20040115Final Order No 29418.pdf

Office of the Secretary
Service Date
January 15, 2004
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE JOINT PETITION
OF AVISTACORPORATION AND
POTLATCH CORPORATION FOR
APPROVAL OF A POWER PURCHASE ANDSALE AGREEMENT
CASE NO. A VU-O3- 7
ORDER NO. 29418
On August 25, 2003, Avista Corporation dba Avista Utilities (Avista) and Potlatch
Corporation (Potlatch) filed a Joint Petition with the Idaho Public Utilities Commission
(Commission) requesting an Order approving a submitted Power Purchase and Sale Agreement
(Agreement) between Avista and Potlatch dated July 22, 2003. Potlatch operates a wood pulp,
paperboard, tissue and wood product manufacturing facility in Lewiston, Idaho. Potlatch owns
and operates four electric generators at the Lewiston plant that are capable of generating
approximately 130 megawatts (MWs) of energy. The Potlatch electric generators are qualifying
facilities (QFs) pursuant to the Public Utilities Regulatory Policies Act of 1978 (PURP A).
Direct testimony of A vista supporting the Purchase and Sale Agreement was filed with the
Commission on September 26 2003. Also filed with the Commission on October 10, 2003 is a
related Interconnection Agreement dated September 22, 2003.
The Commission in this Order approves the submitted A vistaIPotlatch Power
Purchase and Sale Agreement dated July 22, 2003. In doing so we find the contract terms
pricing, jurisdictional allocation and proposed recovery method to be reasonable and acceptable.
The Commission in this Order approves a recovery method and authorizes the booking of
A vista s power purchase costs in the Company s PCA deferral account. This Order has no
immediate rate effect and does not change the tariff rates for other customers. Recovery of
Potlatch power purchase costs by the Company will require a rate case or PCA filing.
Agreement
The submitted Power Purchase and Sale Agreement is for a ten-year term beginning
July 1 , 2003 and ending June 30, 2013. The Agreement is conditioned upon approval by the
Commission of 1) a direct assignment to A vista s Idaho operations of all power purchase costs
paid by A vista to Potlatch under the Purchase and Sale Agreement and 2) deferral and recovery
of 100% of all power purchase costs paid by A vista to Potlatch under the Agreement to A vista
ORDER NO. 29418
Idaho Power Cost Adjustment (PCA) mechanism (Schedule 66) or otherwise recovered by
A vista through base rates.
As recited in the Joint Petition of the parties, A vista will be the sole purchaser of
Potlatch's generation and said purchase is intended to satisfy Avista s obligations under PURPA
to purchase power from the qualifying facilities at the Lewiston plant. A vista will pay Potlatch
$42.92 per MWh up to a maximum base generation amount of 543 120 MWh (544 608 during a
leap year) generated by Potlatch during each July 1 through June 30 period (Operating Year) of
the Agreement. This amount is equivalent to 62 average megawatts (aMW) and is referred to in
the Agreement as the "Base Generation Amount." Amounts generated by Potlatch in excess of
the maximum Base Generation Amount each Operating Year ("Excess Generation Amount"
will either be purchased by Avista at 85% of the applicable Mid-Columbia Firm Index Price
with a price cap of $55 per MWh, or used by Potlatch to reduce its load requirements from
Avista. The purchase of Potlatch's Excess Generation Amounts by Avista is limited to 43 800
MWh (5 aMW) each Operating Year. Excess Generation Amounts above this level would be
used by Potlatch to serve its load requirements.
Additionally, it is noted that Potlatch has the capacity to generate additional amounts
Incremental Generation Amounts ) under certain circumstances. The Purchase and Sale
Agreement provides for the purchase by A vista of Incremental Generation Amounts when it is
mutually beneficial to both parties, under the terms and conditions specified in the Agreement.
As reflected in the Agreement, Avista will serve Potlatch's load requirements at
Potlatch's Lewiston plant under its Extra Large General Service Schedule 25 rates, including the
present Power Cost Adjustment (PCA) surcharge and all applicable rate adjustments, unless the
Commission issues an Order in the future authorizing different billing rates.
A vista and Potlatch request that the Commission issue an Order approving the
Purchase and Sale Agreement as a settlement of all known existing disputes between the parties
including without limitation, Case No. A VU-01-5 (In the matter of the Petition of Potlatch
Corporation for an Order determining the terms and conditions of Potlatch's purchase of
electricity from Avista Utilities) and Case No. A VU-02-8 (a Potlatch complaint alleging that
A vista was refusing to purchase the cogeneration of Potlatch's PURP A qualifying facilities at its
Lewiston plant).
