HomeMy WebLinkAbout20181228Staff Report.pdf,trc r l\,/EDBRANDON KARPEN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-03s7
IDAHO BAR NO. 7956
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Street Address for Express Mail:
472W, WASHINGTON
BOISE, IDAHO 83702-5918
Attomey for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE INVESTIGATION
OF ATLANTA POWER COMPANY
SERVICE AND CUSTOMER RELATIONS
CASE NO. ATL-E-18.01
The Staff of the Idaho Public Utilities Commission submits this report on issues related to
the Atlanta Power Company.
PROCEDURAL BACKGROUND
In the spring of 2017 , Staff received a number of complaints from residents of Atlanta,
Idaho, concerning electric service being provided by Atlanta Power Company. The customers
stated that the Company's hydroelectric turbine was no longer working and the Company was
using a diesel generator to provide electric service. It was reported that the generator was
regularly running out of fuel and electric service outages were occurring frequently for
significant periods of time. On January 2,2018, Atlanta Power customer Mary Drake filed a
Formal Complaint against Atlanta Power Company claiming the Company is violating
Commission Order No. 3 1086 and Idaho Code 6l -302 by failing to maintain adequate service.
On January 22,2018, Staff requested that the Commission direct the Company to respond
to the Formal Complaint of Mary Drake, and to open a formal Staff investigation into the
Company to respond to issues raised in informal complaints. Staff recommended that the
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ISTAFF REPORT DECEMBER 28, 2018
STAFF REPORT
investigation focus on service reliability, maintenance and operation of the Company's facilities,
and customer service. As part of its investigation, Staff was directed to review the Company's
compliance with past orders, inspect generation and distribution facilities, and confer with
customers.
On May 10, 2018, Staff submitted a preliminary report on the condition of the Company,
including the status of a reported downed service line. On July 3 7,2018, the Commission
requested Staff to prepare a more detailed analysis of the issues related to the Company before
the end of the year. The Commission said it would consider further action as needed.
Staff now submits its Report discussing its findings.
STAFF REPORT
Staff s substantive findings and recommendations are attached as Attachment A.
Respectfully submitted this 28th day of December 2018.
YG
2STAFF REPORT DECEMBER 28, 2018
'1913 f
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7a
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Case No. ATL-E-18-01
December 28,2018
Michael Eldred
Johnathan Farley
Brad Iverson-Long
Richard Keller
Kevin Keyt
STAFF REPORT
BACKGROUND
On September I I ,2000, the Commission received a petition from residents of Atlanta,
Idaho. The petition explained that Atlanta Power customers were concerned about issues
including: 1) inconsistent service and power quality; 2) extended outages and untimely response
times to system issues; 3) poor communication between the Company and its customers; 4) the
lack of qualified personnel to troubleshoot problems and make repairs; and 5) the lack of an
operational back-up generator.
In October of 2000, Staff felt it premature for the Commission to formally investigate
Atlanta Power. Staff thus recommended an informal investigation. Staff proposed to perform a
financial audit, compile outage information, identify potential system improvements, and survey
customers to gauge their willingness to pay the higher rates associated with upgrading the
system. Staff s informal investigation lasted about two years.
On March 6,2003, Staff presented its findings to the Commission in a Decision
Memorandum. Staff reported it had worked with the Company and customers to identiff and
address three problems areas: 1) the lack of an onsite back-up generator; 2) the lack of back-up
personnel; and 3) poor communications between the Company and its customers about outages.
Because of Staff s investigation, the Company hired Randy Nye, another Atlanta resident, to
back up the system operator, Dave Gill, and procured a telephone messaging system to notify
customers of planned outages and provide progress reports on system repairs. As a result of the
customer survey performed by Staff, purchasing and installing a back-up generator was not
recommended. Customers surveyed did not want to pay for the additional expense through rates.
On April 10,2003, the Commission opened Case No. ATL-E-03-01 and issued a Notice
of Proposed Order on April 10,2003. Summaries of Staff s report and copies of the Notice of
Proposed Order were sent to all customers.
On June 28,2003, Commission Staff conducted a public workshop in Atlanta, Idaho.
The Company's overdue annual reports were a major concern at the workshop. Without the
annual reports, customers were concerned that the Commission would not have the requisite
information to properly regulate and set rates for the Company. The Company agreed to prepare
and file all overdue annual reports.
