4 have to come up with these building blocks, one on
5 top of another.
6 In putting together the exhibits, the
7 compensation allowed or recommended in this case,
8 however you would like to characterize it, for labor
9 or for management has been set at a higher rate than
10 what we would use for the normal operation and
11 maintenance of the system. All of those labor
12 dollars added together create a labor dollar pool,
13 if you will. It's up to the owner to decide how to
14 distribute the moneys that he receives, whether he
15 spends it on management labor expenses or on
16 operation and maintenance of the physical plant. He
17 is not required to pay himself exactly what is
18 recommended and finally finds its way into his
19 rates. He can pay himself a higher salary, a lower
20 salary. He can use that money to contract out with
21 contract labor somewhere, hire a serviceperson to
22 come in. We're indifferent as to how those dollars
23 are spent, so long as they are spent in a prudent
24 matter on the water system.
25 Is that responsive?
55
HEDRICK COURT REPORTING SMITH (Com)
P.O. BOX 578, BOISE, ID Staff
1 Q. So, in essence, then there is some
2 flexibility contained within the rates that are
3 recommended here with regards to Mr. Cobott's
4 ability to have a higher salary than, say, $80 a
5 week?
6 A. Oh, certainly. In my testimony, I
7 believe I specifically said that this is not
8 intended to represent a budget with budget line
9 items that must be followed to the letter.
10 Q. Thank you, Mr. Smith.
11 COMMISSIONER KJELLANDER: Are there
12 further questions from members of the Commission?
13 COMMISSIONER HANSEN: I have one.
14 COMMISSIONER KJELLANDER: Commissioner
15 Hansen.
16
17 EXAMINATION
18
19 BY COMMISSIONER HANSEN:
20 Q. Mr. Smith, on your Exhibit 102, I
21 think you addressed a question on that, but I would
22 like to know when you make those comparisons, is
23 there similarities that are basic to all water
24 companies in these comparisons you make?
25 A. Oh, all of the water companies have
56
HEDRICK COURT REPORTING SMITH (Com)
P.O. BOX 578, BOISE, ID Staff
1 certain similarities. They have the same kind of
2 billing costs for their customers. They still have
3 to maintain customer ledger cards, accounts
4 receivable cards. They have to pay their electric
5 bills. They have to perform the same water tests as
6 all of the other systems have to perform.
7 The differences lie primarily in, say,
8 how deep their well is, maybe requiring more
9 electricity for pumping power; possibly whether or
10 not the system requires certain amount of treatment,
11 chlorination on some systems, other systems don't
12 require chlorination. That makes a little bit of a
13 difference. They're fairly minute nuances that
14 separate one company from another, but they can --
15 they can vary from one company to another.
16 It's been my experience dealing with
17 these companies in the let's say 12, 14 customer
18 range up to 50 customers, that it really doesn't
19 make a lot of difference how many customers they
20 have in that range. Their costs are still fairly --
21 fairly common. The incremental cost of maintaining
22 a system of 50 customers is not that much greater
23 than a system of 14 or 15 customers.
24 Q. I see. Thank you. That's all I have.
25 COMMISSIONER KJELLANDER: Commissioner
57
HEDRICK COURT REPORTING SMITH (Com)
P.O. BOX 578, BOISE, ID Staff
1 Smith.
2
3 EXAMINATION
4
5 BY COMMISSIONER SMITH:
6 Q. So just to be following up on your
7 last comment then, it's more costly to serve fewer
8 people?
9 A. That's generally true.
10 Q. On your Exhibit 102, how did you
11 choose these companies? I mean, I was trying to see
12 if -- they don't appear to have the same number of
13 customers, so I was curious, why did you choose out
14 of all the water companies, why did you choose
15 these?
16 A. I chose these companies because
17 they're in the Coeur d'Alene/Sandpoint area,
18 basically, and they are under the Commission's
19 regulation, which is the only -- the only companies
20 we have data on.
21 Q. So I guess was your thought that since
22 they're in the same geographic area they would have
23 the same maybe, you know, geography or impediments
24 in terms of service and in terms of geography, or
25 what was your thought there?