ORDER NO. 29418
On October 23 2003 , the Commission issued Notices of Joint Petition and Modified
Procedure in Case No. AVU-03-7. The deadline for filing written comments was November
2003. The reply deadline was November 28 2003. Commission Staff was the only party to
file comments. No reply comments were filed.
Staff Comments
Staff recommends that the Commission approve the submitted Power Purchase and
Sale Agreement between Avista and Potlatch. Staff comments can be summarized as follows:
Proposed Price for Potlatch Generation
Staff notes that Potlatch's generators have been certified by the Federal Energy
Regulatory Commission (FERC) as PURPA "Qualifying Facilities." As such, Avista has an
obligation under PURP A to purchase power offered for sale at avoided cost rates established by
the Commission. The established method for determining avoided cost rates for projects larger
than 10 megawatts is an Integrated Resource Plan (IRP)-based methodology. The avoided cost
methodology is described in Order No. 26576 and its accompanying Settlement Stipulation. The
rate computed for Potlatch is the first under the IRP-based methodology.
A. Determination of the Contract Rate for Base Generation
Avista performed an analysis using the AURORA computer model to determine the
value of Potlatch's generation. Using the same computer model, Staff reviewed the analysis and
computations done by A vista, verified the input data and the assumptions and confirmed the rate
offered to Potlatch. Staff believes Avista has correctly followed the methodology for computing
an avoided cost rate as described in Order No. 26576. The rate for Base Generation Amounts of
$42.92 per MWh is the 10-year levelized avoided cost rate from Avista s 2002 IRP. The rate
represents an estimate of future market prices that fully reflects the fixed costs of new
generation.
Another method used by Staff to verify the value established for Potlatch generation
was to compare the purchase price to published avoided cost rates for projects 10 MW and
smaller. The non-fueled published avoided cost rate for a 10-year contract length with a 2003
online date is $44.43 per MWh. These rates are based on the cost of generating energy using a
gas-fired combined cycle combustion turbine (CCCT). The small difference in these two prices
Staff contends, can be justified based on the different operating characteristics of Potlatch
generation and a CCCT. The 10-year levelized price approved by the Commission and paid by
ORDER NO. 29418
Avista for Potlatch generation in the 1992 special contract was $41.50 per MWh. The annual
cost for Avista to purchase Potlatch generation is only $420 000 more than it was under the old
contract and will remain in effect over the entire life of the new Agreement.
Staff concludes that the contract rate for Base Generation was appropriately derived
and reasonably supported and recommends approval.
B. Contract Rates for Excess and Incremental Generation Amounts
Under the Agreement, Excess Generation (i., amounts generated by Potlatch in
excess of the Base Generation Amount) will either be purchased by A vista at 85% of the
applicable Mid-Columbia (Mid-C) firm index price, with a price cap of $55 per MWh, or used
by Potlatch to reduce its load requirements from Avista. The purchase of Potlatch's Excess
Generation Amounts by Avista is limited to 5 aMW (43 800 MWh) each operating year. Staff
believes that a purchase price equal to 85% of the Mid-C index price is reasonable. In addition
Staff contends that the rate is consistent with comparable rates paid by other utilities. The price
is the same as the price paid by Idaho Power Company for the equivalent of excess energy in
some of its PURP A contracts and is also equal to Idaho Power s non-firm energy rate under its
electric Schedule 86.
Staff also believes it is reasonable to cap the price paid for Excess Generation
amounts at $55 per MWh. A price cap of $55 will insure that Avista is not forced to pay
excessive amounts, yet it will provide the Company an opportunity to purchase small amounts of
energy at below market prices when supplies are limited.
Incremental Generation is energy produced by Potlatch that exceeds the Base
Generation Amounts and the Excess Generation Amounts. The rates for Incremental Generation
are either: a) for prescheduled generation, 85% of market price from a unit contingent sale that
Avista is able to make with a third party, or b) on a real-time basis at 80% of market price for the
hour.Staff believes that these rates are reasonable for Incremental Generation.As the
Agreement is structured, both parties will benefit from the sale and purchase of Incremental
Generation. Potlatch will be able to receive additional benefit from its extra generation during
periods when market prices are high, while A vista will be able to benefit by purchasing from
Potlatch at below market prices.