On September 3, 2003, Atlanta Power's president, Lynn Stevenson, was murdered. Israel
Ray was elected president by the principal shareholders.
ATTACHMENT AI
In 2005, the Commission issued its final order and closed Case No. ATL-E-03-01. By
then, Mr. Ray had become the majority shareholder and president of Atlanta Power and had
improved the Company's operating procedures and physical plant in service. In the
Commission's final order, Order No. 29706, the Commission found that the Company had made
several physical system improvements including:
1. A hole in the bladder that operates the spillway gates that control water flow to the
turbine has been repaired.
2. Four of the wicket gates that control water flow through the turbine have been repaired.
3. Broken or badly warped cross arms have been replaced.
4. A transformer support structure has been replaced.
5. One or more new transformers have been installed to better regulate system voltage.
6. The engine in the Company's old line truck has been replaced.
7. A new line truck has been purchased that can be operated by a single person from the
bucket.
8. The Company's inventory of poles and other supplies has been increased.
The Commission concluded Atlanta Power had improved the physical plant, system
reliability, regulatory accounting practices, and customer relations. The Commission attributed
the improvements to the change in ownership and Company management. In its closing
remarks, the Commission directed Staff to continue working informally with the Company and
its customers to address customer concerns and work toward the continued betterment of electric
service in Atlanta.
In April of 2009, Allen Lake filed a complaint against Atlanta Power Company. Mr.
Lake asserted that he was receiving an inadequate power supply to run a dishwasher he had
installed as part of a home remodeling project.
On August 28,2009, two Idaho Power Company engineers analyzed power quality in
Atlanta. The engineers found that the system frequency varied +/- 10 cycles per second (CPS)
from an ideal 60 CPS. As a solution, a tensioner was built to tighten the chain on the governor
that controlled the wicket gates in the turbine. By tightening the chain on the governor, Atlanta
Power planned to reduce the governor's response time to frequency changes and stabilize the
system frequency. Atlanta Power designed and installed the tensioner but the system frequency
problems persisted. Atlanta Power suggested conditioning the powerhouse in order to avoid
2 ATTACHMENT A
lubricants thickening in colder weather and offsetting the gains in response time that the
tensioner provided.
In November 2009, Mr. Lake filed a formal complaint against Atlanta Power, and the
Commission opened Case No. ATL-E-09-01. In that case, Commission Staff identified two
solutions to address the system frequency issues Mr. Lake was experiencing. The first solution
was for Atlanta Power to buy and install a double conversion uninterruptible power supply
(UPC) in Mr. Lake's home. The UPC would convert Atlanta Power's AC power to DC and store
it in batteries, then convert the DC power back into AC at 60 cps using an inverter. Staff
believed that installing a UPC would eliminate Mr. Lake's problem for about $2,000 but would
only address the problem on a single circuit in Mr. Lake's home. Staff knew that other
customers served by Atlanta Power were experiencing the same frequency issues as Mr. Lake,
and identified a second solution that would address the whole system.
Staff s second solution was to replace Atlanta Power's turbine-generator control systems.
Staff asserted that a more accurate control system would stabilize the power line frequency by
detecting when the system frequency began to change and then quickly adjusting the wicket
gates. Staff concluded that upgrading the turbine-generator control system was the most cost-
effective solution to the power line frequency problem. However, Staff was concerned that the
$15,000 to $25,000 investment would increase rates, cause customers to leave the system, and
ultimately jeopardize Atlanta Power's financial viability. Staff thus recommended the Company
continue to pursue low-cost system improvements, and that Staff evaluate the Company's
financial position after November 2011, when the Company had satisfied a $ 1,460-a-month loan.
On May 13,2010, the Commission issued Order No. 31086 in Case No. ATL-E-09-01.
The Commission accepted Staff s recommendations for pursuing low-cost system improvements
and evaluating the Company's financial position after the Company satisfied its loan in
November 2011. The Commission ordered Commission Staff and Atlanta Power to "continue to
monitor the power quality concerns. If the power quality issues are not satisfactorily mitigated
by November 1,201l, then Staff and the Company will advise the Commission on an
appropriate course of action."
In Novemb er 201I , Staff evaluated the Company's financial position using the financial
records available at the end of the Company's loan term. Staff determined that rates did not need
J ATTACHMENT A
SERVICE RELIABILITY
The Distribution System
On March 14,2018, Atlanta Power customers reported a service line had detached from a
support and was on the ground. The customers were concemed the downed service line could
endanger people and animals that contacted it.
