20041119Reply Comments.pdf

LARRY D. RIPLEY ISB #965
Idaho Power Company
O. Box 70
Boise, Idaho 83707
Phone: [phone]
FAX: [phone]
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Attorney for Idaho Power Company
1221 West Idaho Street
Boise, Idaho 83702
BEFORE THE IDAHO PUBLIC UTiliTIES COMMISSION
IN THE MATTER OF THE REMAND
CONCERNING IDAHO POWER COMPANY'
REQUEST TO RECOVER "LOST REVENUE" )
FROM THE 2001 IRRIGATION LOAD
REDUCTION PROGRAM THROUGH THE
PCA MECHANISM IN THE 2004/2005 PCA YEAR.
CASE NO. IPC-01-
(ON REMAND)
RESPONSE OF IDAHO
POWER COMPANY TO
FILED COMMENTS
As provided by Order No. 29612 issued by the Commission On Remand
Idaho Power Company ("Idaho Power" or the "Company ) hereby replies to the comments
that were filed in response to the Commission s October 15 , 2004 Notice of Modified
Procedure. Comments were filed by the Commission Staff ("Staff"); Idaho Irrigation
Pumpers Association ("Irrigators ); and the Industrial Customers of Idaho Power
Industrial Customers
).
Each comment will be addressed separately and the Company
will then provide a brief summary.
RESPONSE OF IDAHO POWER COMPANY TO FILED COMMENTS , Page
COMMISSION'S NOTICE
Since the Commission s Notice of Modified Procedure ("Notice ) provides
the basis upon which the parties' comments were filed , it is appropriate to first address
the Commission s description of the Company s request contained in that Notice. The
Commission s Notice succinctly and accurately discusses the background leading up to
the implementation of the Irrigation Load Reduction Program. In the Notice, the
Commission solicited additional comments from the parties regarding the calculation of
the Company s lost revenues as a result of the implementation of the Irrigation Load
Reduction Program. The Commission s discussion of the Company s proposed
methodology for calculating lost revenue contained on pages 2 and 3 of the
Commission s Notice accurately and succinctly describes the Company s methodology.
Two points are of particular interest. First, as per Commission directive:
Idaho Power met with the parties in this case to discuss its proposed
methodology for computing the lost revenues. At this meeting, the Company outlined a
three-part methodology to calculate the lost revenue. Following this meeting, the
Company adjusted the proposed methodology. Order No. 28992 at 2.
(Order No. 29612 dated October 15, 2004, p. 2.
Second, the Commission s Notice , in describing the Company
methodology, stated:
After calculating the amount of lost revenue, two other adjustments were
made. Consistent with the PCA mechanism , the amount of lost revenue was reduced by
100/0 to account for the 90/10 sharing adjustment in the PCA. In addition, the
RESPONSE OF IDAHO POWER COMPANY TO FILED COMMENTS, Page 2
jurisdictional allocation process further reduced the calculated amount by 150/0 to allocate
costs to Oregon customers.
(Order No. 29612 dated October 15, 2004 , p. 3.
No party has contended that the Commission s description of the
methodology utilized by the Company to calculate lost revenue is inaccurate.
Accordingly, the Company submits that the Commission s Notice and the resulting
description of the Company s methodology in the Notice provides the basis on which to
review the comments of the parties.
COMMISSION STAFF'S COMMENTS
Staff Concurs In Company s Calculation of Lost Revenues
Staff's November 4 , 2004 comments provide a succinct description of the
Staff's review of the Company s methodology. The Staff's analysis of the Company
methodology and Staff's agreement with that methodology can best be described by
direct reference to the relevant sections of Staff's comments. Staff's analysis
underscores the fact that the methodology the Company used to calculate lost revenues
is correct and should be approved by the Commission. In its comments Staff stated:
In its Request for Authority to Accept Bids , Case No. IPC-01-, filed
with the Commission on March 7, 2001 , the Company proposed a lost revenue
component of 5.2 cents per purchased kWh or 1000/0 of the per kWh revenue that
would have been generated absent the buyback program. The Company stated
without inclusion of the reduced revenues in the PCA mechanism , the benefits derived
RESPONSE OF IDAHO POWER COMPANY TO FILED COMMENTS, Page 3
from the program are not evenly distributed and can become detriments to the
Company (Comments of Commission Staff dated November 4, 2004 , p. 4.