Staff concludes that the methodology for calculation of contract rates for Excess and
Incremental Generation Amounts is reasonable and recommends approval.
ORDER NO. 29418
Service Pricing
Staff notes that the 1992 special contract price for A vista to serve Potlatch was
essentially based on electric prices in the market place:' The price of all but the 25 MW of
interruptible load also included floor and ceiling prices. The average cost for non-interruptible
service under the old contract was approximately $42.50 per MWh in 2001.
Under the proposed Agreement, A vista will provide service to Potlatch under the
terms and conditions of the Company s existing Extra Large General Service Schedule 25. This
schedule requires Potlatch to pay an average base rate of $31.71 per MWh, generating
approximately $27.7 million per year in base revenues. Potlatch will also be subject to the Tax
Adjustment Schedule 58, the Temporary Rate Adjustment Schedule 65, the Power Cost
Adjustment Schedule 66 and the Energy Efficiency Rider Adjustment Schedule 91. When the
rate from non-tax Schedules 65 , 66 and 91 are added to the base rate, the 2003 price paid by
Potlatch for service averages $38.65 per MWh. Although Potlatch's 100 MW of load exceeds
the Schedule 25 limit of approximately 25 MW, Schedule 25A which is part of Schedule 25
states:
Customers whose demand from all such meters exceeds 25 000 KV A (25
MW) may be served under special contract wherein the rates, terms and
conditions of service are specified and approved by the IPUC. If customer
requires service during either the contract negotiation or resolution period
service will be supplied under this rate schedule. . . .
Potlatch, Staff notes, is by far A vista s largest single customer and electric Schedule
25 has the largest load requirement currently approved by the Commission for A vista. Absent an
analysis to specifically identify Potlatch service costs, Staff contends that Schedule 25 is the
most appropriate proxy to reflect Potlatch embedded cost of service. Given that current
Schedule 25 rates are based on the embedded cost to serve a group of industrial customers that
are much smaller than Potlatch, Staff speculates that it is likely that specific embedded costs to
serve Potlatch could be lower than those used to set Schedule 25 rates. The Agreement allows
either party in the context of a future proceeding to argue that the cost to serve Potlatch justifies
rates that are either higher or lower than those found in Schedule 25.
Staff concludes that without a cost of service study the Agreement's proposed use of
Schedule 25 as a proxy for pricing Potlatch's load is reasonable and recommends approval.
ORDER NO. 29418
Jurisdictional Allocation
A. Background
The methodology approved by the Commission to historically allocate cost between
Avista s various jurisdictions includes an allocation of all generation costs based on the
jurisdictional weighting of demand and energy (67% Washington; 33% Idaho). Revenue, on the
other hand, has always been directly assigned to the jurisdiction where the customer resides.
Prior to 1992, A vista paid nothing for Potlatch generation and received revenue from
Potlatch based upon the net load served after Potlatch used its generation to partially offset its
load. Revenues from this service arrangement remained in the Idaho jurisdiction and generation
costs associated with serving the net load were allocated among the Idaho and Washington
jurisdictions.
Under the 1992 special contract, A vista purchased all Potlatch generation at a pre-
established price and received revenue from Potlatch based on its total load. The effect of this
service arrangement under traditional jurisdictional allocation methodology was simply an
increase in generation costs allocated to other jurisdictions. This is due to a traditional allocation
methodology that adds generation cost to the system on the margin but allocates increased
system generation costs to Idaho on the average (i., treating Potlatch load that was previously
self-generated as having an entitlement to embedded cost resources). Allocation of all revenues
on a situs basis compounded the problem. To counteract this effect, the 1992 contract approval
included allocation of 60 MW of Potlatch revenues as well as purchase power costs of 60
megawatts of Potlatch generation on a jurisdictional basis. This adjustment was a compromise
that balanced costs allocated to the various jurisdictions with offsetting revenues and worked
fairly well because revenues from 60 megawatts of Potlatch load were fairly close to the costs of
purchasing 60 megawatts of Potlatch generation.