58
HEDRICK COURT REPORTING SMITH (Com)
P.O. BOX 578, BOISE, ID Staff
1 A. No, I was thinking more in terms of
2 the cost of doing business, the economy of the area,
3 more than I was the geography.
4 Q. Okay.
5 A. The geography of, say, the McGuire
6 system at Post Falls versus Mr. Cobott's system are
7 entirely different. The system at Post Falls is on
8 old, flat farm ground. Mr. Cobott's is vertical
9 every direction you go.
10 Q. Thank you.
11 COMMISSIONER KJELLANDER: Thank you.
12 Being no further questions from the Commission, we
13 move now to redirect.
14 MS. NORDSTROM: Thank you.
15
16 REDIRECT EXAMINATION
17
18 BY MS. NORDSTROM:
19 Q. Mr. Smith, I know that we've discussed
20 the labor expenses pretty extensively. You mention
21 in your testimony I believe it was on pages 3
22 through 5 that the total labor expense that you had
23 come to for administrative maintenance and operation
24 costs was $8,960. Mr. Cobott's testimony indicated
25 that the 76 hours that he estimated were required to
59
HEDRICK COURT REPORTING SMITH (Di)
P.O. BOX 578, BOISE, ID Staff
1 manage and operate the system came to a total of
2 $1,520 a month. Your number is an annual number and
3 his is a monthly number. Why are these numbers so
4 far apart, in your estimation?
5 A. Well, that's why I put together the
6 rebuttal exhibit, to try and eliminate some of what
7 appears to be duplicate of hours. Several of the
8 functions that Mr. Cobott included in his
9 calculation appears to count the same function for
10 more than -- say, an hour's worth of labor has been
11 counted three times and it comes up with three hours
12 for doing simultaneous activities.
13 Q. Now, when you say that these tasks are
14 duplicative, are you saying that they're being
15 attributed to the same person more than once, or
16 both he and another worker are doing the same task?
17 A. I believe I found them both ways.
18 Q. Okay.
19 A. There appears to be, well, as an
20 example, I believe Mr. Cobott indicated he makes
21 eight trips a month to the water system to tour the
22 system, checking for leaks, check on the reservoirs,
23 et cetera.
24 Q. Okay. And that's number 16 on his
25 page 2?
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HEDRICK COURT REPORTING SMITH (Di)
P.O. BOX 578, BOISE, ID Staff
1 A. I seem to have left Mr. Cobott's
2 testimony in my room.
3 Q. (Indicating.)
4 A. Yes, that's correct.
5 Q. Okay. And what was duplicative about
6 that?
7 A. There is also time on the detail from
8 Mr. Fairfax indicating that he cruises the system on
9 a weekly basis, I believe it is, looking for leaks,
10 checking the reservoirs. If Mr. Fairfax is cruising
11 the system every week checking for leaks, I see it
12 unreasonable to expect Mr. Cobott to be duplicating
13 that by making eight trips a month to do the same
14 function.
15 Q. Based on your review of Mr. Cobott's
16 testimony, was it your understanding that he was
17 doing all the tasks of Larry Fairfax since
18 Larry Fairfax had apparently quit, based upon the
19 knowledge that you had?
20 A. We received a letter from Mr. Cobott
21 indicating that Mr. Fairfax had quit. Now, I notice
22 that Mr. Fairfax is here today, so I don't know
23 whether that was a one-day thing. Maybe Mr. Fairfax
24 is working for the Company, I just do not know.
25 Q. So it's a duplicate expense only if
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HEDRICK COURT REPORTING SMITH (Di)
P.O. BOX 578, BOISE, ID Staff
1 Mr. Fairfax is continuing to work for the Company?
2 A. And if left as Mr. Cobott submitted it
3 in his exhibits and testimony, yes.
4 Q. You have mentioned that there were
5 expenses that you believed were being attributed to
6 the same person more than once. Could you give an
7 example of that?