Later in its comments the Staff stated: "In comments filed on March 12
2001 , in Case No. IPC-01-, Staff stated that while it did not necessarily disagree
with the methodology used to estimate the relative impact of the program, it did not
agree with the Company s lost revenue proposal. Based on its calculations , Staff
agreed that allowing some lost revenue recovery would make the Company no worse
off with the Irrigation Load Reduction Program than it would have been without it. Staff
also stated that it believed there was uncertainty in measuring energy reduction due
solely to this Program. While Staff believed it difficult to quantify the effect on lost
revenues of factors such as 'free riders' (reduction in irrigation energy consumption that
would have occurred anyway) and offsetting new customer growth , it (sic Staff)
believed that these issues provided further justification for allowing only a portion of the
lost revenue to be recovered. Staff again stated 'proper recovery is an amount that
would make the Company revenue neutral'(Comments of Commission Staff dated
November 4, 2004, p. 4.
Commenting further, Staff stated: "On September 27 2001 , Idaho Power
met with the Commission Staff and other parties and interested individuals to discuss
the reduced revenue issue. Idaho Power presented a proposed lost revenue
calculation that included the recovery of energy and demand related revenues
associated with irrigation kWh's bought back. The Company reduced this initial
calculation by 1.684 cents/kWh to account for a credit already incorporated in the PCA
when actual energy sales are reduced. This prevents a double counting of this portion
RESPONSE OF IDAHO POWER COMPANY TO FILED COMMENTS, Page 4
of lost revenue. During the meeting the Company also agreed to reduce lost revenue
by the cost of losses that it does not incur when it buys energy back. Average delivery
losses are 10.8 percent of delivered energy for irrigation customers taking service at the
secondary voltage leveL" (Comments of Commission Staff dated November 4 , 2004
Staff went on to state: "In comments filed on November 30, 2001
supporting the modified lost revenue calculation, Staff stated:
It is Staff's position that these adjustments along with the 10
PCA sharing reduction in all of the costs of the program prevent
any "enrichment" to the Company as a result of proposed
Commission approval of lost revenue recovery. The 90/10
sharing adjustment also addresses, in a general way, concerns
that the Staff expressed about free riders in its previous
comments. The fact that 10 % of program costs will not be
passed back to ratepayers provides increased assurance that
free riders would not cause the program to be uneconomic
(Comments of Commission Staff dated November 4 , 2004, p. 5.
In conclusion, Staff stated: "Staff has again reviewed the various
adjustments incorporated in the calculation methodology and continues to believe that
the methodology developed through workshops and proposed by Company witness
Brilz is the appropriate method to calculate lost revenue. The calculated lost revenue
resulting from the methodology is approximately 600/0 of that proposed by the Company
in its original filing. The methodology includes adjustments for a PCA credit when
actual energy sales are reduced and reduced transmission losses associated with
reduced energy consumption. In addition , the revenue losses are jurisdictionally
allocated and shared by Idaho Power shareholders through the PCA assuring fair
treatment of customers and stockholders. However, Staff continues to maintain that the
RESPONSE OF IDAHO POWER COMPANY TO FILED COMMENTS, Page 5
Irrigation Load Reduction Program is different than traditional demand side
management (DSM) or conservation programs because the actual energy savings
associated with the program are discretely tied to actual kWh's purchased. In addition
the energy savings produced by this program occur in a single year at a set price based
upon the irrigation customer s bid. Because the energy reductions occur in a single
year, such reductions are not subject to a true-up as is the case with long-term energy
reductions associated with traditional DSM and conservation programs. See Staff
Comments at 4 (Nov. 30, 2001 ).(Comments of Commission Staff dated November 4
2004, p. 5.
Interest During Pendency of Appeal
While agreeing with the Company s calculation of lost revenue in the
amount of $11 587 179 and the calculation of interest in the amount of $428,008 through
March 2002, Staff's comments at that point clearly diverge from the Company s position
on interest cost recovery. Staff does not believe that carrying charges amounting to
506 3331 for the period April 2002 to June 2004 are appropriate. Staff bases that
belief on a misunderstanding of the Company s position. At the time the Company
requested an Order to assure recovery in the event of a successful appeal , the Company
stated that it was no longer calculating interest. The reason for this discontinuance was
due to the fact that under financial accounting requirements, the calculation of carrying
charges would not be appropriate because the Company did not have an order which
would authorize the booking of that interest. While the accounting rules required
discontinuance of the booking of interest, there should be no misunderstanding of the
All interest calculations contained in the Company s Comments have been computed at the rate of 6%.
