20191031English Direct in Support of Stipulation.pdf

BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION,
RECEIVED
;:;9 [iT 3 t Pil l: 3i
,.,]'''|
IN THE MATTER OF THE APPLICATION OF
AVISTA CORPORATION FOR THE
AUTHORITY TO INCREASE ITS RATES
AND CHARGES FOR ELECTRIC SERVICE
TO ELECTRIC CUSTOMERS IN THE
STATE OF IDAHO
CASE NO. AVU-E.19.04
DIRECT TESTIMONY OF DONN ENGLISH
IN SUPPORT OF THE STIPULATION
AND SETTLEMENT
IDAHO PUBLIC UTILITIES COMMISSION
ocToBER 31, 2019
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O. Please st.at.e your name and business address for
the record.
A. My name is Donn English. My business address is
l-1331 W. Chinden B1vd., BLDG 8. STE 201-A, Boise, Idaho
837 L4 .
O. By whom are you employed and in what capaciEy?
A. I am employed by the Idaho PubLic utiLitsies
Commissj-on as a Program Manager overseeing t.he Accounting
and Audit Department in the Ut.ilities Divisj-on.
O. Whats is your educational background and
prof essional experience?
A. I graduated from Boise Stsaue University in l-998
with a Bachelor of Business AdminisEration ( *BBA" ) degree
in Accounting. Fol-1owing my graduation, I accepted a
position as a Trust Accountant. with a pension
administration, actuarial , and consulting firm in Boise.
ln !999, r was promoted Eo Pension Administrator. rn May
of 2ool-, I became a designated member of the American
Society of Pension Professionals and Actuaries ("ASPPA").
I was the first. person in Idaho to recej-ve the Qualified
401(k) Administrator certification and was also one of
approximately ten peopfe in Idaho who have earned the
Qualified Pension Administ.rator certification. In 2001, I
was promoted to a Pension Consultant.
I was hired by t.he Idaho Publ-ic UtiliEies
CASE NO. AVU-E-19-04 ENGLISH, D
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Commission as a Staff Auditor in 2003. In 2016, I became
Ehe Audic Team Lead, and in 2018 I was promoted to Program
Manager of Accounting and AudiE. Department. At the
Commission, I have audited a number of utilities including
elecEric, water, and natural gas companies, and provided
comments and Eestimony in numerous cases t.hat dealt with
general rates, tax issues, pension issues, depreciation and
other accounting issues, and other regul-atory policy
declsions. In 2004, I actended thre 46th Annual Regufatory
studies Program at the Inst.it.ut.e of Public Util-ities aE
Michigan StaLe Universit.y sponsored by the National
Association of Regulatory UEility Commissioners ("NARUC" ) .
since then I have regularly atEended NARUC conferences and
meeEings, Society of Regulatory Financial Analysts
(*SURFA") meet.ings, and oE.her regulatory training
opportsunities. I am the Commission's representaElve on the
NARUC SubcommiEtee of Accounting and Finance.
O. What is the purpose of your EesEimony in this
proc eeding ?
A. The purpose of my testimony is to describe AvisEa
Corporation's ("Avista" or "Company" ) Application to
increase its rates and charges for el-ectric service in
Idaho, describe the proposed comprehensj-ve settLement
reached by all part.ies in this case, and explain Staff's
support for Ehe proposed agreement.
ENGLISH, D
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o.
A.
headings :
How is your Lest.imony organized?
My test.imony is subdivided under the following
Background Page 3
Settlement Overview Page 5
Staff Investigat.ion Page 5
Settlement. Evaluat.ion Page 8
Revenue Requirement. Page 10
Al-locations and Rate Design Page 15
Energy Efficiency Page l-7
Other Terms and CondiEions Page 18
Background
O. Please describe AvisEa's original filing.
A. Avist.a made iEs original filing on June ).0, 20L9,
requesting authority to increase its elect.ric base ratses in
Idaho by $5.255 million or 2.].2, effective 'January l, 2020.
