20090529Leckie Direct.pdf

BEFORE THE
20n9 lirf 29 Pt'1 li: 3l.
IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )
OF AVISTA CORPORATION FOR THE ) CASE NO. AVU-E-09-1/
AUTHORITY TO INCREASE ITS RATES) AVU-G-09-1
AND CHARGES FOR ELECTRIC AND )
NATURAL GAS SERVICE TO ELECTRIC )
AND NATURAL GAS CUSTOMERS IN THE )STATE OF IDAHO. )
)
)
DIRECT TESTIMONY OF JOE LECKIE
IDAHO PUBLIC UTILITIES COMMISSION
MAY 29,2009
1 Q.Please state your name and business address for
2 the record.
3 A.My name is Joe Leckie. My business address is
4 472 West Washington Street, Boise, Idaho.
5 Q.By whom are you employed and in what
6 capacity?
7 A.I am employed by the Idaho Public Utili ties
8 Commission (Commission) as a senior auditor in the
9 Utilities Division.
10 Q.What is your educational and experience
11 background?
12 A.I graduated from Brigham Young Uni versi ty
13 wi th a Bachelors of Science degree in Accounting. I
14 worked for the accounting firm Touche Ross in its Los
15 Angeles office for approximately one year. I then
16 attended law school and graduated from the J. Rueben
17 Clark School of Law at Brigham Young University with a
18 Juris Doctorate degree.
19 I am licensed to practice law in the State
20 of Montana. I practiced law in the State of Montana for
21 approximately 25 years.
22 I have been employed at the Commission as an
23 auditor since March 2001. I have attended the annual
24 regulatory studies program sponsored by the National
25 Association of Regulatory Utilities Commissioners (NARUC)
CASE NOS. AVU-E-09-1/AVU-G-09-1
OS/29/09 LECKIE, J (Di)
STAFF
1
1 at Michigan State University in August of 2001. I have
2 also attended several other training courses sponsored by
3 NARUC on regulatory accounting and auditing.
4 Q.What is the purpose of your testimony?
The purpose of my testimony is to review the5A.
6 Company's capital additions to electric rate base in
7 October, November and December (last quarter) of 2008 and
8 the twelve (12) months of 2009. i will testify about the
9 annual additions generally and will testify about three
10 (3) specific additions. I recommend that Company witness
11 Andrews' proposal to include the costs for the Spokane
12 River relicensing be excluded from rate base at this
13 time. These costs are currently being deferred and I
14 recommend that they continue to be deferred. I also
15 recommend adj ustments to the accounting treatment for the
16 Coeur d' Alene Tribe settlement; and finally, i will
17 recommend that the unamortized balance of the deferred
18 costs for the Montana settlement not be included in rate
19 base.
20 All of the numbers that are presented in my
21 testimony refer to the Idaho allocation of the total
22 system numbers. If system numbers are referenced, they
23 will be specifically identified as system numbers.
24 Q.What are your recommendations for the last
25 quarter of 2008 capital additions to electric rate base?
CASE NOS. AVU-E-09-1/AVU-G-09-1
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STAFF
2
1 A.Company witness Andrews included the net
2 amount of $3,658,000 as an addition to rate base for
3 capital expenditures in the last quarter of 2008. (See
4 Company witness Andrews Exhibit No. 10, page 8). After
5 reviewing these additions to rate base, it appears that
6 these capital investments are reasonable. The 2008 rate
7 case increased rate base through the end of 2008.(See
8 the Stipulation adopted and approved by the Commission in
9 Order No. 30647).
10 Q.What are your recommendations for Company
11 witness Defelice's additions to rate base for the 2009
12 capital expenditures?
13 A.I have tested and reviewed part of the
14 actual expenditures for those additions through March 31,
15 2009, and I have reviewed the budgeted amounts the
16 Company has projected through the end of 2009. Company
17 wi tness Defelice is requesting a net addition to rate
18 base in the amount of $16.9 million. Although the last
19 nine (9) months of these expenditures are projected, I
20 have not recommended any adjustment to the Company's
21 request. The Company's projections of capital
22 expenditures have been very close to the end of the year
23 actual expenditures. Also, in reviewing the projected
24 expenditures, there were not any projections that
25 appeared to be excessive or unreasonable.