RESPONSE OF IDAHO POWER COMPANY TO FILED COMMENTS, Page 6
Company s position. The Company did notwaive its right to recover carrying charges
during the pendency of the appeal if it were successful. Staff misconstrued the
Company s statement that it was no longer calculating interest during the pendency of the
appeal to mean it was agreeing to forego interest even if the Company was successful on
appeal. Staff, in effect, has imposed a penalty upon the Company for appealing the
Commission s order. During the pendency of this appeal before the Idaho Supreme
Court, Staff would, in effect, require that the Company finance the appeal in its entirety by
not permitting the recovery of any interest as the result of the remand by the Idaho
Supreme Court. The Company does not believe that Staff's position is fair or reasonable
and the Commission should allow the recovery of interest in the amount of $1 506 333
while this matter was pending on appeal.
In summary, Staff's recommendation (with the exception of the Staff'
disallowance of carrying charges in the amount of $1 506 333 for the period April 2002 to
June 2004) should be accepted by the Commission. Staff is the only party that has
conducted an in-depth investigation , complete with audit, as well as an in-depth analysis
of the Company s calculation of lost revenue.
IRRIGATORS' COMMENTS
Irrigators Ignore the Fact that the Amount of Load Reduction
Was Known At the Outset.
Before discussing the various points raised by the Irrigators in their
critique of the Company s methodology, it is important to point out a fatal flaw contained
in the Irrigators' comments as to the calculation of lost revenue. While apparently
recognizing that the Company s Irrigation Load Reduction Program was based on
RESPONSE OF IDAHO POWER COMPANY TO FILED COMMENTS, Page 7
individual contracts with particular identifiable customers , the Irrigators ignore the effect
of this important and critical fact upon the Company s calculation of lost revenue. Lost
in the Irrigators' critique is the fact that the Load Reduction Program was , for the 2001
irrigation season, based upon individual contracts with particular identifiable irrigators
under which the irrigators agreed to reduce their individual irrigation loads and such
reductions were quantified based upon the individual irrigator s power consumption in
the immediate past. This was not a reduction of power by the irrigation class per se
but reductions in power consumption as a result of individual agreements with identified
customers. The composite effect of those agreements gave rise to the pre-identified
load reduction that the Company, the Commission , and the Company s customers
(including the Irrigators) agreed would occur as a result of the Load Reduction Program.
The I rrigators' contention that the Company had no idea what effect the
Load Reduction Program would have on the Company s energy consumption is an
inaccurate portrayal of that Program. The Company s calculations of reduced electrical
consumption and resulting reduction in revenues were based on pre-identified contracts
with individual customers for the 2001 irrigation season. The Company s direct
payments (which had already been allowed by the Commission) were based upon the
irrigator-specific reductions which the Company used to calculate the Company s lost
revenue. The Irrigators in their comments critiquing the Company s methodology have
either forgotten this important element or seriously misunderstand the very basis upon
which the Company s lost revenue was calculated, i.e., the Company had separate
contracts with particular customers that specified the reduction in energy that the
customers participating in the Load Reduction Program would create. This was no.t a
RESPONSE OF IDAHO POWER COMPANY TO FILED COMMENTS , Page 8
Load Reduction Program based on unknown reductions of energy consumption for the
entire irrigation class as is implied in the Irrigators' comments.
Use of 2000 Demand Data To Compute Lost Revenue is
Correct
The Irrigators first object to the Company s use of 2000 demand data to
compute the lost revenue attributable to lost demand charges. The Irrigators claim if a
five-year average were used, the lost revenue attributable to demand charges would be
less. Since the five-year average is less than the 2000 amount, this is the
mathematical result. The Company receives less revenue. However, the procedure to
be utilized to compute lost revenue should not be the one that results in the lowest
amount, but should be a procedure that provides the most accurate calculation. As has
been previously pointed out in the Company s December 28, 2001 comments filed with
the Commission, first and foremost -- unlike energy usage , irrigation demand is not
weather sensitive. If an irrigation pump is operated for one hour during a month or 720
hours during a month , the peak demand will be the same; however, energy usage
would vary significantly. In the short run , demand has no correlation with energy.