8 A. If you would refer to my Exhibit
9 No. 119 and the -- I apologize that I didn't do a
10 very good job of referencing the columns on this
11 exhibit, but about the second or -- one, two --
12 about the third column over where it says Cobott
13 average hours per month, in that column you notice a
14 few zeros show up. On the far right, I have some
15 references A, B, C, and D that are explained down
16 below in the footnote that A, B, C, and D equal
17 duplicative, simultaneous activities.
18 If you look on line 1 of this exhibit
19 you notice that there's a "A" on the far right
20 corner, and on line 7 in the far right column
21 there's an "A." Those appear to be duplicate,
22 simultaneous-type functions. That's just one
23 example.
24 The same holds true for the items
25 indicated with a "B." Those, to me, would be
62
HEDRICK COURT REPORTING SMITH (Di)
P.O. BOX 578, BOISE, ID Staff
1 activities that would be accomplished simultaneously
2 rather than independent of one another.
3 Q. In your rebuttal testimony, you also
4 came up with a different total labor number than the
5 $8,960. I believe on the second page of your
6 testimony, you state that Staff Exhibit No. 119
7 produces a total labor expense of $10,060.63. Could
8 you explain the difference between these two
9 numbers?
10 A. They just come from two different
11 analyses. They are not too awful far apart. The
12 analysis on the rebuttal testimony that produces the
13 $10,060 is based upon the detailed labor by function
14 as shown on these exhibits at the rates -- the
15 hourly rates -- provided to me by the Department of
16 Labor yesterday to come up with a bottom-line
17 number. When I put together my initial testimony, I
18 did not have this kind of hourly detail on the
19 various functions.
20 Q. And on what did you base your list of
21 detailed functions? What additional information did
22 you receive that helped you come up with this second
23 analysis?
24 A. This is from the data prefiled by
25 Mr. Cobott and Mr. Fairfax.
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HEDRICK COURT REPORTING SMITH (Di)
P.O. BOX 578, BOISE, ID Staff
1 Q. I'm sorry, I believe I interrupted
2 you. You said that this was part -- the difference
3 between these two numbers, the $8,900 number and the
4 $10,000 number, was due to?
5 A. They're simply just two different
6 types of analyses: One based upon, as I indicated a
7 moment ago, the detailed hourly functions as
8 provided by Mr. Cobott and Mr. Fairfax in their
9 exhibits and testimony to come up with this $10,060.
10 The initial analysis was based upon, as I indicated
11 in my original testimony, based upon interviews with
12 Mr. Cobott and what appeared to be reasonable rates
13 in basically two functions -- one function being
14 management and the other function being operation
15 and maintenance -- with no distinction as to what
16 each of the individual activities might have been
17 within those two broad categories.
18 Q. Is it your testimony that these two
19 numbers provide a reasonable range of total labor
20 expenses in this case?
21 A. I believe that these two separate
22 analyses together with the comparisons that I show
23 in my Exhibit 102 with other companies indicates
24 that they're in a reasonable range, yes.
25 Q. Are the labor expenses that are
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HEDRICK COURT REPORTING SMITH (Di)
P.O. BOX 578, BOISE, ID Staff
1 allocated or that you are proposing be allocated to
2 Ponderosa Water, are they in a range of
3 reasonableness with other Northern Idaho small water
4 companies?
5 A. Yes.
6 Q. Would you state that they -- what you
7 are recommending in this case tends to be higher or
8 lower than what you would consider average for
9 Northern water -- small water companies?
10 A. They're at the top end.
11 Q. Okay. Directing your attention to the
12 issue of the mortgage expense, Mr. Cobott stated in
13 his testimony on the second page of his testimony
14 that he used 30,000 of the $77,000 loan for the new
15 well. Your testimony on page 10 states that the
16 well cost just over $25,000. Do you know what
17 accounts for the $5,000 difference between your
18 number and Mr. Cobott's number?
19 A. No.
20 Q. Have you discussed that with him at
21 all?
22 A. No. I just got his testimony here
23 yesterday and I haven't had a chance to speak
24 privately with Mr. Cobott since he arrived today.
