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HomeMy WebLinkAbout20220729Application.pdf./ittsra Avista Corp. 141 I East Mission P.O. Box 3727 Spokane. Washington 99220-37 27 Telephone 509-489-0500 Toll Free 800-727-9170 July 29,2022 State of Idaho Idaho Public Utilities Commission 11331 W. ChindenBlvd Bldg 8 Suite 201-A Boise,ID 83714 Case No. AVU-E-22-12- Electric Fixed Cost Adjustnent Annual Rate Filing of Avista Corporation Dear Commission Secretary: Enclosed for electonic filing with the Commission is Avista's electric Fixed Cost Adjustment (FCA) annual rate adjustment filing. This filing consists of Avista's Application, Exhibit A (the Companyos proposed tariffs), Exhibit B (rate calculations), Exhibit C (12 months ending June 30, 2022 deferral), and Exhibit D (customer communications) in support of the Application. The Company request that the proposed tariffsheets be made effective October 1,2022 Electronic versions ofthe Company's filing were emailed to the Commission, and the Service List, on July 29,2022. Please direct any questions on this matter to me at (509) 495-8620 or Joel Anderson at (509) 495- 281 l. Sincerely, /s/ Patrick Ehrbar Patrick D. Ehrbar Director of Regulatory Affairs Enclosures Re: 1 DAVID J. MEYER2 VICE PRESIDENT AND CHIEF COT]NSEL FOR3 REGULATORY AND GOVERNMENTAL AFFAIRS4 AVISTA CORPORATION5 14I1 E. MISSION AVENUE6 P. O.BOX37277 SPOKANE, WASHINGTON 992208 PHONE: (509) 495-4316, FAX: (509) 495-8851 10 11 9 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION t2 l3 t4 15 t6 t7 IN THE MATTER OF THE FIXED COST ADruSTMENT MECHANISM (FCA) ANNUAL RATE ADruSTMENT FILING OF AVISTA CORPORATION CASE NO. AW-E-Z}-[ ?- APPLICATION OF AVISTA CORPORATION ) ) ) ) 18 I. INTRODUCTION 19 In accordance with Idaho Code $61-502, Commission Order No. 33437, and RP 20 052, Avista Corporation, doing business as Avista Utilities (hereinafter "Avista" or 2l "Company"), at 1411 East Mission Avenue, Spokane, Washington, respectfully makes 22 application to the Idaho Public Utilities Commission ("Commission") for an order 23 approving the level of electric Fixed Cost Adjustment Mechanism (FCA) revenue deferred 24 during the twelve month period from July 2021 through June 2022 and authorizing FCA 25 rates for electric service from October 1,2022 through September 30,2023. The FCA rate 26 for the Residential Group (Schedule l) is proposed to change from a present rebate rate of 27 0.189p to a proposed rebate rate of 0.405$ per kilowatt-hour. The FCA rate for the Non- 28 Residential Group (Schedules ll, 12,21,22,31 and 32) is proposed to change from a 29 presentsurchargerateofO.l9T$toaproposedrebaterateof0.034$perkilowatt-hour. The AVISTA'S ELECTRIC FCA ANNUAL RATE ADruSTMENT FILING PAGE 1 5 6 7 8 9 1 Residential Group rate change represents a$2.7 million, or 2.4o/o, decrease to Schedule 1 2 customers, and the Non-Residential group rate change represents a $2.4 million, or 2.5Yo 3 decrease. The combined effect of expiring FCA rates and the proposed 2022 rates are 4 shown on the table below. Expiring Present FCA Revenue Proposed FCA Revenue Proposed FCA Decrease Residential $ (2.368.18s)$ (s.074.681\$ Q.706.497\ Non-Residential $ 2.060.121 $(35s.5s4)$ (2,4r5,67s) The Company has requested an October 1,2022 effective date. The Company requests that this filing be processed under the Commission's Modified Procedure Rules (RP 201-204). Communications in reference to this Application should be addressed to: David J. Meyer, Esq. Vice President and Chief Counsel for Regulatory & Govemmental Affairs Avista Corporation P.O.Box3727 MSC-10 l4l1 E. Mission Ave Spokane, WA 99220-3727 Phone: (509)495-4316 David. Meyer@avistacorp. com Patrick Ehrbar Director of Regulatory Affairs Avista Utilities P.O.Box3727 MSC-27 1411 E. Mission Ave Spokane, WA 99220-3727 Phone: (509) 495-8620 patrick. ehrb ar @av istacorp. com l0 ll L2 13 t4 l5 l6 l7 l8 l9 20 2t 22 23 24 25 26 27 28 29 30 31 32 AVISTA'S ELECTRIC FCA ANNUAL RATE ADruSTMENT FILING PAGE 2 I II. BACKGROUND 2 The purpose of the electric FCA is to adjust the Company's Commission- 3 authorized revenues from kilowatt-hour ("kWh") sales, such that the Company's revenues 4 will be recognized based on the number of customers served under the applicable electric 5 service schedules. The FCA allows the Company to: l) deferthe difference between actual 6 FCA-related revenue received from customers through volumetric rates, and the FCA- 7 related revenue approved for recovery in the Company's last general rate case on a per- 8 customer basis; ard2) file a tariff to surcharge or rebate, by rate Broup, the total deferred 9 amount accumulated in the deferred revenue accounts for the prior January through l0 December time period. 