As previously discussed , the Irrigators fail to appreciate the fact that the
demand component of the Company s calculation of lost revenue is no.t based on class
data. While the Company does not agree with the Irrigators' conclusions based on
class data, those disagreements do not need to be addressed as this is not an analysis
based on the irrigation class. For the majority of participants in the voluntary Irrigation
Load Reduction Program, the five-year average demand on a month-by-month basis will
be the same as the 2000 demand on a month-by-month basis simply due to the fact
that the peak demand for a pump is consistent from year to year. However, a five-year
RESPONSE OF IDAHO POWER COMPANY TO FILED COMMENTS , Page 9
average was not utilized to compute the base energy amount for all customers
participating in the Program. As detailed in the Request for Proposals issued to
irrigation customers on February 16, 2001 , the average kWh consumption at each
metered service point during the immediately preceding five years was used to compute
the base consumption amount for each customer unless a change in pumping
horsepower at a metered service point was demonstrated by the customer desiring to
participate in the Irrigation Load Reduction Program. The base energy amount for
customers participating in the Irrigation Load Reduction Program whose billing records
demonstrated a change in their pumping horsepower during the five-year historical
period was calculated using the energy consumption for the 2000 growing season or, at
the Company s discretion , the period of time consistent with the revised horsepower.
Again , in these situations , the average of the demand on a month-by-month basis over
the number of years used to compute the base energy amount would be the same as
the 2000 month-by-month demand; however, due to the increase in pumping
horsepower during the five-year period, a five-year average demand would be less than
the 2000 demand. Using a five-year average demand as urged by the Irrigators would
cause a mismatch between the data used to calculate the base energy usage and the
data used to calculate the demand component. Utilizing a five-year average to
calculate the demand component would not be consistent with the methodology used to
compute the base energy amount and would unfairly penalize the Company by
understating the amount of reduced revenue which could be recovered through the
PCA.
RESPONSE OF IDAHO POWER COMPANY TO FILED COMMENTS , Page 10
Second , the Irrigators assume that the energy and demand components
of irrigation usage are relatively proportional. As pointed out earlier in these comments
the amount of energy consumed relative to demand is highly affected by the weather.
Assuming that the percentage change in demand over a five-year period is equal to the
percentage change in energy consumption is unfounded. Likewise, making an
adjustment to the amount of reduced revenue based on this assumption is
unsupportable.
Finally, the adjustment suggested by the Irrigators is based upon an
inappropriate global approach to computing the reduced revenue demand component.
As detailed in the direct testimony of Ms. Brilz (Brilz, Tr. at p. 19, IPC-01-03; Brilz, Di.
at p. 5-, IPC-01-34), the Company has proposed computing the demand component
of reduced revenue on a customer-by-customer, month-by-month , and service point-by-
service point basis. The Company s methodology, unlike the methodology proposed by
the Irrigators , closely ties the calculation of the revenue impact with the actual behavior
of each customer participating in the voluntary Irrigation Load Reduction Program.
Essentially, the Irrigators' recommendation that the Commission use five
years of demand data rather than the year 2000 demand data is driven by a single
rationale, i.e., because it results in a lower revenue amount.
All "Energy" Revenues Must Be Included in the Lost Revenue
Calculation.
In their comments, the Irrigators correctly state that for the summer
months the energy rate used to compute lost revenues was 4.1831 cents per kilowatt-
hour. This value came directly from the Company s tariff Schedule 24 , Irrigation
Service effective energy rate for the 2001 irrigation season , which became effective
RESPONSE OF IDAHO POWER COMPANY TO FILED COMMENTS , Page
May 1 , 2001. The effective rate is the result of adding the base rate, 2.8416 cents per
kilowatt-hour, and the PCA rate of 1.3415 cents per kilowatt-hour. The base rate was
determined as part of a general rate case when irrigation rates were established to
provide for recovery of the Company s revenue requirement for that class under
normalized conditions, i.e. normal water, normal market prices , normal loads , etc. The
PCA rate was determined as part of a PCA rate case wherein the one-year change in
revenue requirement due to changes in variable power supply expenses incurred to
serve all customers but adjusted to normal load conditions is determined. The change
in revenue requirement by approved PCA methodology is spread to all classes on a
uniform cents per kilowatt-hour basis.
