20031107Comments.pdf

SCOTT WOODBURY
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
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Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE JOINT PETITION
OF A VISTA CORPORATION AND POTLATCH)
CORPORATION FOR APPROVAL OF POWER
PURCHASE AND SALE AGREEMENT.
CASE NO. A VU-O3- 7
COMMENTS OF THE
COMMISSION STAFF
COMES NOW the Staff of the Idaho Public Utilities Commission, by and through its
Attorney of record, Scott Woodbury, Deputy Attorney General, and in response to the
October 23 2003 Notice of Joint Petition, Notice of Modified Procedure, Notice of
Comment/Protest Deadline and Notice of Reply Comment Deadline in Case No. A VU-03-
submits the following comments.
BACKGROUND
Potlatch Corporation (Potlatch) owns and operates a wood pulp, paperboard, tissue and
wood products manufacturing facility in Lewiston, Idaho. Potlatch has the capability at its
Lewiston plant to produce energy in conjunction with its manufacturing processes. Prior to
January 1 , 1992, Potlatch utilized its generation to serve a substantial portion of its load
requirements, with the balance of its load requirements served by A vista under electric tariff
Schedule 25. From January 1, 1992 through December 31 2001 , Avista purchased 55 average
megawatts (aMW) of Potlatch's generation and served essentially all ofPotlatch's.1oad
STAFF COMMENTS NOVEMBER 7, 2003
requirements under a special contract. The rates, terms and conditions for power purchases and
sales under the special contract were negotiated between the parties and approved by the
Commission in Order No. 23858 in Case No. WWP-91-5. As part of that case, Avista
proposed and the Commission approved, special regulatory/accounting treatment of the contract
due in part to the size of the load and the unique nature of the contract.
Avista and Potlatch agreed, in a Joint Motion dated August 17 2001 , filed in Case No.
A VU-01-, that upon expiration of the special contract on December 31 , 2001 , Potlatch's load
would be served under Schedule 25 rates. From January 1 , 2002 through June 30, 2003, Potlatch
used its approximate 60 aMW of generation to reduce its load requirements while purchasing the
remainder (approximately 40 aMW) from A vista. Potlatch now desires to sell all of its
generation to A vista and to purchase power from A vista to meet its full load requirements. After
many months of negotiation, the parties have reached agreement on the future purchase and sale
of power and seek Commission approval of the Power Purchase Agreement.
ANALYSIS
The Agreement
The Power Purchase and Sale Agreement (Agreement) submitted jointly by A vista and
Potlatch is for a ten-year term, beginning July 1 , 2003 and ending June 30, 2013. The
Agreement is conditioned upon Commission approval of: (i) the Purchase and Sale Agreement as
a settlement of all known existing disputes between the Parties, without precedential value and
without prejudice to the Parties' positions on similar issues in the future; (ii) the direct
assignment of all power purchase costs paid by A vista to Potlatch under the Purchase and Sale
Agreement to A vista s Idaho operations; and (Ui) the deferral and recovery of 100% of all power
purchase costs paid by A vista to Potlatch under the Purchase and Sale Agreement to A vista
Idaho Power Cost Adjustment (PCA) or otherwise recovered by Avista through base rates.
A vista will be the sole purchaser of Potlatch's generation and such purchase is intended
to satisfy Avista s obligations to purchase power from the Lewiston plant pursuant to the Public
Utility Regulatory Policies Act of 1978 (PURP A). A vista will pay Potlatch $42.92 per
megawatt-hour (MWh) for up to a maximum Base Generation Amount of 543 120 MWhs
generated by Potlatch during each July 1 through June 30 period ("Operating Year ) of the
Agreement. This amount is equivalent to 62 aMW and is referred to in the Agreement as the
Base Generation Amount." The Base Generation Amount will constitute the vast majority of
STAFF COMMENTS NOVEMBER 7, 2003
energy sales under the Agreement. Amounts generated by Potlatch in excess of the maximum
Base Generation Amount each Operating Year ("Excess Generation Amounts ) will either be
purchased by Avista at 85% of the applicable Dow Jones Mid-Columbia index price, with a price
cap of $55 per MWh, or used by Potlatch to reduce its load requirements from A vista. The
purchase of Potlatch's Excess Generation Amounts by Avista is limited to 43 800 MWhs (5
aMW) each Operating Year.
Additionally, Potlatch has the capacity to generate additional amounts ("Incremental
Generation Amounts ) under certain circumstances. Potlatch could generate 10-20 megawatts of
Incremental Generation for short periods of time when electric market prices are high, and
perhaps as much as 50 additional megawatts at extreme market prices. Because both parties
would benefit from Incremental Generation under these circumstances, the Agreement provides
for the purchase by A vista of Incremental Generation Amounts, under the terms and conditions
specified in the Agreement. Incremental Generation can be purchased by A vista, either on a
prescheduled basis at 85% of market price from a unit contingent sale that Avista is able to make
with a third party, or on a real-time basis at 80% of market price for the hour.