The requested increase was based on a 2018 tes! year, with
proforma adjustsmentss t.hrough 2020. Rate base was presented
on a 2019 proforma end of period basis. The Company
proposed a capital structure of 50/50 and a return on
common equity ("RoE" ) of 9.9t.
Based on Ehe different cosE-of-service
methodologies fil-ed, the Company proposed no increase for
ceneral- Service Schedules 11/12 and street and Area LighE
Schedufes 47-49, resulting in a 30? movement towards unity.
Large ceneral Service cusEomers (Schedules 21,/22), Extra
Large General Service customers (Schedules 25 and 25P) , and25
CASE NO. AVU-E_ 19 - 04
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Pumping customers (Schedules 3L/32) would receive ?5? of
the overall base revenue increase. The remaining revenue
requiremenE was proposed to be spread to Residentiaf
Service Schedule 1, resulting in a 34t movement towards
uniEy. Tabl-e No. 1 below illustrates the proposed revenue
spread and relative rates of return ("ROR" ) for Ehe
customers cl-asses.
Table No. 1 - Proposed Rate Spread and Relative ROR
fncreaBe in
Base Rates
ProposedRelative RORRale scheduleResidenti,af Schedule 1cen. service Schedules 11/ 1-2Lg. cen. Service schedules 2l-/22Extra Lg. Gen. Service Sch. 25
CfearwaLer Papwer Sch. 25P
Pumpj-ng service schedules 3l-/32St.reet & Area Lights Sch. 41-49
overalL
cAsE NO. AVU-E-19-04
3.42
0.0*
1.5?1.5t
1. st1.5t0.0?4
0.88
1.36
1.06
0.90
0.95
o.96
1.38I.TT
O. How was the case processed after the Company's
filing was received?
A. The Commission issued a notice of filing and
established an inE.ervenEion deadline. Intervenor stsaEus
was granEed to Cl-earwater Paper Corporation ("Clearwater"),
Idaho Forest Group, LLC, the Community Action Part.nership
Association of Idaho, Inc. ("CAPAI"), the Idaho
Conservation League, Inc. ("ICL"), and Walmart, Inc. A
procedural schedule was approved by the Commission and a
settlement conference was held on October 1, 2019. A
comprehensive set.L.lemenL was reached by all parties, and
ENGLISH, D
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the Motion to Approve the SEipulatsion and Settlement was
filed with the Commission on OcEober 1,5, 20L9.
settlement overview
O. Would you please descrj-be the terms of t.he
setElement?
A. The proposed Stipulation and Settl-emenL
("SettlemenE") specifies a decrease in elect.ric base
revenues of $7.188 million (2.84*) on December 1, 2019. It
also specifies a 50/50 debE Eo equity capital stsrucEure, a
5.2? cost of debE, and a 9.5? return on common equity. The
overall return is 7.35?.
Besides specifying capital structure, return on
equity, and Ehe cost of debts, tshe SeEt.Iement also specifies
a variety of expense and invescment adjusEments. The
revenue requirement adjusEmenE.s faff primarily into lhree
categories: 1) update 2019 pro forma expense and invesEments
with known, actual amounts; 2) modify or update
m j. sce]]aneous Eest year expenses; and 3) lengthen
amorEization periods for deferred accounts. The revenue
requirement is further adjusted by continuing the PaLouse
Wind Purchase Power Agreement ("PPA" ) expense recovery
t.hrough the Power cost Adjustment ("PCA") mechanj-sm ratsher
than through base rates.