On March 29,2018, Commission Staff travelled to Atlanta to investigate the situation.
Staff saw the service line had fallen and was partially buried in snow, but the wire connections
were still intact. Staff surmised the low-hanging service line detached from a support pole when
a large amount of snow slid off a nearby roof and snagged the line. Due to weather and road
conditions, Staff could not investigate the entire distribution system.
On May 15,2018, Staff returned to Atlanta to continue its investigation. Staff found the
overhead distribution system consisted of poles, attachments, and transformers that exhibited a
range of conditions. Some equipment appeared to have been recently upgraded while some
equipment was derelict or broken. Staff noted several low-hanging lines and many poles that
were rotted at the base or leaning. Instead of replacing these poles, the Company used thru-bolts
or straps to join the old pole to a shorter anchor pole.
Staff also found transformers ranging in age and condition from near new to antiquated.
Some transformers showed signs of damage and possible leakage. Staff also identified
ATTACHMENT A4
to be reduced based on investments made by the Company. Staff continued to work with Atlanta
Power on an informal basis to address ongoing systems issues.
On January 2,2018, Mary Drake formally complained that the Company was violating
Commission Order No. 3 1086 and Idaho Code $ 6l-302 by not maintaining adequate service.
See Attachment B. Ms. Drake addressed frequent power outages, public safety, lack of qualified
personnel to operate and maintain Company facilities, and the Company's inaccessibility and
failure to respond to customer complaints.
On February 20,2018, the Commission opened Case No. ATL-E-I8-01. The
Commission ordered the Company to respond to Mary Drake's formal complaint, and Staff to
conduct a formal investigation. Staff s investigation focused on service reliability, maintenance
and operations, and customer service. See Order No. 33988.
questionable Company practices, such as using pine trees as utility poles and service drops to
meters supported by a piece of wood above the customers' rooflines.
Power Generation
The Company has two sources of power generation, a run of river hydroelectric turbine
and a diesel electric back-up generator. The hydro plant has failed several times in recent years
and most recently in the spring of 2017. Issues with the electronic load govemor put the turbine
out of service for approximately three months.
On March 29,2018, when Staff inspected the dam site and powerhouse Staff was
informed that concerns remained about the electronic load governor. Several spillway gates that
control the flow of water into the reservoir were inoperable. The Atlanta Fire Chief, Gene
Haught, was concerned that the reservoir's water level would damage the electronic load
governor. He was also concerned that the reservoir water level could get too high and potentially
damage the dam.
During Staff s May 15 site inspection, Staff saw the fuel storage tank for the diesel
electric generator in the Company's equipment yard was on wooden blocks without secondary
containment. Staff noted that secondary containment would help mitigate ftrehazards from
leaks and spills and prevent environmental contamination. Staff was also concerned with the
generator's exposure to the elements. Though the generator is enclosed, both doorways at
opposite ends of the building are open to the elements.
Service Outages
In December 2016, an outage occurred when equipment malfunctioned in the
powerhouse. The Company lacked adequate insulation for the equipment in the system control
room, and the equipment failed because of excessive cold. When the Company switched to
auxiliary power (a diesel generator), the generator ran out of fuel due to the reserve not being
filled completely. The Company has a reserve capacity of 1,500 gallons of diesel but the
Company's fuel supplier has a minimum delivery requirement of 3,000 gallons.
On March 12,2017, the hydroelectric turbine went down and the Company had to use the
diesel electric back-up generator to serve customers. The Company had attempted to service the
turbine but could not restart the system after completing the repairs. On March 27,2017,the
5 ATTACHMENT A
diesel electric generator ran out of fuel and service was out for all customers. The Company had
to borrow fuel from the local highway district and the local mine to operate the generator.
The generator ran out of fuel again on April 26, andthe Company could not have fuel
delivered until May 2. Outages continued to plague the system throughout the year, culminating
in a 13-hour long outage on January 1,2018.
Safety Concerns
On March 29,2018, Staff identified a potential safety hazard posed by exposed drive
pulleys and belts on the turbine-generator. Although a makeshift railing separated building
access from the turbine-generator drive, Staffbelieves the barrier inadequately protects personnel
who enter the powerhouse.