CASE NOS. AVU-E-09-1/AVU-G-09-1
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STAFF
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1 Q.You also reviewed three other specific
2 proj ects of a capital nature: the Spokane River
3 Relicensing Costs, the Coeur d' Alene Tribe Settlement and
4 the Montana Riverbed Lease. Are these costs included in
5 your acceptance of the Company's rate base additions
6 discussed above?
7 Q.No, i discuss my recommendations for each of
8 these expenditures below, and separate from the rate base
9 additions discussed above.
10 Spokane River Relicensing
11 Q.What are your recommendations for the costs
12 expended to date on the Spokane River Relicensing?
13 A.I recommend that all costs expended by the
14 Company for Spokane River hydro relicensing continue to
15 be deferred as they were in the last rate case. The
16 Company has still not obtained a FERC license for the
17 project and therefore, final costs are not known and
18 measureable nor is the new license used and useful.
19 Staff witness Lobb also discusses this in his testimony.
20 Once the license is obtained, Staff will be able to
21 conduct a thorough review of all costs for prudency and
22 include the prudent costs in rate base at that time.
23 The FERC license for the Spokane River
24 hydro-electric facilities has not yet been issued, and
25 there is no indication from FERC when that license might
CASE NOS. AVU-E-09-1/AVU-G-09-1
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STAFF
4
1 be issued. Currently, the Company is operating the
2 facilities on a temporary license. Past practice would
3 indicate that the Company will be able to continue its
4 operation under a temporary license for the future.
6
5 Company witness Storro testified that the license should
7 However, there is no evidence that the license will be
be issued by July 2009.(See Storro testimony, page 29).
9
8 issued at that time.
Q.Is deferral of these relicensing costs
10 consistent with the Commission's Order in last year's
11 rate case?
12 A.Yes. In the Company's last rate case
13 (AVU-E- 08 - 01), all the costs for the relicensing were
14 deferred. In Order No. 30647, the Commission accepted
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15 the Stipulation of the parties to the case. The
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Stipulation stated:
9. Accounting Treatment for Certain Costs.
(a.) Spokane River Relicensing - The Company
included the processing costs associated with
its Spokane River relicensing efforts, which
expenditures included actual life-to-date costs
from April 2001 through December 31, 2007, and
2008 pro forma expenditures though December 31,
2008. (See Andrews' Direct Testimony at page
32) Although the Company anticipates receiving
a final license from the Federal Energy
Regulatory Commission ("FERC") in the near
future, that has yet to occur. The relicensing
costs will remain in CWIP (Construction Work in
Progress) and the Company will continue to
accrue AFUDC until issuance of the license, at
which time the relicensing costs will be
transferred to plant in service and
CASE NOS. AVU-E-09-1/AVU-G-09-1
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LECKIE, J (Di)
STAFF
5
1 depreciation will begin to be recorded. The
Parties have agreed to defer as a regulatory
expense item (in Account 186 - Miscellaneous
Deferred Debits) on the Company i s balance sheet
depreciation associated with Idaho's share of
the aforementioned relicensing costs and
related protection, mitigation, or enhancement
expenditures, until the earlier of twelve (12)
months from the date of the issuance of thelicense or the conclusion of Avista i s next
general rate case ("GRC"), together with a
charge on the deferral, as well as a carrying
charge on the amount of relicensing costs not
yet included in rate base. The carrying charge
for deferrals and rate base not yet included in
establishing rates would be the customer
deposit rate at that time (presently 5%) .
(Emphasis added) .
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11 The situation has not substantially changed between that
12 case and this one. No evidence indicates the license is
13 any nearer to issuance now than it was then.
14 Consequently, it is reasonable to continue the provisions
15 for deferral of the depreciation and the carrying charge
16 as set out in the stipulation.
17 Coeur d' Aiene Tribe Settlement
18 Q.Please explain the background surrounding
19 the Coeur d' Alene Tribal Settlement.
20 A.This litigation extends back to 1973 but I
21 will outline the recent history. Briefly, the Tribe
22 asserted that it possessed an ownership interest in Coeur
23 d' Alene Lake and its banks. In 1992, the federal
24 government brought suit against the State of Idaho on
25 behalf of the Tribe to quiet title to that lower portion
CASE NOS. AVU-E-09-1/AVU-G-09-1
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STAFF
6
1 of the Lake located within the Reservation boundaries.
2 On appeal to the U. S. Supreme Court, the Court ruled that
3 the United States held in trust for the Tribe, that
4 portion of the Lake within the Reservation. Idaho v.