B. Agreement - New Potlatch Allocation Methodology
Under the new Agreement, the cost of purchasing 60 megawatts of Potlatch
generation is significantly higher than the revenue generated from serving 60 megawatts of
Potlatch load. Consequently, the Company is proposing a different jurisdictional allocation
method. A vista proposes to directly assign all revenues and costs associated with the additional
60 megawatts of Potlatch load and generation to Idaho. This allocation methodology places the
net cost of buying from Potlatch and selling to Potlatch on the Idaho jurisdiction. Under the
ORDER NO. 29418
net cost of buying from Potlatch and selling to Potlatch on the Idaho jurisdiction. Under the
Company s allocation proposal, all ofthe Company s other jurisdictions will be held harmless.
Although no other generation costs are jurisdictionally allocated in this fashion, the
Company believes it is appropriate in this case because the Agreement provides the opportunity
for additional benefits to Idaho customers and Idaho is the primary beneficiary of "secondary
benefits. Avista states also that it does not believe the Washington Utilities and Transportation
Commission (WUTC) would accept the ratemaking consequences of the Agreement using
traditional allocation methodology. Nor, the Company states, does it believe that A vista
shareholders should bear the additional costs deemed unacceptable by the WUTC. The
Company believes the Agreement is "an Idaho solution to an Idaho problem.
Staff notes that the Company has conditioned the appropriateness of the proposed
purchase/sale rates on the Commission s approval of the Company-proposed allocation method.
The fact is, Staff observes, the net cost of the Agreement increases under the proposed rates
because expenses exceed revenues. For Avista to be made whole under the jurisdictional
allocation previously approved for the old contract, the Company must collect a large portion of
the excess costs from Washington customers. From a practical standpoint, someone must pay
the difference between serving Potlatch at embedded cost and purchasing Potlatch generation at
marginal cost. Staff recognizes that Potlatch is an Idaho customer providing employment and
taxes in Idaho. If rates are appropriately established and if benefits accrue primarily to Idaho
Staff believes it is also reasonable to recover the costs from Idaho customers. Staff supports and
recommends approval of the Company-proposed method of cost allocation.
Cost Recovery and Revenue Impact
F or the purposes of this case, Staff evaluated Idaho revenue impact by comparing net
revenues/costs included in base rates under the 1992 contract to revenues/costs that will be
included in rates under the new Agreement. Until the new jurisdictional allocation methodology
and revenues/costs of the new Agreement are included in base rates as part of a general rate case
the Company proposes to account for the changes through the Company s Idaho PCA. The
comparison also reflects that Potlatch is subject to the PCA under the new Agreement but was
not subject to the PCA under the old contract.
The simplest way to evaluate the impact of the new Agreement, Staff contends, is to
compare the net cost of the two contracts on a system basis. The old contract had annual system
ORDER NO. 29418
expenses of $28.8 million and annual system revenues of $26.2 million for a net annual cost of
$2.6 million. The new Agreement has annual system expenses of $31.25 million and annual
revenues of $27.7 million for a net system cost of $3.6 million. Therefore, the new Agreement
increases annual net costs by approximately $1 million on a system basis.
However, the proposed change in the jurisdictional allocation, Staff notes, shifts most
of the costs to the Idaho jurisdiction. Under the jurisdictional allocation methodology approved
with the old contract, the net cost allocated annually to Idaho is actually a benefit of $296 000.
Under the allocation methodology proposed with the new Agreement, Idaho costs increase by
$4.l million for the term of the Agreement, from a $296 000 allocated net benefit to a $3.
million directly assigned net cost. A $4.1 million increase in Idaho s revenue requirement
represents the equivalent of a 2.3% overall rate increase.Until power purchase costs are
included in base rates, the Company proposes to pass 100% of this annual expense increase
through the Idaho PCA. Staff agrees with the recovery method proposed. Staff notes that
Potlatch will contribute approximately $5.3 million during the current year as a Schedule
customer subject to the PCA. The resultant net effect of the new Agreement during the 2003
PCA period is a $1.2 million reduction in deferred costs borne by other Idaho customers.
The above analysis of revenue impact, however, is valid only under existing rates and
continued service to Potlatch under Schedule 25. Staff notes that there is a possibility that the
net cost of the Agreement could increase in the future if rates applied to serve Potlatch are
reduced. Moreover, there will be no offsetting revenue through the PCA from Potlatch under
normal water and power supply conditions to offset the effect of higher base rates. In fact
during high water conditions, Potlatch will receive some of the PCA credit that would otherwise
go to other Idaho customers. However, because the rate paid to Potlatch for generation is fixed
Staff believes that it is likely that the cost differential between the cost to serve Potlatch and the
cost to buy its generation will ultimately decline.