The revenue decrease will be spread to the
customer classes in varying amounts to move towards
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CASE NO. AVU- E- 19 - 04
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cost-of-service parity. The decrease by cuscomer class and
relative ROR for each class is shown in Table No. 2 below:
Table No, 2 - Stipulated Rate Spread and Re1atj.ve ROR
IncreaEe in Stipulated
Rate Schedule Base Rates Relative RORResidential Schedule Icen. Service Schedules 11/ 12Lg. cen. Service Schedules 21/22Extra Lg. Gen. Service Sch. 25Clearwacer Papwer Sch. 25P
Pumping Service Schedules 31/32
Streets & Area Lights Sch. 41-49
Overal l
The setstslements also provides additional funding
for energy efficiency projects in Idaho, and increases the
annuaf funding for the Company's Low Income Weatherization
Program from the currenly approved $800,000 to $850,000 per
year.
O. Are Ehere any other provisions included in the
Sett lement ?
A. Yes. The Settlement
of base power supp]y revenues,
Ehe Load Change Adjustment Rate
stipulaled revenue reguirement
PCA mechanism cafcufations. It
al-so specifies the new
1oad,
1evel of base]ine val-ues for t.he
adjustment ("FCA" ) mechanism.
also specifies
electric fixed
Staff Inve6tigation
O. what type of investigation did staff conduct to
fevef
andexpenses, retail
resulting from
for purposes of
the
the monEhly
the new
cosLs
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-4.52
-1.0?
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0.86
1.35
1.05
0 .92
o .99
1.00
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evaluatse tshe Company's rate increase request?
A. Staff's approach prior to the settlement
conference was to extensivel,y review the Company's
Application and associaEed testj.mony and workpapers,
ident.ify adjustments to its revenue requirement request,
and prepare to file testimony for a ful fy- 1j- tigated
proceeding. Three Staff auditors were assigned to the case
and began reviewing the 2018 results of operations before
Ehe Company fifed iE.s Applicaton in ,June of 20f9. AfEer
the filing, the auditsors reviewed the capital budget.s,
capital spending Erends, operations and maintenance ("o&M" )
expenses and trends, and verj,f ied all of the Company's
calculations and assumptions with regards Eo Ehe overall
revenue requirement. The auditors spent two rreeks on-siEe
at Avist.a's corporate headquarters in Spokane, Washj-ngton.
interviewing Company personnel, reviewing thousands of
tsransactions, selected samples and performed transacEion
testing in accordance wj-Eh standard audit pracEices. The
audit.ors reviewed Ehe Company's labor expense, incentive
plans, and employee benefiEs Eo insure the appropriaEe
1eve1 of expendiEure.
The auditors worked with ten other technical
sUaff from the Utilities Division, consisEing of engineers,
utility analysts, and consumer investigators, to determine
t.he prudence of capit.al additions and verify in-service
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dat.es. Staff reviewed both completed and proposed Company
investments, evaluat.ed expenditures incl-uding pension.
salaries, and operation and maintenance expenses,
investigated power suppLy modeling, weather normalizat,ion,
class cos!-of-service methodologies, and compared rat,e
design alternatives. In total, Staff submitEed over 150
production requests to the Company as part of iE.s
comprehensive investigation. In additsion to audit. work
on-sitse, other Staff also conducted on-site investigations.
O. How did St.af f prepare for the settlemenL
conf erence ?
A. Stsaff prepared for the settlement conference by
preparing for testimony as in a litigated case. In
developing its revenue requiremenE proposal, Staff
identified 28 adjustments Eo Ehe Company's requested
revenue requirement totaling $14.35 mi11ion. sE.af f
developed iEs revenue requirement proposal and escablished
positions on various issues for presentation at the
setstslement conference on Oct.ober 1, 2019, whj.Ie
simultaneously preparing direct. testimony to file on
November 5, 2oL9, should Ehe case be fitigated.
Settslement Evaluati.on
O. How did Staff determine that the overall
Settfement was reasonable?
A. In every setstlement evaluaE.ion, Staff and other
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partsies must deLermine if the agreement is a better overall
outcome than could be expecE.ed ats hearing. A11 of Ehe 28
revenue requirement adjustments identified by Staff were
incorporated eiEher totally or partially in the Settfement..