Avista will serve Potlatch's net load requirements at Potlatch's Lewiston Plant
(approximately 40 MW) under its Extra Large General Service Schedule 25 rates, including all
applicable rate adjustments, unless the Commission issues an order in the future authorizing
different billing rates.
Proposed Price For Potlatch Generation
Potlatch's generators have been certified by the Federal Energy Regulatory Commission
(FERC) as PURP A "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 ten megawatts is
an Integrated Resources Plan (lRP)-based methodology. The avoided cost methodology is
described in Order No. 26576 and its accompanying Settlement Stipulation.
One of the reasons for adopting an lRP-based avoided cost methodology was that larger
projects were thought likely to have project-specific characteristics that would make their
generation more or less valuable than the published avoided cost rates. In addition, large
projects were big enough that their generation could conceivably have a significant impact on a
utility's need for new resources. Large projects could perhaps eliminate the need to add new
STAFF COMMENTS NOVEMBER 7, 2003
resources as identified in the utility's IRP, or at least possibly defer the need for adding a new
resource. In order to recognize and fairly value the different individual characteristics oflarge
projects, a methodology was formulated based on utilities' IRPs and computer models that
compute power supply costs.
The rate computed for Potlatch is the first under the methodology. Staff believes the
lRP-based methodology is a reasonable method for calculating avoided cost rates for large
projects. In fact, Staff believes that the methodology may be even more appropriate today given
that the modeling tools available to the utilities have improved.
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. In its analysis, Avista modeled six different scenarios involving
Potlatch and Coyote Springs II. Also using AURORA, 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.
Coincidentally, Avista had just completed calculating its avoided cost as part of its 2002
lRP using AURORA and a nearly identical methodology to that prescribed by the Commission
for computing avoided costs. The rate for the Base Generation Amounts of $42.92 per MWh is a
ten-year levelized avoided cost rate from Avista s 2002 IRP, essentially verified by the
independently modeled computer runs made to calculate the value of Potlatch generation. 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 proj ects 10 MW and smaller.
The non-fueled published avoided cost rate for a ten-year contract length and 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). As previously mentioned, the small difference in
these two prices can be justified based on the different operating characteristics of Potlatch
generation and a CCCT. The ten-year levelized price approved by the Commission and paid by
Avista for Potlatch generation in the 1992 special contract was $41.50 per MWh.
STAFF COMMENTS NOVEMBER 7 , 2003
Staff believes the rate for Base Generation in the Agreement fairly represents the value of
Potlatch's generation and is satisfied that the method used to derive the rate conforms closely
enough to the methodology as prescribed in Order No. 26576 and its Settlement Stipulation.
Contract Rate 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 Avista at 85% of the applicable
Mid-Columbia (Mid-C) 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 A vista is limited to 5 aMW each Operating Year.
Staff believes that a purchase price equal to 85% of the Mid-C index price is reasonable.
In addition, the rate is consistent with comparable rates paid by other utilities. The price is the
same as the price paid by Idaho Power for the equivalent of excess energy in some of its PURP
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. Mid-C index prices have soared on occasion in the past few years to levels many
times normal, and price excursions even beyond the $55 range have not been unusual. A price
cap of $55 will insure that A vista 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 A vista 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 COMMENTS NOVEMBER 7, 2003
Service Pricing
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 designed to stabilize both revenues collected by A vista and
costs incurred by Potlatch within a specified range. The average cost for non-interruptible
service under the old contract was approximately $42.50 per MWh in 2001.
Under the proposed contract, 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 ofload 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 I.P.u.C.
If customer requires service during either the contract negotiation or
resolution period, service will be supplied under this rate schedule...
Potlatch is by far Avista s largest single customer and electric Schedule 25 has the largest
load requirement currently approved by the Commission for Avista. Absent an analysis to
specifically identify Potlatch service costs, 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, it is
likely that specific embedded costs to serve Potlatch could be lower than those used to set
Schedule 25 rates. While Staff believes the rates proposed in the Agreement adequately cover
Potlatch embedded cost of service, the Agreement allows any party to argue, in the context of a
future proceeding, that the cost to serve Potlatch justifies rates that are either higher or lower
than those found in Schedule 25. Consequently, the Commission has the explicit ability to
modify service prices during the term of the Agreement.