11 In Case Nos. AW-E-15-05 and AW-G-15-01, the Commission in Order No. 12 33437 approved for Avista a Fixed Cost Adjustnent Mechanism. On page l0 of Order 13 No. 33437, the Commission stated: The parties have also agreed upon a three-yearr FCA pilot for electric and natural gas operations. The FCA will compare actual FCA revenues to allowed FCA revenues determined on a per-customer basis. Any differences will be deferred for a rebate or surcharge. There are a number of customer safeguards, including that an FCA surcharge cannot exceed a 3o/o anrnal rate adjustnent. Any unrecovered balances will be carried forward to recover in future years. Furttrer, there is no limit to the level of the FCA rebate. As part of the Stipulation, Staffand other interested parties, will review the efficacy of the FCA after its second fulIyear to ensure it is functioning as intended. Fixed cost adjustnent mechanisms are intended to encourage conservation and allow customers more control over their bills. Further, the proposed FCA will remove any financial disincentive of the Company to encourage energy conservation. Section 13 of the Stipulation and Settlement, as amended by Addendum to the Stipulation On June 15, 2018, the Idaho Public Utilities Commission approved an Addendum to the Stipulation which extended the term of the pilot for an additional year by OrderNo. 34085. t4 15 t6 t7 18 t9 20 2I 22 23 24 25 26 27 AVISTA'S ELECTRIC FCA ANNUAL RATE ADruSTMENT FILING PAGE 3 4 5 6 7 8 9 10ll t2 l3 t4 15 l6 t7 18 t9 20 2t 22 23 24 25 26 27 28 29 30 3l 32 33 34 35 I approved by the Commission in Order No. 34085 on June 15, 2018, provided further 2 details, reproduced below, regarding the mechanics of the fixed cost adjustrnent 3 mechanism. A. FCA Mechanisms Term. The Parties agree to an initial FCA terrn of 4 years, with a review of how the mechanisms have functioned conducted by Avista, Staff, and other interested parties following the end of the third full year. Avista may seek to extend the term of the mechanism prior to its expiration. 2 B. Rate Groups. There will be two rate groups established for both the electric FCA and natural gas FCA: Electric Customer Rate Groups:l. Residential - Schedule I2. Commercial - Schedules 11, 12,21,22,31,32 Natural Gas Rate Groups:1. Residential - Schedule 1012. Commercial - Schedules I l1 and ll2 C. Existing Customers and New Customers. The Parties have agreed that revenue related to certain items discussed below would not be included in the FCA for new customers. The result is that the Fixed Cost Adjustment Reve,nue-Per-Customer for new customers will be less than the Fixed Cost Adjustment Revenue-Per- Customer for existing customers. For new electric customers added after the test period, recovery of incremental revenue related to fixed production and hansmission costs would be excluded from the electric FCA. For new natural gas customers added after the test period, recovery of incremental revenue related to fixed production and underground storage facility costs would be excluded. These modifications are included in Appendices B and C to the Stipulation. D. Quarterly Reporting. Avista will file, within 45 days of the end of each quarter, a report detailing the FCA activity by month.3 The reporting will also include information related to the deferrals by rate group, what the deferrals would have been if tracked by rate schedule, use and revenue-per-customer for existing and new customers, and other summary financial information. Avista will provide such Review of the mechanisms took place at a workshop March27,2019, and the Company filed a sepaxate application with the Commission which extended the term of the FCA Mechanisms through March 31, 2025. See also discussion starting