Rather than an increase of $5.255 million as proposed by
the Company, the Settlement specified an electric revenue
decrease of $7.188 miLlion. Other parties, made up of
customer groups and fow income representatives , agreed wj.th
Staff in support of the Settlement.
O. Does staff support. the proposed seEtlement as
reasonable ?
A. Yes. After a comprehensive review of the
Company's Application, thorough audit of the Company's
books and records, and extensive negotiations with the
partsies to tshe case, Staff supports the proposed
Sett,1ement. The Sett]ement offers a reasonable balance
between E.he Company's opportunity to earn a reE.urn and
affordable rates for customers. Several- of Staff's primary
goals after evaluation of revenue requirement have been met
with this Settl-emetn. Its provides addiLional funding for
energy efficiency projects and the Company's low income
weatherization program. Not all cost-of-service alfocat.ion
concerns or different methods addressed by other parties
are included in tshis settlement. However, iE does properly
address cost-of-service differentials raised by the various
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parties, including Staff, by distributing the rate decrease
base on costs causatsion principl-es to bring customer classes
closer to parity. Staff believes thaE t.he Settlemenc,
supported by alt part.ies to the case, is in t.he public
interest, is fair, jusE and reasonabl-e, and should be
approved by Ehe Commission.
Revenue Requirement
O. What type of revenue requirement adjustments were
proposed by Staff and included in the Sett.lement?
A. The adjustments proposed by SEaff covered a broad
range of revenue and cost caEegories. Besides a reduction
in RoE, the adjustments generally fa]1 into the three
previousfy identified categories: 1) updaEe 2019 pro forma
expense and invesEment wit.h known, actual amount.s; 2)
modify or update miscellaneous test year expenses,' and 3)
Iengthen amortization periods for deferred accounEs.
O. Please explain why staff believes the 9.5t RoE is
reasonable ,
A. The Stipulation ref Iect.s an RoE of 9.52 based on
a capital- structure of 50? equiLy and 50* debt. The
Company originally proposed a 9.9? ROE. The 9.5? RoE is
consistent. with the Company's currently authorized ROE, and
also with the most recent Commission decisi-on for
Inlermountain Gas Company in Order No. 33757. It is also
consistenE wit.h authorized ret.urns grantsed for other
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elecEric and gas utilit.ies operating in t.he NorEhwests. The
40 basis point reduction in ROE from the Company's proposal
reduced Ehe Company's requested revenue requiremenE by
approximately $2.2 million. The 9.5* ROE allows Avist.a to
attract new capitsal from the market to fund new capital
investments and refinance maturj-ng debt issuances.
a. will you please explain oEher revenue requirement
adjustments proposed by SEaff and accept.ed by Ehe part.ies?
A. Yes. While Table No. 1 of the SettlemenE
provides a line by line calculation of Ehe revenue
requirement, and the SeEtlement further provides a summary
of each adjusEmenE., I will highlight a few of the major
adjustments. The first adjustments proposed by Staff
related Eo the timing of expenses and invesEmenEs, The
Company proposed a EesE year based on a 2018 base year with
proforma expenses t.hrough 2020, arld capitsal investments
t.hrough 2019. Staff verj.f ied the proforma expense amounts
with acEuaf expenses as they became available.
Additional"ly, staff invest.igat.ed t.he in-service dates of
proposed capital projects to confirm tshey would be j-n-
service and used and useful prior to the end of 2019. By
removing capit,al projects not completed in 2019 from the
Company's request, Idaho jurisdictional rate base vras
reduced by $9,070.000 which reduced the Idaho electric
revenue requirement by approximately $1.5 mi1Iion.
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Updating 2019 expenses wit.h acEual amounts reduced Ehe
Idaho elecErj-c revenue requirement by another $1.15
mi 11ion .
O. Woufd you please explain how the SetElement
treats employee labor and benefits?