STAFF COMMENTS NOVEMBER 7 , 2003
Avista maintains that to the extent the Company s overall costs rise, e., through general
rates, the cost to serve Potlatch will increase relative to the cost of purchasing Potlatch
generation. However, Staff also believes there is a risk that service rates applied to Potlatch
could decline in the next general rate case to the extent the cost to serve Potlatch is found to be
below the cost to serve all other Schedule 25 customers. Nevertheless, Staff believes the rates
proposed to both purchase power from Potlatch and sell power to Potlatch were appropriately
derived and reasonably supported.
Jurisdictional Allocation
In order to understand the jurisdictional allocation rationale proposed by the Company for
the new Agreement, one must understand the history of service to Potlatch and the traditional
methodology used to jurisdictionally allocate Avista costs and revenues. The methodology
approved by the Commission to historically allocate cost between the various jurisdictions
includes an allocation of all generation costs based on the jurisdictional weighting of demand and
energy. 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. Effectively, Idaho retained that portion of average system generation costs based
upon Potlatch net energy and demand. Potlatch net revenue was retained in Idaho to cover those
costs.
Under the 1992 special contract approved by the Commission, 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.e. 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
STAFF COMMENTS NOVEMBER 7, 2003
purchase power costs of60 MW 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 MW of Potlatch load were fairly
close to the costs of purchasing 60 MW of Potlatch generation.
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 yet another jurisdictional allocation. Avista proposes
to directly assign all revenues and costs associated with the 60 megawatts of Potlatch load and
generation to Idaho. This allocation methodology places the net cost of buying 60 megawatts
from Potlatch and selling 60 megawatts back to Potlatch on the Idaho jurisdiction. All other
jurisdictions are held harmless by this transaction.
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. In addition, the Company does not believe the Washington Utilities and Transportation
Commission (WUTC) would accept the ratemaking consequences of the Agreement using
traditional allocation methodology. Nor does the Company 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.
Revenue Impact
Revenues and expenses associated with the A vistaIPotlatch service arrangement have
changed on an interim basis since the 1992 special contract expired at the end of2001.
However, for 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 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 is to compare the net cost
of the two contracts on a system basis. The old contract had annual system expenses of$28.
STAFF COMMENTS NOVEMBER 7, 2003
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.
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 change proposed in the jurisdictional allocation 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 $4.1 million
from a $296 000 allocated net benefit to a $3.8 million directly assigned net cost. The Company
proposes to pass this annual expense increase through the PCA until costs are included in base
rates. A $4.1 million increase in base rates represents a 2.3% overall increase in Idaho revenue
requirement on a permanent basis. On the other hand, Potlatch will contribute approximately
$5.3 million during the current year as a Schedule 25 customer subject to the PCA. Therefore
the net effect of the new Agreement during the 2003 PCA period is a $1.2 million reduction in
costs borne by other Idaho customers.
As previously mentioned, 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, it is likely that the cost
differential between the cost to serve Potlatch and the cost to buy its generation will ultimately
decline.
CONCLUSIONS
After review of the Joint Petition presented by A vista and Potlatch along with supporting
testimony, Staff concludes that the proposed Agreement may be the only practical approach to
resolving the Potlatch service arrangement dispute. This conclusion was not reached without
considerable discussion and evaluation to address concerns regarding jurisdictional allocation of
service arrangement costs and revenues as proposed by A vista.
While A vista and Potlatch have agreed to the terms in the Agreement after lengthy, often
contentious negotiations, continued agreement is subject to approval by the Commission of
STAFF COMMENTS NOVEMBER 7, 2003
conditions established by A vista. The Agreement conditions include adoption of a special
jurisdictional allocation of contract costs and 100% recovery through the PCA or base rates of
power purchase costs incurred by A vista as a result of the Agreement.
Staff has spent considerable time and effort evaluating the proposed prices to purchase
Potlatch generation and serve Potlatch load and conclude they are reasonable. The proposed
price paid by Avista for Potlatch generation of$42.35 per MWh is slightly less than the
Company s published avoided cost rate over the ten-year period of $44.25 and corresponds to the
avoided cost rate calculated in the Company s latest IRP. 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 also accepts A vista s proposal to allow
100% recovery of the purchase power costs through the PCA. This treatment is consistent with
that provided to Idaho Power Company for mandated purchases from PURP A projects and will
soon be subject to 100% recovery anyway as a result of the upcoming general rate case.
The proposed price charged by A vista for electrical service to Potlatch is the existing
Schedule 25 rate for large industrial customers. By agreeing to apply Schedule 25 rates to
Potlatch's entire 100 MW load, Staff concedes a Potlatch entitlement to embedded cost rates.
While A vista has also agreed to serve all Potlatch load under Schedule 25 rates, it does not agree
to include the net cost to serve 60 MW of that load in its traditional jurisdictional allocation
methodology.