at page 6 of this application. As stated in Order No. 34502 Case No. AVU-E-19-06, the Company altered its quarterly reporting from 45 days to 60 days from the end ofeach quarter. AVISTA'S ELECTRIC FCA ANNUAL RATE ADruSTMENT FILING PAGE 4 1 2 3 4 5 6 7 8 9 10 11 L2 13 t4 l5 t6 t7 18 t9 20 2l 22 23 24 25 26 27 28 29 30 3l 32 33 34 35 36 37 38 39 40 4t other information as may be reasonably requested, from time to time, in the funre quarterly reports. E. Annual Filings. On or before July 1, the Company will file a proposed rate adjustnent surcharge or rebate based on the amount of deferred revenue recorded for the prior January through December time period.a The rate adjustment would be calculated separately for each Rate Group, with the applicable surcharge or rebate recovered from each group on a uniform cents per kWh or per therm basis. The proposed tariff (Schedule 75 for electric, Schedule 175 for natural gas) included with that filing would include a rate adjustment that recovers/rebates the appropriate deferred revenue amount over a twelve-month period effective on October I for electric (to match with Power Cost Adjustnent and Residential Exchange annual rate adjustments time period) and November lst for natural gas (to match with the annual Purchased Gas Cost Adjustnent rate adjustment time period). The deferred revenue arnount approved for recovery or rebate would be transferred to a balancing account and the revenue surcharged or rebated during the period would reduce the deferred revenue in the balancing account. After determining the amount of deferred revenue that can be recovered through a surcharge (or refunded through a rebate) by Rate Group, the proposed rates under Schedules 75 and 175 would be determined by dividing the deferred revenue to be recovered by Rate Group by the estimated kWh sales (Electric FCA) or therm sales (Natural Gas FCA) for each Rate Group during the twelve-month recovery period. Any deferred revenue remaining in the balancing account at the end of the amortization period would be added to the new revenue deferrals to determine the amount of the proposed surcharge/rebate for the following year. F. lnterest. Interest will be accrued on the unamortized balance in the FCA balancing accounts at the Customer Deposit Rate. G. Accounting. Avista will record the deferral in account 186 - Miscellaneous Deferred Debits. The amount approved for recovery or rebate would then be transferred into a Regulatory Asset or Regulatory Liability account for amortization. On the income statement, the Company would record both the deferred revenue and the amortization of the deferred revenue through Account 456 (Other Electric Revenue), or Account 495 (Other Gas Revenue), in separate sub- accounts. The Company would file quarterly reports with the Commission showing pertinent information regarding the status of the current deferral. This report would include a spreadsheet showing the monthly revenue deferral calculation for each month of the deferral period (January - December), as well as the curre,rt and historical monthly balance in the deferral account. As stated in Order No. 34502 Case No. AVU-E-19-06, The company altered the deferral period of its FCA extension to July through June by using a one-time l8-month deferral period of January l, 2020 through June 30, 2021. See also discussion starting at page 6 ofthis application. 4 AVISTA'S ELECTRIC FCA ANNUAL RATE ADruSTMENT FILING PAGE 5 1 2 3 4 5 6 7 8 9 H. 3% Rate lncrease Cap. An FCA surcharge, by rate group, cannot exceed a 3%o annual rate adjustment, and any unrecovered balances will be carried forward to future years for recovery. There is no limit to the level of the FCA rebate. III. DRIVERS OF ELECTRIC FCA DEFERRALS The FCA rebate deferrals for residential customers for 12 months ended June 30, 2022were the result of higher monthly use-per-customer than the use-per-customer that was embedded in the20l9 test year (i.e., the FCA base). Residential average monthly use- per-customer was higher by 45 kwhs. The FCA rebate deferrals for non-residential customers for 12 months ended June 30, 2022 werc the result of slightly lower monthly use-per-customer than the use-per-customer that was embedded in the 2019 