A. Yes. The Company proposed to include in j.ts
Idaho efectric revenue requirement proforma labor expenses
through 2020 for non-executj.ve employees, and increased
labor expense t.hrough 2019 for its execut.ives. The parEies
agreed Eo only include the schedufed 2O2O wage increases
for the Company's union employees because E.hat wage
increase is a conEracEual obligation under the Company's
collective bargaining agreements. Af1 other 2020 wage
increases were removed, Additionally, the 2019 wage
increase for the Company's executives was also removed from
t,he revenue requirement. The effect of the agreed upon
labor adjustments reduced t.he Company's requested revenue
requirement by $305, 000.
The company also included in its request.
incentive palrments for its employees and execut.ives.
Consistent with prior Commission treatmenL, St.af f proposed
and the parties agreed Eo remove executive incenEives in
their entirety from Ehe Company's revenue requirement.. For
non-executive incentive payment.s, t.he part.ies agreed to
include on]y the operating portion of the incentives aE the
CASE NO. AVU- E- 19 - 04
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2018 t,arget ]eveI, as opposed to the 6-year average
proposed by Ehe Company. The effect of the agreed upon
level of incentives reduced the Company's requested revenue
requirements by $438, 000.
The Company also proformed employee benef j-ts
through 2020 in its original requesE. Staff proposed and
the parties agreed to remove L}re 2o2o mat.ching
contribulions Eo the Company's 401(k) and use the 2018 Eest
year level of matching contributj-ons plus a 3* labor
escalator for 201-9. The Company's pension contributions
were estimaEed to decrease ifl 2020. To remain consistenE
with Staff's policy on excluding 2020 labor and benefiEs,
tshe part.ies agreed Eo accept the higher 201-9 pension
contribution. The overalL effect of the adjusEments to Ehe
Company's employee benefits increased tshe Company's
requested revenue requirement. by $86,000.
O. Please explain tshe treatment of t.he PaLouse Wind
and RatElesnake Flats Wind PPAs.
A. Both the Pafouse Wind and Rattlesnake Flats PPAS
have been removed from base rat.es and the costss associated
wit.h the PPAS \"ri11 be reflected in the PCA subject to the
current sharing (90? customer, LoZ Company) , The Palouse
Wind PPA was executed in 2011, and has never been incfuded
in base rates. In every previous settlement agreement in
Avista's race cases since its execution, Ehe expenses25
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associated with the PPA have been included in the PCA and
subjecL to sharing.
The Rattlesnake Flats Wj.nd PPA is expect.ed to
deliver power beginning in December 2020. The capital
investments necessary for Ehis project to be integrated
have been excluded from the Company's revenue requirement
and will be addressed in the Company's next general raEe
case. For purposes of t.his case, tshe partsies agree that
any expenses associated with the Ratstlesnake Flats Wind PPA
will be included in the PCA and subject t.o sharj-ng. The
effect of excluding t.hese two PPAS from base rates reduces
the Company's requested revenue requ.irement by
approximately $4 .3 million.
O. Will you please explain the miscellaneous
adjustment l-isted in the settfemenE.?
A. The miscellaneuous adjustment ref l-ects Ehe net
change in operaEing expenses for items SEaff discovered
during iEs audit. Those iEems consist of 1) the
reclassif icaEion of non-utility ffights and fixed cosEs
associatsed wit.h the Company's private jet, as well as the
expired lease expense; 2) Ehe amorEization of the 2018
intervenor funding over a Ewo-year period; 3) removal of
other miscellaneous administraEive and general ("A&G" )
expenses thaE should hrave been charged below-the-line; and
4) and agreed upon expense adjustment that increases
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revenue requirement by $500,000. The net effect of the
miscellaneous adjustment.s increases the Company's requested
revenue requirement by $451, 000.
Allocationa and Rate Design
O. Please explain the cost-of-service methodofogies
included in E.he Company's Application.