5 United States, 533 U.S. 262, 121 S. Ct. 2135 (2001).
6 The Court's decision that the Tribe owned
7 the lower part of the Lake opened the door to other
8 claims against Avista. These claims included: Avista' s
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"storage" of lake water for its hydro-electric facilities
without authorization of the Tribe constituted a
"trespass" on Tribal lands for the period from 1907 to
1981; this trespass would entitle the Tribe to
compensation under § 10 (e) of the Federal Power Act for
the past use of its lands to store water; § 10(e)
(storage) compensation for the period from 1981 to the
present; and prejudgment interest. Based upon the
Court's decision, Avista and the Tribe entered into
settlement negotiations with a mediator. After years of
negotiations, the parties reached a settlement last year
but the terms of the settlement had not been approved
prior to the Commission's Order in the prior rate cases.
Q. Why is the Company attempting to recover
costs it expended in litigating and settling a legal
action with the Coeur d' Alene Tribe?
CASE NOS. AVU-E-09-1/AVU-G-09-1
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STAFF
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1 A.In December 2008 the Company reached an
2 agreement with the Tribe over its property right claims.
3 The settlement provides for an annual payment to the
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4 Tribe for the present right to store water on the Tribe's
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land (§ 10 (e) of the FPA) ($400, OOO/year for first 20
years and $700, OOO/year for the next 30 years); an annual
payment of $32,000 for a transmission line easement
across the lake; and a series of payments totaling $39
million for the past storage and the "trespass." As
explained above, these claims relate to the Spokane River
facili ties and are the subj ect of a relicensing process
with FERC. The resolution of this legal action clears
one of the Company's hurdles to receive that new license.
Recovery of these costs was in the Company's
last rate case (AVU-E-08-01) were not included in the
agreed upon revenue requirement in that case because the
settlement agreement had not been completed, but the
Company was allowed to defer any annual payments made,
that portion of the $39 million paid (for the past
storage and trespass) and the costs of litigation plus a
carrying charge of five percent (5%) until this rate case
(deferred balance). The Company requested recovery of
its deferred costs by amortizing those costs over a 45-
year period. This time period was chosen to match the
remaining life for any new Spokane River license. Any
CASE NOS. AVU-E-09-1/AVU-G-09-1
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STAFF
8
1 unamortized balance would be included in rate base and
2 earn the overall rate of return.
3 Q.How is the Company requesting recovery of
4 these costs in this case?
5 A.Company witness Andrews has included the
6 annual payments and an amortization of the deferred
7 balance of costs as an addition to the requested revenue
8 requirement. This is a gross increase in annual expense
9 of $401,000 and net increase in the revenue requirement
10 of $257,000. See Company witness Andrews' Testimony,
11 Exhibit No. 10, Schedule 1, page 9.
12 Q.Did Staff review various options for
13 allowing the Company recovery of these costs other than
14 including the unamortized balance in rate base?
15 A.Staff considered the following options for
16 allowing the Company recovery of these costs: First,
17 Staff considered allowing recovery of the costs but not
18 allowing rate base treatment or allowing any return on
19 the unamortized balance. This would have resulted in a
20 reduction to the Staff's revenue requirement of
21 $1,108,000.
22 Second, Staff then considered the
23 reasonableness of allowing recovery but including a
24 return on the unamortized balance at the average cost of
25 debt. This would have been a reduction of $429,000 to
CASE NOS. AVU-E-09-1/AVU-G-09-1
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STAFF
9
1 the Staff's revenue requirement. Staff determined that
2 these options were not reasonable under the circumstances
3 because these costs are similar to other relicensing
4 costs or expenses previously considered and accepted by
5 the Commission for rate recovery.
6 Third, Staff also considered amortizing
7 these costs over a life other than 45 years. I believe
8 it is appropriate to link the amortization of these costs
9 to approximately the same life as a new license for the
10 Spokane River hydroelectric facilities. While the
11 agreement and associated costs stand alone from the new
12 hydropower license, the agreement is required before a
13 new license can be obtained. Therefore, it seems
14 reasonable to amortize the agreement costs over the
15 expected useful life of the new hydropower license.
16 Q.Is Staff in agreement that the Company
17 should be allowed to recover these costs?