test year (i.e., the FCA base). Non-residential average monthly use-per-customer was lower by 29 kWhs. The Company has identified the primary drivers for the change in use-per-customer. First, weather was colder than normal for 12 months ended June 30, 2022, fluctuating with offsetting impacts from heating and cooling throughout the period, giving rise to a weather normalization adjustments that required 20.5 million less kWhs to residential usage (15 kWhs per customer) and required 8.6 million less kWhs (27 kWhs per customer) to non-residential usage. The estimated FCA revenue surplus associated with weather was approximately $ 1 .3 million residential and a surplus of $0.4 million non- residential. Since the 2019 test year used to set 2021 rates,Idaho customers have achieved energy efficiency savings from participation in the Company's Demand Side Management programs. Estimated cumulative savings since the test year (derived from the Idaho 2019, The 2021 weather normalization adjustment was included in the Company's WA Commission Basis Filing and the same process was applied to year-to-date Jrurrre 2022. 10 11 t2 13 t4 15 r6 l7 l8 t9 20 2l 22 23 24 AVISTA'S ELECTRIC FCA ANNUAL RATE ADruSTMENT FILING PAGE 6 I 2020 arrd202l DSM Annual Reports) reduced residential usage for 12 months ended June 2 30,2022 approximately 16 million kWhs and non-residential usage approximately 46 3 million kWhs. The estimated FCA revenue shortfall associated with energy efficiency 4 programmatic savings is $0.1 million residential and $0.3 million non-residential. 5 The "other" drivers are related to items not easily quantifiable, such as the effects 6 of non-programmatic energy efficiency, changes in business cycles, etc. The following 7 table summarizes the impact of these drivers on the FCA Revenues received from 8 customersin202l. 9 Non-Residential Use/Cust FCA Revenue TV. RESIDENTIAL GROTIP RATE DETERMINATION The Company recorded $5,039,128 in the rebate direction in deferred revenue for the electric residential customer group for 12 months ended June 30, 2022. The proposed rate of 0.405 cents per kWh is designed to rebate $5,074,681 to the Company's residential electric customers served under rate Schedule l. The following table summarizes the components of the Company's request for rebate: Driver Residential Use/Cust FCA Revenue ro!91 Weather Energy Efficielc.y Other 45 15 55,1 sl,9. (So.11 Sg.s32 (2el 28 (20) (37) So.z So.+ (So.a1 So.r l0 ll t2 13 t4 l5 t6 t7 l8 t9 AVISTA'S ELECTRIC FCA ANNUAL RATE ADruSTMENT FILING PAGE 7 I 2 3 4 07.2021 - 06.2022 Deferred Revenue ($5.039.128) Add: Prior Year Residual Balance $28,019 Add: lnterest throueh 913012023 ($35.731) Add: Revenue Related Expense Adi ($27.841) Total for Recovery ($5.074.681) Customer Rebate Revenue ($s.074.681) Carryover Deferred Revenue $0 5 Exhibit B, page I shows the derivation of the proposed rate to rebate revenue of 6 $5,074,681 based on projected sales volumes for Schedule 1 customers during the 7 rebatelamortizationperiod (October2022 through September2023). As identified ontariff 8 Sheet 75B under Step 7 of "Calculation of Monthly FCA Deferral", interest on the deferred 9 balance accrues at the Customer Deposit Interest Rate.6 If the proposed rebate is approved 10 by the Commission, the 12 months ended June 30, 2022 deferral balance, plus interest 1l through September, and any outstanding balance approved for recovery in the prior year 12 FCA rate filing will be transferred into a regulatory liability balancing account. The 13 balance in the account will be reduced each month by the revenue collected under the tariff. t4 15 V. NON.RESIDENTIAL GROTIP RATE DETERMINATION 16 The Company recorded $226,046 in the rebate direction in deferred revenue for the 17 electric Non-Residential Group for 1.2 months ended June 30, 2022. The proposed rebate 18 rate of 0.034 cents per kWh is designed to recover $335,554 from commercial and 19 industrial customers served under rate Schedules ll,12,21,22,31, and 32. The following 20 table summarizes the components of the Company's request for recovery: 2t The Customer Deposit Interest Rate was 1.00% beginning January 2021. T}ire current rate of 1.00% has been used as an estimate for purposes of this rate determination. 