A. The Company's original Application in this case
incl-uded a Base Case electric cost-of-service stsudy where
producEion costs are classified to energy and demand based
on a the system load fact.or. Transmission costs are
cLassified l-00t demand and aLLocated by the average of the
12 monEhly coincident peaks. This methodology is
consisEent. with the cost - of - servi-ce studies filed in the
last four Idaho general rate cases (Case Nos. AVU-E-]-2-08,
AvU-E-15-05, AvU-E-16-03, and AVU-E-17-01) and reflecEs the
methodology EhaE was acceptsed in the stipul-ation and
Settlement in Case No. AVIJ-E-10-01.
The Company also provided three alternative
cost-of-service scenarios. The first al-t.ernative scenario
startss vrith the Base Case but incorporaEes tshe
cfassification of Dist.ribution Land and Land Rights (FERC
Pfant Account 360) as reLat.ed to other distribution plant
in FERC Plant Accounts 361 though 357. The second
alternative scenarj-o modified the coincidenE peak
allocation factor which is used on aIl demand-related
CASE NO. AVU- E - 19.04
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(Stip)1s
production and transmission costs t.o reflect. t.he average of
the seven highest monthly peaks during t.he E.est. period.
The third alt.ernat.ive scenario al-so modi.f ied the coincident
peak a11ocaE.j-on factor by using all twelve monthl-y peaks,
but the demand values were weighted by the marginal
costs-of-power in each month.
a. were Lhere any simiJ.ariti.es in tshe different
cost-of-service scenarios presented by Ehe Company?
A. Yes. Each cosE-of-service scenario presented by
the Company illustrated an under-recovery of assigned costs
by tshe ResidenEial class (Schedule 1) and Ehe Extra Large
General Service classes (schedul"e 25 and 25P) . General
Service Schedules 1l- and 12. al-ong with Larger Genera]
Service Schedules 21 and 22, were shown tso be over-
recovering Eheir assigned costs.
O. Do the parEj-es agree on any specific
cost-of-service met.hodology for lhis case?
A. No. The parties do not agree on any particular
cost-of-service methodology for t.his case. However, the
parties generally agree with the represenEations presenEed
in the multiple scenarios provided by t.he Company t.hat
certain customer classes do not recover all of their costs,
while other classes recover more Ehan t.heir assigned costs.
In recognition that certain rat.e schedules are wef l- above
their relaEive cost-of-service, the Parties agree that
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General Service Schedules 11 and 12, and Large Generaf
Service Schedufes 21 and 22 will receive a revenue decrease
above E.he overafl- base raEe change in order t.o move t.hese
schedules closer to cost. - of - service parity. The remaining
schedul-es will still receive a revenue decrease, buts tshe
decrease wilf be below Lhe overall percentage base rate
change. The rat.e decreases by Customer Schedule are shown
on page 10 of the settlemenE.
Energy Efficiency
O. Please explain the Settlement as it refates to
energy efficiency.
A. First., the sett,lement increases the annual amount
funded by the Company for its Low Income weaEherization
Assislance Program admininstered by the Lewiston Community
Action Partnership. The currencly auEhorized Level of
funding is $800,000. The settlement increases the Ieve1 of
funding to $850, 000 .
The SettLement al-so sEipulaEes that Avist.a will
establish an Energy Efficiency Assistance Fund ("EEAF" ) to
provide additsional funding for projects that are not
otherwise full-y funded through existing energy ef f icj.ency
incenEives, or do noL otherwise qualify for t.raditional
energy efficiency funding. The EEAF will be funded with a
deferred liability owed Eo cusEomers related Eo the
Allor"rance for Funds Used During Construction ("AFUDC")
CASE NO. AVU-E- 19.04to/3L/te ENGLISH, D
STAFF
(st ip ) 17
EquiEy Tax Deferral addressed in Case Nos. A\ru-E-19-02 and
AVU-G-19-01, as ordered by Commission Order No. 34326.
This deferral balance is approxi,mately 9800,000. Avista
will also contribute an addj.Eional $800,000 in below-the-
fine dollars as a matching contribution to the EEAF.