As separate components of the effective rate , both the base rate and the
PCA rate are in place to allow the Company to recover its revenue requirements (base
and PCA) from all of its customers , including the Irrigation class. The Irrigators
comments suggest that lost revenues associated with a general revenue requirement
are appropriate for recovery, but lost revenues associated with PCA revenue
requirement are not appropriate for recovery. The Irrigators have confused the issue by
attacking PCA methodologies that have been in place since 1992 , implying that the
PCA revenue requirement determined in 2001 was incorrect and therefore
inappropriate for use in determining lost revenues. They suggest that PCA revenue
requirement recovery is less certain than base revenue requirement recovery.
In reviewing the comments of the Irrigators as it applies to the energy
component, it must again be emphasized that the Company s calculation of lost
revenue is based upon individual contracts with particular identifiable irrigation
RESPONSE OF IDAHO POWER COMPANY TO FILED COMMENTS, Page
customers. When that important critical factor is taken into account when reviewing the
Irrigators' comments , it becomes apparent the Irrigators' calculation of lost revenue is
not correct. The Irrigators' comments assume the discussion should focus on the entire
irrigation class, not a precise, identifiable subset of the irrigation class. The Irrigators
comments are nothing more than a critique of the PCA rate methodology, not a critique
of Idaho Power s lost revenue calculations. As the Irrigators point out at Page 5 of their
comments: "Case No. IPC-01-34 , but is concerned
with the establishment of lost revenues.
The Forecast Portion of the PCA Must Be Included In the Lost
Revenue Calculation.
The Irrigators' contention that the forecast component should not be
included in the lost revenue calculation ignores the fact that the forecast of power
supply expenses was based upon the forecast of power supply expenses, not a
forecast of the power supply costs that a particular subset of the irrigation class would
cause. The Irrigators ignore the fact that had the irrigation customers that participated
in the Program consumed energy, they would have paid for that energy under a rate
which included the entire PCA component. The power supply costs that are actually
experienced are recognized in the true-up portion of the PCA. The PCA does not
identify individual or class cost-causers or cost-relievers. No distinction is made for any
class. During this period there was only one PCA rate that was in effect and applicable
to all customer classes. By focusing on the forecast, while ignoring it has always been
recognized the PCA forecast may overstate or understate power supply costs thus the
need for a true-up, the Irrigators have misstated the reason and methodology for
computing the PCA forecast.
RESPONSE OF IDAHO POWER COMPANY TO FILED COMMENTS , Page 13
The Irrigators also complain that the increased revenue will go to the
Company s bottom line. Obviously, if the utility is required to absorb all costs, then it
logically follows that if the utility is entitled to recover some of those costs , that recovery
will have a positive effect on the utility s "bottom line." What the Irrigators fail to
appreciate is that the revenues from the PCA forecast rate component are also
normalized as a reduction to the normalized PCA expenses. The Irrigators would
normalize power su~enses and reduce those normalized expenses but replace
the normalized revenues with a higher level. An obvious "heads I win, tails you lose
scenario to the detriment of Idaho Power.
Finally, the Irrigators point out that loads grew in spite of the significant
reductions of load by the Irrigation Load Reduction Program. The Irrigators again fail to
recognize that the PCA rate methodology does not identify cost-causers or cost-
relievers. The PCA rate is for the recovery of power supply expenses by a uniform rate
applicable to all customer classes. The changes in load are taken into account through
the normalization process. In that process, revenues from the PCA forecast rate
component are also normalized as a reduction to the normalized PCA expense, thus
maintaining a consistent approach to normalized revenues and normalized expenses.
The True-Up Portion of PCA Revenues Must Be Included In the
Lost Revenue Calculation.
While the above-stated arguments directly refute the Irrigators' comments
on the forecast portion of the PCA, they are equally applicable to the Irrigators
comments concerning the PCA true-up component. Simply put, the Irrigators make the
same error on both the forward-looking (forecast) and the backward-looking (true-up)
components of the PCA.
RESPONSE OF IDAHO POWER COMPANY TO FILED COMMENTS , Page 14
While the Irrigators' comments urging reductions in the lost revenue
calculation of Idaho Power must be rejected , their comments have provided a valuable
contribution to these proceedings. Their comments have required the Company to
provide additional clarification as to the Company s lost revenue calculations. While the
Company, as pointed out by Staff's comments, is only receiving a portion of its lost
revenue, providing assurance of this fact to the Company s customers is important.