Commission Findings
The Commission has reviewed and considered the filings of record in Case No.
AVU-03-, including the underlying Agreement, the supporting filings of Avista and the
comments and recommendations of Commission Staff. We find that the established record in
this case presents an adequate basis for decision. We therefore continue to find it reasonable
process this case pursuant to Modified Procedure. Reference IDAP A 31.01.01.204.
ORDER NO. 29418
Power Purchases (Power Deliveries to Avista)
The submitted Agreement represents that Potlatch'electric generators at its
Lewiston plant are PURPA qualifying facilities. Section 210 of PURPA requires that electric
utilities offer to purchase power produced by co-generation or small power producers that obtain
qualifying facility (QF) status under Section 201. Under the implementing rules and regulations
ofthe Federal Energy Regulatory Commission (FERC), the rate a QF is to receive for the sale of
its power is generally referred to as the "avoided cost" rate, the incremental cost to an electric
utility of electric energy or capacity or both which, but for the purchase from the QF, such utility
would generate itself or purchase from another source. 18 C.F .R. 9 292.101 (b)( 6).
The Commission finds that the $42.92/MWh levelized purchase price for the Potlatch
base generation amount" (62 aMW) is a reasonable approximation of Avista s avoided cost and
was correctly calculated under the Commission approved IRP-based avoided cost methodology.
Reference Order No. 26576. We further find the 10-year contract term beginning July 2003 to
be reasonable. Locking in the purchase rate for that term, we find, provides benefit to the
Company, its Idaho customers and Potlatch.
We find the proposed market pricing method of Excess Generation amounts to be
reasonable and consistent with comparable rates paid by other electric utilities. Also reasonable
are the related 5 aMW operating year limit on Excess Generation and the $55 per MWh price
cap. The third component of the Purchase Agreement is Incremental Generation. This
generation is also market-based and is priced in a manner that we find reasonable. With market-
based pricing, we find that the potential purchase of both Excess and Incremental Generation
will provide benefit to the Company and its Idaho customers.
Power Sales (Power Deliveries to Potlatch)
The Agreement provides that A vista will provide electric service to Potlatch under
the terms and conditions of the Company s existing extra large general service Schedule 25
tariff. Schedule 25 is a default rate for a customer as large as Potlatch. The Company s tariffs
envision that a customer whose demand exceeds 25 MW will be served under a special contract.
The Agreement allows either party in the context of a future proceeding to argue that Potlatch'
se~ice should be priced at rates other than Schedule 25 rates. Agreement 9 5(b). Avista has
informed the Commission of its intent to file a general rate case in early 2004. Absent further
analysis and study Staff contends that Schedule 25 is the most appropriate proxy to reflect
ORDER NO. 29418
Potlatch's embedded cost of serVice.Until the serVice rates for Potlatch are otherwise
determined, the Commission finds that it is reasonable to serve Potlatch under Schedule 25. As
Schedule 25 tariff customer, Potlatch is subject to all the same rate adjustments applicable to
other Schedule 25 customers.
Jurisdictional Allocation/Cost Recovery
The jurisdictional allocation method proposed by the Company is a departure from
historical allocation. What is proposed is the allocation of 100% of Potlatch power purchase
costs to Idaho. Without changing the allocation methodology, power purchase costs would be
treated as generation and based on the jurisdictional weighting of demand and energy shared
between Washington (67%) and Idaho (33%).
Avista and its Idaho customers have long benefited from Potlatch's self-generation
capability. Prior to 1992 and from January 2002 through June 30, 2003, Potlatch used its
generation to reduce its load requirement while purchasing the remainder from A vista. From
1992 to 2002 Idaho received a net benefit from the Potlatch contract.
A vista contends that its proposed allocation of Potlatch power purchase costs is
appropriate because Idaho realizes all the benefit of Potlatch's 100 MW ofload and Schedule 25
revenue. Additional secondary benefits cited by the Company as accruing to Idaho and its
citizens from Potlatch's continued operation in Lewiston are the benefits from continued
employment, a bolstered tax base and economic spin-off benefits for other businesses.
As further justification for the proposed treatment of power purchase costs, the
Company notes that the Washington Utilities and Transportation Commission (WUTC) takes a
much different view of PURP A purchases than the Idaho Commission. A vista contends that the
Agreement eliminates potential inter-jurisdictional disputes.The submitted Agreement, the
Company contends, is an Idaho solution to an Idaho problem.While we appreciate the
Company s perspective, we believe it is fair to recognize also that a utility operating in multiple
jurisdictions has voluntarily assumed regulatory challenges and the related risk of disparate
treatment.