The funding will be disbursed as directed by the
EEAF Advisory Group, a new committee of stakehofders tasked
with determining which existing or new programs shoul-d
receive this addi-tional funding to address energy
efficiency, weatherization, conservation. and low-income
needs j-n Avista's Idaho service territ.ory. This committee
wj-11 initially consj.st of representatives from Avista,
Commission SEaff, Cl,earwaEer, Idaho Forest Group, ICL, and
the L,ewist.on Community Action Part.nership.
other TermB and condit.ionB
O. Are there Eerms and conditions described in the
Settlement?
A. Yes. The new leveI of power supply revenues,
expeneses, retail 1oad, and the Load Change Adjustment RaEe
resulting from the new December 1-, 2019 stipul-ated revenue
requirement. for purposes of the PcA mechanism are detai]ed
in Appendix A to the Sett,lemenc. Additionally, the new
l-eve1 of baseline val-ues for the electric FcA mechanism
resulting from the st.ipulated revenue requirement are
detail-ed in Appendix B.
CASE NO. AVU-E-19-0410/3r/t9
ENGLISH, D
STAFF
(stip) 18
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O. Does this conclude your testimony in this
proc eeding ?
A. Yes, it does.
CASE NO. AVU-E- 19 - 04
to / 3]-/ te
ENGLISH, D
STAFF
(st ip ) 1e
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE ]'HIS 3I'' DAY OF OCTOBER 2019.
SERVED THE FOREGOING DIRECT TESTIMONY OF DONN ENGLISH IN
SUPPORT OF THE STIPULATION AND SETTLEMENT, IN CASE NO. AVU-E-I9-04,
BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
PATRICK EHRBAR
DIR OF REGULATORY AFFAIRS
AVISTA CORPORATION
PO BOX3727
SPoKANE WA99220-372'1
E-MAIL: rratrick.chrbaraatavistacorD.conr
.1\ristadockels aiiavislacQlD.corn
PETER J RICHARDSON
RICHARDSON ADAMS PLLC
5I5 N 27TH STREET
BOISE ID 83702
E-MAIL eter'tZrichardsonadarns.cont
NORMAN M SEMANKO
PARSONS BEHLE & LATIMER
8OO W MAIN ST STE I3OO
BOISE ID 83702
E-MAIL: tlscrnanlior'4parsonsbt hlc.rltlrlr
BENJAMIN J OTTO
ID CONSERVATION LEAGTJE
710 N 6,IH ST
BOISE ID 83702
DAVID J MEYER
VP & CHIEF COTINSEL
AVISTA CORPORATION
POBOX3727
SPOKANE WA99220-3727
E-MAIL: tlavicl.nrcyeririlavi stacorp.corn
DEAN J MILLER
3620 E WARM SPRINGS AVE
BOISE ID 837I6
E-MAIL: clcanimiIlcra,cableonc.r.rcl
DR DON READING
6070 HILL ROAD
BOISE ID 83703
E-MAIL: dre-adingiii:rnindspri ns.conr
VICKI M BALDWIN
PARSONS BEHLE & LATIMER
2OI S MAIN ST STE 18OO
SALT LAKE CITY UT 84I I1
E-MAIL: r bald*'inlrDparsonsbchlc.corn
E-MAIL: botto:/il itlahoconselr,ation.or 1I
CERTIFICATE OF SERVICE
RONALD L WILLIAMS
WILLIAMS BRADBURY PC
PO BOX 388
BOISE ID 83701
E-MAIL: ron/Zrvillianrsbradburv.corn
BRAD M PTJRDY
AITORNEY AT LAW
20I9N 17TH ST
BOISE ID 83702
E-MAIL: bryp!41r_ghq1!t!atL!g l
S
CERTIFICA'TE OI.- SERV ICE
ELECTRONIC ONLY
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lenv.borden(Zlcl earwatemaper. com
nral i sa. ma.vnard (a);c learwaten:apcr.corn
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