The financial effect of approving the rates with the proposed allocation is a permanent
3% base rate increase for Avista s other Idaho customers. Potlatch will be subject to the PCA
under the proposed Agreement so Idaho customers will experience relatively lower PCA rates
during surcharge periods but will also share credits with Potlatch during refund periods.
Staff understands Avista s desire to specify allocation conditions in order to agree to the
rates described above. The fact is, 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.
While Staff has no desire to see increased rates for A vista s Idaho customers, it sees no
other reasonable alternative to supporting Agreement approval with Avista s conditions. From a
practical standpoint, someone must pay the difference between serving Potlatch at embedded
cost and purchasing Potlatch generation at marginal cost. Staff has already agreed that the rates
STAFF COMMENTS NOVEMBER 7, 2003
established under the Agreement appear to be reasonable. Staff also recognizes that Potlatch is
an Idaho customer providing employment and taxes in Idaho. Ifrates are appropriately
established and benefits accrue primarily to Idaho, then it seems reasonable to recover costs from
Idaho customers.
Beyond A vista s promised withdrawal from the Agreement, the consequences of denying
the Company s request are difficult to predict. Absent a mutually agreeable purchase/sales
contract, Potlatch would need to reevaluate its options with regard to generating into its own
load or selling its generation off system. A vista would need to reevaluate the cost and its ability
to serve Potlatch load if the size of that load depends upon availability of Potlatch generation.
Disagreement would continue and costs ultimately borne by Idaho ratepayers could be even
higher.
Absent an agreement, Potlatch could continue to generate into its own load indefinitely.
As long as Potlatch continued to do so, it would in effect receive the equivalent of its Schedule
25 retail rate for its generation. Alternatively, Potlatch could choose to simply sell its generation
on the market or to some utility other than Avista. However, if Potlatch chose to sell outside of
A vista s system, then A vista would have to serve Potlatch's full load of 100 MW by acquiring
other resources rather than relying on Potlatch generation. Potlatch would need to commit to a
steady load for a fixed time period in order to qualify for Schedule 25 rates. Alternately selling
off system by Potlatch and then generating into its own load could cost Potlatch, A vista, and
ultimately its ratepayers, more in the long run.
Finally, the Commission could direct Avista to serve Potlatch under the proposed
Agreement, deny the proposed cost allocation methodology and require Avista to seek 67% of
the net contract cost differential from the Washington jurisdiction. It is unlikely that Idaho
Commission Staff would support such a recovery if the roles were reversed. Staff does not
recommend such a decision in this case. Given that the benefits of the Agreement primarily
accrue to Idaho, that the proposed rates are properly derived and supported using the Idaho
avoided cost methodology, that Potlatch is an Idaho customer that has historically utilized its
generation to serve its own load and the fact that the incremental 60 MW load makes up such a
large portion of A vista s overall load, Staff does not oppose the proposed Agreement rates nor
the proposed cost recovery conditions.
STAFF COMMENTS NOVEMBER 7, 2003
RECOMMENDATIONS
Staff recommends that the Commission approve the submitted Power Purchase and Sale
Agreement between A vista and Potlatch. Staff also recommends that all power purchase costs
paid by A vista to Potlatch under the Agreement and all revenues received by A vista for serving
the 60 MW of incremental load be directly assigned to A vista s Idaho jurisdiction. Finally, Staff
recommends the Commission allow deferral and recovery of 100% of all power purchase costs
paid by Avista to Potlatch under the Agreement to Avista s Idaho Power Cost Adjustment
PCA") or otherwise recovered by A vista through base retail rates.
Respectively submitted this "fJ, day of November 2003.
Scott Woodbury
Deputy Attorney General
Technical Staff: Rick Sterling
Randy Lobb
i:umisc :comments/avueO3. 7 swrps
STAFF COMMENTS NOVEMBER 7 , 2003
CERTIFICATE OF SERVICE
HEREBY CERTIFY THAT I HAVE THIS 7TH DAY OF NOVEMBER 2003
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN
CASE NO. AVU-03-, BY MAILING A COpy THEREOF, POSTAGE PREPAID, TO
THE FOLLOWING:
DAVID J. MEYER
SR VP AND GENERAL COUNSEL
A VISTA CORPORATION
PO BOX 3727
SPOKANE W A 99220-3727
R. BLAIR STRONG
PAINE, HAMBLEN, COFFIN, BROOKE &
MILLER LLP
717 W. SPRAGUE AVE, SUITE 1200
SPOKANE, WA 99201
PAMELA MULL
ASSOCIATE GENERAL COUNSEL
POTLATCH CORPORATION
601 W RIVERSIDE AVE SUITE 1100
SPOKANE WA 99201
CONLEY WARD
GIVENS PURSLEY
277 N 6TH STREET SUITE 200
PO BOX 2720
BOISE ID 83701-2720
b1~
CERTIFICATE OF SERVICE