18 A.Yes. Staff also reviewed the possibility of
19 challenging the $39 million in payments and a related
20 portion of the litigation costs under the theory of
21 retroactive ratemaking. Some might argue that if these
22 costs are attributable to a past period and, therefore,
23 it would be inappropriate to have current ratepayers bear
24 the burden of such costs. An alternative theory is that
25 because the past actions where claimed to be for past
CASE NOS. AVU-E-09-1/AVU-G-09-1
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STAFF
1 trespass to property, an unlawful act, these costs should
2 not be recoverable.
3 Staff determined that it would not challenge
4 recovery of the costs on these theories. Staff places
5 great weight on the fact that the legal obligation did
6 not become known and measurable until the Supreme Court's
7 2001 decision and until the subsequent settlement was
8 legally accepted by the appropriate authorities in 2008
9 makes this an argument of retroactive ratemaking tenuous
10 at best. The legal obligations and monetary costs of
11 these issues were not fully settled until the settlement
12 approved in December 2008.
13 Q.Should the Company be allowed to recover the
14 deferred balance of the payments and expenses?
15 A.It is clear that the annual payments for the
16 ongoing use of the Tribe's property and the right to use
17 the Tribe's property for water storage, as well as the
18 transmission easement are reasonable and reoccurring
19 costs of doing business. Therefore, the annual payments
20 to the Tribe for the use of the property and the
21 transmission easement should be recoverable by the
22 Company in its revenue requirement.
23 Q.What about the recovery of that portion of
24 the $39 million payments made through the test period
25 plus the litigation costs amortized over 45 years with
CASE NOS. AVU-E-09-1/AVU-G-09-1
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LECKIE, J (Di) 11
STAFF
1 the unamortized deferred balance included in rate base as
2 requested by the Company?
3 A.I have reviewed the Company's treatment of
4 these costs and support the amortization of these costs
5 over the 45-year period. I also support including the
6 unamortized balance in rate base to earn the overall rate
7 of return. If the deferred balance is amortized over a
8 45-year life, the Company should be entitled to receive
9 some return on the unamortized balance. Allowing the
10 unamortized balance to accrue a return at the average
11 cost of debt does not recognize the full financing costs
12 to the Company for these expenditures.
13 The history of this action is long and
14 complicated. Ultimately, the matter found a forum in the
15 U. S. District Court where the legal issues were presented
16 by the interested parties. It was under the supervision
17 of the federal district court that the settlement was
18 finally achieved. During this entire process, the
19 Company diligently pursued a clear definition of its
20 legal rights, thereby clarifying its legal obligation.
21 It appears the Company actively pressed its legal
22 defenses to the claims by the Tribe. Ultimately, the
23 Company agreed to pay the Tribe $39 million as
24 compensation for 100 years of use of tribal property.
25 Also the Company has expended litigation costs of $2.15
CASE NOS. AVU-E-09-1/AVU-G-09-1
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STAFF
1 million to determine what its legal rights and
2 obligations are respecting the Tribe and its property.
3 Since the settlement was agreed to by all the interested
4 parties, including review by the U. S. Department of
5 Interior, it can be argued that the Company reached a
6 fair and reasonable settlement for its costs in this
7 matter.
8 Prior to 1973, the Tribe asserted no
9 ownership interest of the property used by the Company
10 for water storage that would have caused the Company to
11 be put on notice that their use of the property was
12 improper. Prior to the settlement, the specif ic amount
13 of an obligation, if any, owed by the Company was not
14 known or measurable. Therefore, any speculation on these
15 costs by the Company could not be included in any request
16 for recovery from the Commission.
17 Q.Do you agree with Company witness Andrews'
18 determination of the annual amount of amortization and
19 the amount of the deferred balance that will be amortized
20 in the test period?
21 A.No. I am in disagreement with the
22 accounting methodology used by Company witness Andrews to
23 determine the amount of the annual amortization and the
24 amount of the unamortized balance to include in rate
25 base. As I discuss the deferred balance amounts, I will
CASE NOS. AVU-E-09-1/AVU-G-09-1
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LECKIE, J (Di) 13
STAFF
1 only use Idaho's allocation of the total system costs.
2 (The total system costs are included in Company witness
3 Andrews' Exhibits and Workpapers, as well as the
4 allocation to Idaho.)
5 The basic difference between Company witness
6 Andrews' calculation and my calculation is the 12 -month
7 period of time used to determine the average of monthly
8 balances. Company witness Andrews used the monthly
9 balances for the months of July 2009 through June 2010;
10 and I used the monthly balances for the months of January
11 2009 through December 2009. Exhibit No. 108, page 2
12 compares the Company's calculation of a $7,861,266 rate
13 base addition to the Staff calculation of $6,796,290 for
14 a net rate base difference of $1,064,976.