6 AVISTA'S ELECTRIC FCA ANNUAL RATE ADruSTMENT FILING PAGE 8 I 2 3 4 5 07.2021 - 06.2022 Deferred Revenue (s226.046\ Add: Prior Year Residual Balance (s108.817) Add: Interest throueh 913012023 ($2.313) Add: Revenue Related Expense Adi.s1.621 Total for Recovery ($335.ss4) Customer Rebate Revenue ($33s.ss4) Carryover Deferred Revenue $0 6 Exhibit B, page 3 shows the derivation of the proposed Rebate rate to return revenue 7 of $335,554 based on projected sales volumes for Schedules 11, 12, 21, 22, 31, and 32 8 during the surchargelamortization period (October 2022 tlvoagh September 2023). As 9 identified on tariff Sheet 758 under Step 7 of "Calculation of Monthly FCA Deferral", 10 interest on the deferred balance accrues at the Customer Deposit Interest Rate. If the 11 proposed surcharge is approved by the Commission, the deferral balance, plus interest 12 through September, will be transferred into the regulatory asset balancing account. The 13 balance in the account will be reduced each month by the revenue collected under the tariff. 14 Support showing the monthly calculation of the defenal balances for both the 15 Residential and Non-Residential Groups is provided as Exhibit C. These calculations were L6 also provided to the Commission in quarterly reports (except April through June which will l7 be provided in the Q2 report by the end of August). l8 19 \rI. 3% ANNUAL RATE INCREASE TEST 20 FCA rate adjustrnent surcharges are subject to a3o/o annual rate increase limitation. 2l There is no limit to rebate rate adjustnents, therefore the reversal of any rebate rate is not 22 included in the incremental surcharge test. As described in tariff Schedule 75 (see First 23 Revision Sheet 75C), the3o/o annual rate increase limitation will be determined by dividing AVISTA'S ELECTRIC FCA ANNUAL RATE ADruSTMENT FILING PAGE 9 I the incremental annual revenue to be collected (proposed surcharge revenue less present 2 surcharge revenue) under this Schedule by the total "normalized" revenue for the two Rate 3 Groups for the most recent January through December time period. Nomralized revenue 4 is determinedby multiplying the weather-corrected usage forthe period by the present rates 5 in effect. If the incremental amount of the proposed surcharge exceeds 3%o, only a 3o/o 6 incremental rate increase will be proposed, and any remaining deferred balance will be 7 carried over to the following year. 8 Exhibit B, page 6 shows the 3% test for the two rate groups. The incremental 9 change from the existing rebate to the proposed rebate for the residential group is a decrease l0 of $2.7 million or approximately 2.4%o. For the Non-Residential group, the incremental l1 change from the existing surcharge to the proposed rebate is a decrease of $2.4 million or 12 approximately 2.5o/o. As the Residential deferral incremental change is a decrease and the 13 Non-Residential deferral incremental change is also a decrease for 12 months ended June 14 30,2022 there is no proposed carry over for either rate class. l5 16 VII. EXSTING CUSTOMERS AND I\IEW CUSTOMERS 17 The mechanism approved by the Commission requires that electric customers that 18 have been added since the test year are subject to an FCA Revenue-Per-Customer that 19 excludes incremental revenue related to fixed production and transmission costs. Separate 20 calculations for new versus existing customers are clearly identified in the FCA base that 2l was approved in Order No. 34499 for rates effective since December 1,2019. 22 Due to this segregation" Avista tracks the usage of new customers since January 1, AVISTA'S ELECTRIC FCA ANNUAL RATE ADruSTMENT FILING PAGE 10 I 2019 as compared with existing customers.T In general, the average usage of new 2 customers is lower compared to the average usage of existing customers. Avista has found 3 that new customer meters, on average, have less usage in the first six to 12 months after 4 meter installation, then generally see increases in their usage until their usage is more in 5 line with the average usage of existing customers after 12 months of service. This is due, 6 in part, to the lag that occurs between when a meter is installed and billing commences, 7 and when a customer