Though the Company had repaired the downed service line reported to the Commission
in March 2018, Staff identified several other issues during its May 2018 inspection. Staff found
damaged transformers, leaning or rotted poles, low hanging lines, and questionable methods used
for routing and securing lines. In its May 2018 report to the Commission, Staff expressed
concern that the system may not satisfy the National Electric Safety Code, and that further
investigation may be warranted.
OPERATIONS & MAINTENANCE
Personnel
Currently, the Company has three employees, a bookkeeper (Linda Churches), a
maintenance person (Gene Haught), and a meter reader. The bookkeeper does not live in Atlanta
and works remotely. The maintenance person and meter reader live in Atlanta, Idaho.
Linda Churches produces and mails billings/notices, collects and deposits payments, and
reconciles customer usage with billing. Though she makes monthly cash deposits, she cannot
access the Company's financial records and she lacks check-writing authority.
The Company hired the Atlanta Fire Chief, Gene Haught, as the maintenance person in
May 2018. He performs general maintenance like greasing the turbine fittings, cleaning debris
from the spillway and syphon tube gates, etc. He can stop and reboot the turbine-generator and
program the electric governor, but he is not responsible for troubleshooting the generation or
distribution systems, making repairs, or performing any duties comparable to those of a lineman
6 ATTACHMENT A
or electrician. Much like the bookkeeper, Mr. Haught lacks check-writing authority and account
access. He relies on the owner to provide the materials he needs to complete his daily functions.
The Company employs a meter reader whose sole function is to report each customer's
use to the bookkeeper on a monthly basis. The Company has employed several people as the
meter reader in20l8. No matter who serves as the meter reader, the Company has required the
person filling that position live in Atlanta.
System Operator
The Company has not employed a system operator since December 2016. The system
operator troubleshoots the distribution and generation facilities, repairs and services equipment,
connects and disconnects services, and restores service outages. The previous system operator,
Dave Gill, was a longtime Atlanta resident who served in that position for over ten years.
In20l6, Dave Gill moved to Panama. The Company has struggled to hire a capable
replacement. Throughout2}lT, the Company had several prolonged outages and technical
mishaps that may have impacted customers less if the Company had a system operator.
In January 2018, customers reported to the Commission that Atlanta Power no longer had
a presence in Atlanta and customers were maintaining the generation and distribution systems.
Accounting and Financial Records
The Company has several known financial accounting and financial issues, and its lack of
regulatory compliance prevents Staff from knowing if it has further issues. The Company has
not filed an Annual Report with the Commission since 2007, and has not filed other necessary
documents, including an Inventory of Physical Properties and copies of maps and records in
compliance with Idaho Code $$ 6l-402,61-404, and 6l-605. Additionally, the Company has not
responded to all of the Production Requests issued by Commission Staff in ATL-E-18-01, has
not complied with past Commission orders, nor has it paid its annual Commission fees.
Staff has had only minimal access to any current financial information for the Company,
making it difficult to tell if the Company is financially viable. In response to a request from
Staff, the Company did report that it had 65 customers (57 residential, 8 commercial) as of
April20l8.
l ATTACHMENT A
Previously, employees, contractors and other persons, including customers, were
performing work for Atlanta Power but not getting paid for that work. Some customers who
performed work for the Company received credit on their electric bills in lieu of payment.
Recently, Staff was informed that all employees and contractors are getting paid for their work.
CUSTOMER SERVICE
Availability
In January 2018, Staff received reports that the Company was becoming increasingly
hard to contact. Previously, all calls for service were routed to the owner, Israel Ray. If
customers questioned billings and notices, they would contact the bookkeeper. Customers could
call the owner and bookkeeper directly or they could call a l-800 number that would route calls
to the owner.
Staff found the Company's 1-800 number was disconnected, and the owner was no
longer answering calls or returning messages from Staff or customers.
In March 2018,Israel Ray's brother, Ronald Ray, explained to Staff that his brother had a
medical condition that made it difficult for Israel to make rational decisions. Ronald Ray
claimed Israel needed continuous care, and that he would be travelling with Ronald to Alaska.
Staff has had no direct contact with Israel Ray since June2017, and believes he still resides in
Alaska.
Responsiveness and Dispute Resolution
On February 20,2018, the Commission ordered the Company to respond to Mary
Drake's formal complaint. See Order No. 33988, Case No. ATL-E-I8-01. The Company has
not responded to the complaint as of December 18, 2018. Additionally, the Commission has
issued four summons, and Staff has served two production requests since the case was opened.