25 Q. And on what are you basing your
65
HEDRICK COURT REPORTING SMITH (Di)
P.O. BOX 578, BOISE, ID Staff
1 $25,000 round number?
2 A. That's based upon the invoices
3 provided to me by Mr. Cobott last March.
4 Q. On the issue of water testing, on your
5 Exhibit No. 101, you have several different line
6 items for water testing. One of those, line 12 --
7 or, line 11, rather -- is $1,500 for water tests
8 from two sources. Are those for the tests
9 themselves or the labor necessary to conduct those
10 tests?
11 A. Those are the lab costs to have the
12 tests performed at a State-licensed lab on two
13 separate water sources.
14 Q. Is Staff and Mr. Cobott in agreement
15 on that figure?
16 A. I believe we are.
17 Q. Okay. You also indicated on Exhibit
18 No. 101 that money has been allocated for the daily
19 testing of the water, the labor that is required to
20 do that. How much is allocated to test the water?
21 A. How much labor?
22 Q. Yes.
23 A. On this exhibit, I didn't make that
24 kind of a distinction. I don't believe I did. Hope
25 I haven't misspoken here.
66
HEDRICK COURT REPORTING SMITH (Di)
P.O. BOX 578, BOISE, ID Staff
1 Q. I'd like to direct your attention to
2 line 28.
3 A. I beg your pardon. I did split that
4 out. And the daily water testing, that includes
5 more than just taking a water test, however. That's
6 a daily visit to the wellhouse, taking the water
7 test. It's basically Mr. Fairfax's daily check on
8 the pumping system, make sure that the chlorination
9 is working, checking the chlorine level, taking the
10 water samples, the whole works.
11 Q. Okay. Your exhibit indicates under
12 Column C that Ponderosa estimates this expense to be
13 $3,600. You've only allocated 1,000 -- or, $1,800.
14 Why is that?
15 A. Because there's approximately another
16 $1,800 embedded in the electricity price on -- if I
17 can find it here. Where is pumping power -- in the
18 electricity price shown on line 6.
19 Q. So on line 28 when you say $10 per
20 day, less $5 for electric power, does that mean that
21 half of the $3,600 is being attributed to
22 Mr. Fairfax in electricity rather than wages?
23 A. That was a number that was provided to
24 us by Mr. Cobott, by Mr. Fairfax I believe, that
25 indicated that there was approximately $150 that was
67
HEDRICK COURT REPORTING SMITH (Di)
P.O. BOX 578, BOISE, ID Staff
1 considered to be compensation to Mr. Fairfax for his
2 labor that was the value of the electricity that he
3 received monthly through the Water Company's
4 electric meter at the pumps.
5 Q. The $150 number, is that a monthly
6 number or an annual number?
7 A. Monthly, I believe. Yes, that's
8 right, monthly.
9 Q. On the issue of property taxes, you
10 indicated in your testimony that $286.86 was an
11 appropriate cost. How did you calculate that
12 number?
13 A. That number is based upon the
14 valuation of approximately $26,000 for the new well,
15 multiplied by the Bonner County assessment rate of I
16 believe it's -- I've got it in here somewhere --
17 point 14447 -- goes out for about eight digits.
18 That was given to me by the Bonner County
19 Treasurer's office -- or, Assessor's office, excuse
20 me.
21 Q. So do you agree with Mr. Cobott in his
22 testimony when he says that property taxes cost
23 about $2,300?
24 A. That would be close.
25 Q. Okay. And in coming up with an annual
68
HEDRICK COURT REPORTING SMITH (Di)
P.O. BOX 578, BOISE, ID Staff
1 revenue requirement, did you allocate any money to
2 pay Ponderosa for rent of the land on which the
3 water system sits?
4 A. No.
5 Q. Why did you feel that that was not
6 appropriate?
7 A. The purchase and sale agreement for
8 the purchase of the land or purchase of the water
9 system is attached as Exhibit No. I believe it's
10 104. The language in that contract indicates that
11 the land upon which the well is situated were part
12 and parcel of the water system. They were included
13 with it and transferred as a part of that purchase.