moves into the premises. Avista will continue to tack the usage of 8 new customers over the Fixed Cost Adjustment term. 9 IO VIII. PROPOSED RATES TO BE EFFECTIVE OCTOBER 1.2022 1l The Company is proposing a per kilowatt-hour FCA rebate rate of 0.405(, for the t2 Residential Group, and a per kilowatt-hour FCA rebate rate of 0.0340 for the Non- 13 Residential Group, both to become effective October 1,2022. Exhibit B to this Application 14 provides the Residential and Non-Residential Rate Calculation, and Exhibit C provides the l5 support for the deferrals for the July 1, 2021 through June 30,2022 deferral period. Exhibit 16 A is a copy of the proposed tariff, Schedule 75, which contains the proposed FCA rates. 17 Exhibit A also includes the proposed changes to Schedule 75 in strike/underline format. l8 Residential customers using an average of 892 kilowatt-hours per month would see 19 their monthly bills decrease from $86.29 to $84.36, a decrease of $ 1.93 per month, or 2.2o/o. "Existing customers" were part of the test year used to set the December 1, 2019 rates (201 8 calendar year). 'New customers" consist of all new hookups after the test year. 7 AVISTA'S ELECTRIC FCA ANNUAL RATE ADruSTMENT FILING PAGE 1I I IX. COMMUNICATIONS AI\D SERVICE OF APPLICATION 2 In conformance with RP 125, this Application will be brought to the attention of 3 the Company's customers. First, the Company has served a copy of this Application upon 4 the service list in Case Nos. AVU-E-15-05 and AVU-G-15-01, the cases that gave rise to 5 the FCA mechanisms. Second, a copy of Company's news release and customer notice is 6 provided as Attachment D. The news release will be issued in July, and the customer notice 7 will be inserted in customer bills starting in August and will run for a full billing cycle. 8 9 X. REOUEST FOR RELTEF l0 The Company requests that the Commission issue an order approving FCA 1l deferrals for the period July l, 2021 through June 30, 2022 and approve a per kilowatt- 12 hour FCA rebate rate of 0.405( for the Residential Group, and a per kilowatt-hour FCA 13 rebate rate of 0.03 4( for the Non-Residential Group, both to become effective October 1, 14 2022. The Company also requests that the Commission approve the proposed tariff 15 modifications to tariff Sheet 75. The Residential Group rebate represents a$2.7 million, 16 or 2.4Yo, decrease to Schedule I customers, and the Non-Residential group rebate results 17 in a$2.4 million, or 2.5o/o, decrease. The Company requests that the matter be processed l8 under the Commission's Modified Procedure rules through use of written comments. 19 Dated at Spokane, Washington this 29th day of Jdy 2022. 20 AVISTA CORPORATION BY /s/ Patrick Ehrbar Patrick D. Ehrbar Director of Regulatory Affairs 2t 22 23 24 AVTSTA'S ELECTRIC FCA ANNUAL RATE ADruSTMENT FILING PAGE 12 CERTIFICATE OF SERVICE I HEREBY CERTIFY that I have this 296 day of hiy, 2022, served the Application of Avista Corporation - Fixed Cost Rate Adjustment, upon the following parties, by mailing a copy thereof, properly addressed with postage prepaid to: Jan Noriyuki, Secretary Idaho Public Utilities Commission I l33l W. Chinden Blvd Bldg 8 Suite 201-A Boise,lD 837L4 i an.norivuki(Dpuc. idaho. gov Peter J. Richardson Greg M. Adams Richardson Adams 515 N.27ft Street PO Box 7218 Boise, ID 83702 peter@richardsonadams.com gres@ri chardsonsdams. com Karl Klein Brandon Karpen Deputy Attorneys General Idaho Public Utilities Commission 472W. Washington Boise,ID 83702-0659 karl.klein@puc.idaho. sov Brandon.karpen@puc.idaho. gov Marv Lewallen 28530 SW Canyon Creek Rd. - South Wilsonville, OR 97070 marv@malewallen.com Larry A. Crowley The Energy Strategies Institute, Inc. 5549 S. Cliffsedge Ave Boise,ID 83716 crowleyla@aol.com Wendy Wilson Clean Energy Program Director Snake River Alliance 223 N 6th Street, Suite 317 Boise, ID 83702 wwilson@snakeriveralliance.ors Dean J. Miller, Lawyer 36208. Warm Springs Boise,ID 83716 deanimiller@cableone.net Benjamin J. Otto Idaho Conservation League 710 N. 6th St. Boise, ID 83702 bo tto (g) i d ahoc ons ervati on. ore Dr. Don Reading 6070 Hill Road Boise,ID 83703 dreadin e(dmindspri n s. com /s/ Patrick Ehrbar Patrick Ehrbar Director of Regulatory Affairs