All have gone unanswered.
Staff has tried to contact Israel Ray but has only reached his brother, Ronald Ray. As
noted above, on several occasions, Ronald has stated that Israel cannot make rational decisions,
and Ronald is uncertain if or when Israel will be able to do so. Staff has asked Ronald if he
would pursue a power of attorney for Israel. Ronald unequivocally replied that he would not and
is unwilling to take control of Atlanta Power.
ATTACHMENT A8
SUMMARY
The lack of response to Staff s requests for information (both formal and informal) has
impeded Stafls investigation in this case. Another major impediment to investigating and
attempting to resolve this case is that Israel Ray, the only person authorized to do business on
behalf of Atlanta Power, has been unavailable, and is apparently unable to perform his duties.
While it appears that some issues, such as hiring or contracting with people to maintain,
operate, and, if necessary, repair the system have been addressed, Staff remains concerned about
a number of issues, including how the system is being maintained, the condition of lines, poles
and other equipment, maintaining an adequate supply of diesel fuel for the back-up generator as
well as unresolved safety issues. With the arrival of winter, Staff is concerned that service
reliability will continue to be an issue.
STAFF RECOMMENDATION
Due to the Company's failure to respond to Staff s Production Requests and the uncertain
status of Israel Ray, Staff recommends that, as a next step, an Order to Show Cause be issued to
compel compliance with the Commission's Orders as well as statutory and regulatory
requirements.
9 ATTACHMENT A
ldaho Publlc UtllltlEs Commiiesion
Oflice of lhe SecretaruRECEIVED
JAN 0 2 20t8
$orse, ldaho
F ro m : f I u! e. r-n d @sm aiLtalt I m a i I t o : f I u tS..n-r-d.@ em a r l. c o |n ]
Sent: Tuesday, January 2,2418 L47 PM
To: Front <front@puc..idaho.sov>; Beverly Barker <Beverlv.Barker@puc.idaho.gov>
Subject: Consumer Assistance Form: Mary Drake
Name: Mary Drake
Ema il' f I ute. md (&j!I! il.conl
Telephone: 2A8854217t
Address: 72 E PINE ST
ATLANTA ID,837].6
Name of Utility Company: Atlanta Power Company Contacted Utility: Yes
Complaint: Mary t. Drake
72 E, Pine
Atlanta, ldaho 83715
ldaho Public Utilities Commission
472W. Washington
Boise, ldaho 83702
Dear Commissioners
Please consider this a formal complaint against Atlanta Power Company for failing to fulfill their lawful
duty of providing and maintaining adequate services of electricity to the town of Atlanta, ldaho, per
ldaho Statute 61-301. The Statute reads: "DUTIES OF PUBLIC UTILITIES 61-302. MAINTENANCT OF
ADEQUATE SERVICE. Every public utility shall furnish, provide and maintain such service,
instrumentalities, equipment and facilities as shall promote the safety, health, comfort and convenience
of its patrons, employees and the public, and as shall be in all respects adequate, efficient, just and
reasonable."
lhavebeenaresidentofAtlanta, ldahofor20years. lhaveexperiencedthechangeofownershipofthe
Atlanta Power Company. I am also aware of previous complaints about the services provided by the
company, and the ensuing Final Order of May 13, 2010. There is plenty of historical evidence that shows
there has been a problem with Atlanta Power Company outages for many years.
This complaint, today, is to inform you that Atlanta Power Company is NOT DOING WHAT they agreed to
do per the Final Order dated May 13, 2010 (Order # 31086) in which it states: "lt is further ordered that
Atlanta Power Company continue to monitor the power concerns. lf the power concerns are not
mitigated, then the staff and company will advise the commission on appropriate course of action." lt
has been 7 years since this order, and the power outages still occur. Many people have complained to
the PUC, yet no action is taken. This complaint poses the question: Why is the Atlanta Power Company
not being held accountable to uphold its duties as a utility provider by the PUC? Flease, we need helpl
Also, after an investigation into Atlanta Power Company by PUC in February, 2005, Order *29706,it
states that "lt appears Dave Gill's availability has changed. He is available in Atlanta for immediate
system repairs most of the time." This is NO LONGER TRUE. Dave Glll no longer lives in Atlanta, ldaho
Hence, this formal complaint, filed here, now is:
ATTACHMENT B
1. There continues to be frequent power outages in Atlanta, ldaho.
2. Power outages HARM the safety of Atlanta residents, due to needing access to electronics for
emergencies, drinking water (for those with electronic water pumps), and access to healthy food
(refrigerators go out and food spoils during outages).