The I rrigators' participation in this proceeding has supplied the catalyst by which this
additional assurance can be provided to the Company s customers.
INDUSTRIAL CUSTOMERS OF IDAHO POWER COMMENTS
Unlike Staff and the Irrigators, the Industrial Customers in their filing
provide no analysis or substantive comment on Idaho Power s calculation of lost
revenue. Despite their "general opposition" to recovery of lost revenues , the Industrial
Customers acknowledge that, by Supreme Court mandate, it is clear Idaho Power is to
be allowed such recovery in this proceeding. The Industrial Customers then present
under the heading "Close Scrutiny Required", vague , broad , unsupported conclusory
statements with no analysis or substantive comment and certainly no specific comment
as to Idaho Power s calculation of lost revenue as requested by the Commission in its
notice. The time for hyperbole is long past in this proceeding, and it is unfortunate the
Industrial Customers have chosen to file comments of this nature.
SUMMARY
Staff, as the result of an in-depth analysis, has agreed that Idaho Power
calculation of lost revenues in the amount of $11 587 179.04 and interest in the amount
RESPONSE OF IDAHO POWER COMPANY TO FILED COMMENTS, Page 15
of $428 008.18 through March 2002 is correct. Upon a thorough analysis and review of
the Irrigators' comments , the Irrigators have underscored the conclusion that the
Company s lost revenue calculation is correct. To that extent , the Irrigators have
provided a valuable contribution to this proceeding. The Industrial Customers, other
than acknowledging that Idaho Power is entitled to lost revenues in this proceeding,
have made no other meaningful comments. The Company continues to believe that it
is entitled to interest from the period April 1 , 2002 through May 31 , 2004, in the amount
of $1 506 333 contrary to Staff's position that no interest for that period should be
allowed. In addition , there would obviously be interest in the amount of $695,230 for
the period June 2004 through May 2005, the date that Idaho Power will begin to receive
back its lost revenues through the 2005 PCA.
ADDITIONAL HEARINGS
The only party requesting hearings in this matter was the Industrial
Customers , who provided no reason other than the desire to have additional hearings.
The Company believes that additional hearings are not required in order to allow the
Company to recover $11 ,587 179.04 in lost revenues and interest in the amount of
629,571.2 If the Commission does not believe it can allow a $11 587 179.
recovery based on the Irrigators' comments , then the Company requests that the
Idaho Power requests that the Commission issue its order determining the amount of lost revenue
prior to the end of 2004. As previously noted by the Commission in this proceeding in Order No.
29143 issued on November 6, 2002, the Company is required to follow General Accepted Accounting
Principles (GAAP) before the Company may report any recovery of lost revenues in its financial
statements. This requirement can only be satisfied by obtaining an appropriate order from the
Commission authorizing the recovery of lost revenues. If that order is not issued until 2005, the
Company will not be able to report any recovery in its financial statements until the year 2005.
RESPONSE OF IDAHO POWER COMPANY TO FILED COMMENTS, Page 16
Commission award the Company $6,058 249 (the Irrigators recommended amount)
with interest calculated on that allowance at six percent (60/0) and set for hearing the
additional amount in dispute between Staff and Idaho Power s calculation and the
Irrigators' calculation.
DATED at Boise, Idaho, this 19th day of November, 2004.
LARRY . RI PLEY
Attorney for Idaho Power Company
RESPONSE OF IDAHO POWER COMPANY TO FILED COMMENTS, Page 17
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 19th day of November, 2004, I served a
true and correct copy of the within and foregoing RESPONSE OF IDAHO POWER
COMPANY TO FILED COMMENTS upon the following named parties by the method
indicated below, and addressed to the following:
Donald L. Howell, II
Deputy Attorney General
Idaho Public Utilities Commission
472 W. Washington Street
O. Box 83720
Boise, Idaho 83720-0074
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Overnight Mail
FAX
Randall C. Budge
Racine, Olson , Nye, Budge & Bailey
O. Box 1391
201 E. Center
Pocatello, Idaho 83204-1391
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Anthony Yankel
29814 Lake Road
Bay Village, Ohio 44140
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Peter J. Richardson
Richardson & 0' Leary LLC
99 East State Street , Suite 200
P. O. Box 1849
Eagle , ID 83616
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CERTIFICATE OF SERVICE