15 While I agree with the Company's
16 determination of the beginning deferred balance of the
17 CDA Tribe settlement costs, an adjustment must be made to
18 the calculation of the unamortized deferred balance to be
19 added to rate base in order to be consistent with Staff's
20 recommended proforma period ending December 31, 2009.
21 The period used by the Company to determine average
22 monthly rate base balances ended June 30, 2010. Under
23 the terms of the settlement with the CDA Tribe, a payment
24 of $3,541,000 ($10,000,000 total system) must be made in
25 December of 2009. This payment has been included by the
CASE NOS. AVU-E-09-1/AVU-G-09-1
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STAFF
1 Company in the unamortized monthly deferred balance as
2 part of the average through June 2010. Because Staff's
3 proforma period ends in December 2009, this payment
4 should only be included in the December 2009 deferred
5 balance as the average of monthly deferred balances is
6 calculated. See Staff Exhibit No. 108, page 2.
7 With the difference in monthly balances used
8 by the Company and Staff, the annual amortization of the
9 deferred balance as determined by Staff is $26,000 less
10 than the determination by the Company and reduces the
11 Company's revenue requirement by this $26,000. See
12 Staff's Exhibit No. 108, page 1.
14
13 Non tana Lease
Q.What recommendations do you have for Company
16
15 witness Andrews' treatment of the Montana Lease Bxpense?
A.I recommend acceptance of the accounting
17 treatment for the Montana Lease annual expense as
18 appropriate for inclusion in the revenue requirement
19 calculation.
20 The Company sought and obtained the right to
21 defer the costs associated with lease payments to Montana
22 under the terms of its settlement with the State of
23 Montana on the issue of rental of state property in the
25
24 stream beds of hydro-electric facilities owned by the
Company in Montana.(See Order No. 30492). Company
CASE NOS. AVU-E-09-1/AVU-G-09-1
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LECKIE, J (Di) 15
STAFF
1 witness Andrews is asking to defer the Idaho costs to
2 date of $2,885,489 over eight (8) years, or $360,686 per
3 year. Idaho's share of the annual expense for the 2009
4 test year is $1,556,781. Total expense for the test year
5 is $1,917,465, and a net increase to the revenue
6 requirement of $1,231,000.(See Company witness Andrews
7 Exhibit No. 10; Workpaper PF12-3)
8 Company witness Andrews' amortization of the
9 deferral amount is the annual amount necessary to
10 amortize the deferred balance over the 8-year period.
11 The annual deferral expense remains constant over the 8-
12 year period. The 8 -year period is an appropriate period
13 of time for the deferral because the agreement/settlement
14 with the State of Montana has a provision for
15 renegotiating the annual lease price beginning in 2016 or
16 eight (8) years from the date of the agreement.
17 The annual lease payment is increased
18 annually by a CPI index. I have reviewed the CPI index
19 increases to determine the annual lease obligation for
20 2009, and the Company used the appropriate increases to
21 determine the 2009 Idaho share of the annual payment of
22 $1,556,781.
23 Q.What is the Company's proposal for the
24 unamortized balance of the total costs?
25 A.The Company is asking that the unamortized
CASE NOS. AVU-E-09-1/AVU-G-09-1
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STAFF
1 balance of the lease settlement cost ($2,434,617) be
2 included in rate base. I recommend that this balance not
3 be included in rate base, but be amortized over the
4 remaining seven years of the proposed 8 -year amortization
6
5 period. This adjustment would reduce net rate base by
$1,582,501.(See Company witness Andrews' Workpaper
7 PF12-4 and Staff witness Vaughn Exhibit No. 118, page 3,
8 Column S) .
9 Staff recommends the Company be allowed to
10 recover its out of pocket costs. However, Staff
11 recommends the unamortized balance not be included in
12 rate base. The 8 -year recovery period allows full
13 recovery of the lease payments and is a short enough time
15
14 period to not require a return.
Q.Does this conclude your direct testimony in
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16 this proceeding?
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A.Ye s , it doe s .