14 Therefore, the land, it would appear to me, belongs
15 to the Water Company.
16 Q. Okay. Mr. Cobott has indicated that
17 he -- that the -- he personally should be
18 compensated $100 a month for use of his excavator.
19 Did you include that in your revenue requirement?
20 A. That is included, yes.
21 Q. And did you determine that that was an
22 appropriate figure to attribute to that expense?
23 A. I relied on my fellow Staff member
24 Michael Fuss for the reasonableness of that rate.
25 He's more familiar with heavy equipment than am I,
69
HEDRICK COURT REPORTING SMITH (Di)
P.O. BOX 578, BOISE, ID Staff
1 and as an engineer, he has rented numerous pieces of
2 equipment. He thought that was a reasonable rate,
3 so I accepted it.
4 Q. So that issue is not in dispute?
5 A. No.
6 Q. Returning your attention to Exhibit
7 No. 101, line 10, you recommend that $2,600 be
8 allocated for system repair. Do you believe that to
9 be an accurate number?
10 A. That was a number that was provided by
11 Mr. Cobott a number of months ago. It didn't appear
12 to be terribly unreasonable and we had no reason to
13 challenge it so we did not, and it is included.
14 Q. Based upon the testimony filed by
15 Mr. Cobott and Mr. Fairfax, do you have cause to
16 question that particular figure?
17 A. If the Commission were to accept the
18 recommendations of Mr. Cobott and Mr. Fairfax for
19 the costs they have enumerated, I believe that would
20 duplicate many of the dollars that were included in
21 this estimate to begin with, so I think it would
22 probably have to be adjusted downward if those labor
23 costs as prefiled by Mr. Cobott and Fairfax are
24 accepted.
25 Q. So are you saying that some of the
70
HEDRICK COURT REPORTING SMITH (Di)
P.O. BOX 578, BOISE, ID Staff
1 labor expenses that are being requested by
2 Mr. Cobott and Mr. Fairfax are accounted for in this
3 system repair expense?
4 A. That's correct.
5 Q. Thank you. I have no further
6 questions at this time.
7 COMMISSIONER KJELLANDER: Thank you,
8 Mr. Smith. And I think at this point then we'll
9 excuse you and allow the next witness to be called.
10 (The witness left the stand.)
11 MS. NORDSTROM: As its next witness,
12 the Staff would call Michael Fuss.
13
14 MICHAEL FUSS,
15 produced as a witness at the instance of the Staff,
16 being first duly sworn, was examined and testified
17 as follows:
18
19 DIRECT EXAMINATION
20
21 BY MS. NORDSTROM:
22 Q. Good afternoon. Please state your
23 name and spell your last for the record.
24 A. Michael Fuss, F-U-S-S.
25 Q. By whom are you employed and in what
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HEDRICK COURT REPORTING FUSS (Di)
P.O. BOX 578, BOISE, ID Staff
1 capacity?
2 A. By the Idaho Public Utilities
3 Commission, and I'm a Staff engineer.
4 Q. Are you the same Michael Fuss that
5 filed direct testimony on June 7th, and prepared
6 Exhibit Nos. 107 through 116?
7 A. Yes.
8 Q. Do you have any changes or corrections
9 to your testimony or exhibits?
10 A. None that I'm aware of.
11 Q. If I were to ask you the questions set
12 out in your prefiled testimony today, would your
13 answers be the same?
14 A. I believe so, yes.
15 MS. NORDSTROM: I'd move that the
16 prefiled direct testimony of Michael Fuss be spread
17 upon the record as if read, and that the
18 aforementioned exhibits be marked for
19 identification.
20 COMMISSIONER KJELLANDER: Without
21 objection, we'll spread the testimony as if read,
22 and introduce Exhibits 107 through 116.
23 (The following prefiled direct
24 testimony of Mr. Fuss is spread upon the record.)
25
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HEDRICK COURT REPORTING FUSS (Di)
P.O. BOX 578, BOISE, ID Staff