3. There is no one in town who knows how to fix the system when the owner of Atlanta Power
Company (lsrael Ray) is out of town.
4. lsrael Ray does not hire anybody to be available to diagnose problems and fix problems during
outages.
5. Although there is a generator up here, in Atlanta, it does not function in cold weather, due to diesel
fuel.
6, lsrael Ray, as owner of Atlanta Power Company is not fulfilling his lawful duty as a utility company per
stAtUtC 61.302 WhiCh StAtES: DUTIES OF PUBLIC UTILITIES: 61-302. MAINTENANCE OF ADEQUATE
SERVICE. Every public utility shall furnish, provide and maintain such service, instrumentalities,
equipment and facilities as shall promote the safety, health, comfort and convenience of its patrons,
employees and the public, and as shall be in all respects adequate, efficient, just and reasonable."
Evidence that demonstrates Failure to comply with this statute includes, but not limited to:
a. There is no telephone number to call for assistance when the power goes out in Atlanta, ldaho. The
number to call ts lsrael's, and the message inbox is ALWAYS FULL. No other number to call, or way to
contact him or anybody who knows how to help during a power outage. This is blatant disregard for us,
consumers, customers, residents of Atlanta, who pay our bills to Atlanta Power Company every month
for services we EXPECT to receive in exchangel
b. lsrael Ray leaves town and nobody has any way to contact him. He leaves town and is nowhere to be
found during a power outage, nor has he trained anybody to help during his absence. This is simply
irresponsible, and a blatant disregard for Statute 61-302.
7. After many, many years of problems with the power in Atlanta, ldaho, there seems to be no
resolution. lf something gets fixed, it's momentary. Granted, there is a generator up here now, but it
doesn't start in the winter, and in the summer, it runs out of gar and we need to wait days before we
get diesel gas up here. Therefore, the Time is NOW to fix the problem ! | When witl this be resolved??
Please, please give attention to this formal complaint. The situation in Atlanta needs ATIENTION nowl
lsrael Ray and The Atlanta Power Company need to be held accountable for their LACK of ACTIONS in
adhering to the law for public utilities. For, l, myself am a paying customer, as are many others in this
town and we simply WANT TO NOT HAVE TO DEAL WITH THE CONSTANT POWER OUTAGES and TOTAL
LACK OF CUSTOMER CONSIDtRATION, and the lack of ACCOUNIABILITY demonstrated by lsrael Ray and
the Atlanta Power Company.
Thank you for your action in this matter
Sincerely,
s/ Mary E. Drake
Mary E. Drake
U nique ldentifier: 275.182.LLL.139
ATTACHMENT B
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 28TH DAY OF DECEMBER 2018,
SERVED THE FOREGOING STAFF'REPORT OF THE COMMISSION STAFF, IN
CASE NO. ATL-E-I8-01, BY E-MAILINGANDMAILING A COPY THEREOF,
POSTAGE PREPAID, TO THE FOLLOWING:
ISRAEL RAY
ATLANTA POWER COMPANY
I I I40 CHICKEN DINNER RD
CALDWELL ID 83607
ELECTRONIC SERVICE ONLY
ATLANTA WATER ASSOC INC
th eerm y o bri en @) gra ai L c o r:r
dv ancc. awafg) grnail. c om
ri ckand ev),jenki ns (r) gmai I . com
.net
ELECTRONIC SERVICE ONLY
ATLANTA LANDOWNER'S ASSOC
by greylock@)wildblue.net
andy.epoerson@ gmail.com
nratt(0boi seinIi ILcorn
i gi lles(d,cableone.net
STEVEN J MEADE
ATLANTA WATER ASSOC INC
PO BOX 1097
BOISE ID 83701E-MAIL:@
STEVEN J MEADE
ATLANTA LANDOWNER'S ASSOC
PO BOX 1097
BOISE ID 83701
E-MAIL: smeade@idalar.v.com
ELECTRONIC SERVICE ONLY
ATLANTA LAND OWNER
steve (.0p umpki nc re ekranc h. c om
SECRET
CERTIFICATE OF SERVICE