CASE NOS. AVU-E-09-1/AVU-G-09-1OS/29/09 LECKIE, J (Di) 17
STAFF
. Coeur d'Alene Tribe Settlement
Idaho Allocation Only
(OOO'S OF DOLLARS)
Line
No.DESCRIPTION Comnany Staff Position Difference
REVENUS --
I Total General Business $0 $0 $0
2 Interdeparental Sales 0
3 Sales For Resale 0
4 Total Sales of Electrcity 0 0 0
5 Other Revenue 0
6 Total Electric Revenue 0 0 0
EXPENSES
Production and Transmission
7 Operating Expenses 0 0 0
8 Purchased Power 0
9 Depreciation and Amortization 401 361 (40)
10 Taxes 0
II Total Production & Transmission 401 361 (40)
Distrbution .
12 Operating Expenses 0 0 0
13 Depreciation 0
14 Taxes (5)(4)1
15 Total Distrbution (5)(4)1
16 Customer Accounting 0 0 0
17 Customer Service & Information 0 0 0
18 Marketing 0 0 0
Administrative & General
19 Operating Expenses 0 0 0
20 Depreciation 0 ----~-
21 Taxes 0
22 Total Admin. & General 0 0 0
23 Tota Electrc Expenses 396 357 (39)
24 Operating Income before FIT (396)(357)39
Federal Income Taxes
25 Curent Accrual 35.0%(138)(125)13
26 Deferred Income Taxes 0
0
27 NET OPERATING INCOME ($258)($232)$26
RATE BASE
PLANT IN SERVICE
28 Intangible $11,930 $10,168 $1,762
29 Production
30 Transmission
31 Distribution
32 General
33 Total Plant in Service 11,930 $10,168 $1,762 i34ACCUMATED DEPRECIATION (219)($109)($110)
35 ACCUM. PROVISION FOR AMORTIZATION ex I
36 Total Accum. Depreciation & Amor .(219)(109)($110)0..I
37 GAIN ON SALE OF BUILDING .
38 DEFERRD TAXES (3,850)(3,263)($587):£
39 TOTAL RATE BASE $7,861 $6,796 $1,065 LJor-
Exhibit 108,.0or-
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CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 29TH DAY OF MAY 2009,
SERVED THE FOREGOING DIRECT TESTIMONY OF JOE LECKIE, IN CASE
NOS. A VU-E-09-1 & A VU-G-09-1, BY ELECTRONIC MAIL TO THE FOLLOWING:
DAVID J. MEYER
VICE PRESIDENT AND CHIEF COUNSEL
AVISTA CORPORATION
PO BOX 3727
SPOKANEWA 99220
E-MAIL: david.meyerCfavistacorp.com
DEAN J MILLER
McDEVITT & MILLER LLP
PO BOX 2564
BOISE ID 83701
E-MAIL: joeCfmcdevitt-miler.com
CONLEY E WARD
MICHAEL C CREAMER
GIVENS PURSLEY LLP
PO BOX 2720
BOISE ID 83701-2720
E-MAIL: cewCfgivenspursley.com
mccCfgivenspursley.com
BETSY BRIDGE
ID CONSERVATION LEAGUE
710 N SIXTH STREET
POBOX 844
BOISE ID 83701
E-MAIL: bbridgeCfwildidaho.org
CARRE TRACY
1265 S MAIN ST, #305
SEATTLE WA 98144
E-MAIL: carrieCfnwfco.org
KELL Y NORWOOD
VICE PRESIDENT - STATE & FED. REG.
A VISTA UTILITIES
PO BOX 3727
SPOKANE WA 99220
E-MAIL: kelly.norwoodCfavistacorp.com
SCOTT ATKINSON
PRESIDENT
IDAHO FOREST GROUP LLC
171 HIGHWAY 95 N
GRANGEVILLE ID 83530
E-MAIL: scottaCfidahoforestgroup.com
DENNIS E PESEAU, Ph.D.
UTILITY RESOURCES INC
SUITE 250
1500 LIBERTY STREET SE
SALEM OR 97302
E-MAIL: dpeseauCfexcite.com
ROWENA PINEDA
ID COMMUITY ACTION NETWORK
3450 HILL RD
BOISE ID 83702-4715
E-MAIL: RowenaCfidahocan.org
BRAD MPURDY
ATTORNEY AT LAW
2019 N 17TH ST
BOISE ID 83702
E-MAIL: bmpurdyCfhotmail.com
'~U4;D~ \\Q
SECRETARY
CERTIFICATE OF SERVICE