Until such time as the purchase contract is reflected in base rates , the Company
proposes to defer 100% of the power purchase costs for recovery in its Idaho PCA. We note that
the generators owned by Potlatch are PURP A qualifying facilities. The purchase by A vista is
obligatory and mandated by federal law and FERC regulations, i., 18 C.R. 9 292.303. We
ORDER NO. 29418
have always treated purchases from PURP A QFs as non-discretionary and have authorized
recovery of contract costs. The $42.92 per megawatt hour purchase price set forth in the
Agreement for 62 aMW of annual base generation we find is just and reasonable and a good
approximation of the Company s avoided cost. 18 c.F.R. 9 292.304. The additional excess and
incremental energy offered by Potlatch we find are also PURP A purchases. Potlatch is a unique
customer of A vista with long and strong economic ties to Idaho. As Staff notes, from a practical
standpoint, someone must pay the difference between serving Potlatch at embedded cost and
purchasing Potlatch generation at marginal cost. While not choosing to speculate what the
Washington Commission would do if presented with this Agreement, we find the Company
allocation proposal on the facts presented to be one of fairness and equity. As the benefits and
revenue of Potlatch accrue to Idaho, so too, we find, should the related costs. Accordingly, we
find it reasonable to approve the proposed allocation and method of power purchase cost
recovery. In approving the requested recovery method, we authorize the booking of A vista
power purchase costs in the Company s PCA deferral account. Recovery of Potlatch power
purchase costs by the Company will require a rate case or PCA filing.
Settlement of All Known Existing Disputes
Part of the mutual consideration recited in the Joint Petition is the settlement of all
known existing disputes between the parties before the Idaho Commission and Idaho Courts.
Joint Petition ~ 11 (b). Specifically mentioned in the Agreement are Potlatch's complaint in
Idaho u.S. District Court, Case No. CV02-543-EJL alleging that Avista violated the terms of
the 1992 AvistaiPotlatch Agreement and Potlatch's complaint in Commission Case No. A VU-
02-8 alleging that A vista had refused to purchase the co-generation output of the Lewiston plant.
Agreement 9 31. The Commission acknowledges that the Agreement by its terms intends to put
an end to all existing litigation between the parties. We find that in addition to the cases cited
the Agreement also finally concludes Commission Case No. A VU-01-, a Potlatch Petition
regarding the purchase of power from A vista.
CONCLUSIONS OF LAW
The Idaho Public Utilities Commission has jurisdiction over A vista Corporation dba
A vista Utilities, an electric utility, pursuant to the authority granted the Commission in Idaho
Code, Title 61 and the Public Utility Regulatory Policies Act of 1978 (PURP A).
ORDER NO. 29418
The Commission has authority under PURP A and the implementing regulations of
the Federal Energy Regulatory Commission (FERC) to set avoided costs, to order electric
utilities to enter into fixed term obligations for the purchase of energy from qualified facilities
and to implement FERC rules.
ORDER
In consideration of the foregoing and as more particularly described above, IT IS
HEREBY ORDERED and the Commission does hereby approve the Power Purchase and Sale
Agreement (Agreement) between Avista and Potlatch dated July 22 2003.
IT IS FURTHER ORDERED and the Commission hereby authorizes the booking of
all power purchase costs paid by A vista to Potlatch under the Agreement in the Company
Power Cost Adjustment (PCA) deferral account. PCA recovery of Potlatch power purchase costs
is authorized until such costs are otherwise included in the Company s base rates.
THIS IS A FINAL ORDER. Any person interested in this Order may petition for
reconsideration within twenty-one (21) days of the service date of this Order. Within seven (7)
days after any person has petitioned for reconsideration, any other person may cross-petition for
reconsideration. See Idaho Code 9 61-626.
ORDER NO. 29418
DONE by Order of the Idaho Public Utilities Commission at Boise, Idaho this St+--
day of January 2004.
~#
J2Jw'
MARSHA H. SMITH, COMMISSIONER
ENNIS S. HANSEN, OMMISSIONER
ATTEST:
~/D.
D. Jewell
C mmlSSlon Secretary
bls/O:A VUE0307 sw
ORDER NO. 29418