20041229Final Order No 29669 on Remand.pdf

Office of the Secretary
Service Date
December 29, 2004
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)
ORDER NO. 29669
In June 2004, the Idaho Supreme Court issued its amended remittitur in Idaho
Power Company v. Idaho PUC 140 Idaho 139, 90 P.3d 889 (2004). In its opinion, the Supreme
Court set aside the Commission s decision in Order Nos. 28992 and 29103 denying Idaho
Power s request to recover the "lost revenue" associated with the Company s implementation of
the Irrigation Load Reduction Program in 2001. Lost revenue represents a calculated amount of
revenue the Company might have received from the sale of power to irrigation customers if the
Load Reduction Program had not been in operation. In overturning the Commission s Orders
the Court concluded that the "question left to be resolved at the end of the program was a
determination of how those lost revenues would be computed.Id.140 Idaho at 142, 90 P .3d at
892.
On October 15,. 2004, the Commission issued a Notice of Modified Procedure
soliciting additional comments from the parties and interested persons regarding the calculation
of the lost revenue. The Commission received timely comments from eight members of the
public, the Commission Staff, the Irrigation Pumpers Association, and the Industrial Customers
of Idaho Power. On November 19, 2004, Idaho Power filed reply comments. In this Order, the
Commission authorizes an amount for the Company to recover as a result of the Supreme
Court's decision. This will be included in the 2005 Power Cost Adjustment (PCA) case.
BACKGROUND
A. The Irrigation Load Reduction Program
During 2000-2001 Idaho Power purchased large amounts of high-cost power to meet
its load requirements. In an effort to reduce electric consumption and the purchase of high-
priced wholesale power, the Company initiated several load reduction programs, one of which
was the Irrigation Load Reduction Program Case No. IPC-01-3. This program provided
ORDER NO. 29669
monetary incentives to large irrigation customers who could reduce their energy consumption by
at least 100 000 kWh during the summer of 2001. In April 2002, the Commission issued Order
No. 28992 authorizing Idaho Power to recover nearly $74 million in payments made to
participating irrigation customers for reducing their energy consumption. However, the
Commission denied the Company s request to recover approximately $12 million of "lost
revenue" ($11 587 179 plus $428 008 in carrying charges up to March 31 , 2002). Because
recovery of the lost revenue was denied, the Commission did not address the Company
proposed methodology used to calculate the lost revenue. The Supreme Court's decision makes
it necessary for us to do so now.
B. The Proposed Lost Revenue Methodology
Idaho Power s proposed methodology for calculating the lost revenue has three
components. The Company s witness Maggie Brilz identified the three parts as: (1) the energy
component; (2) the demand component; and (3) the PCA load reduction offset component. The
Company s methodology has remained constant since the Company requested recovery of lost
revenue. Ms. Brilz provided a more detailed description of the three components.
First, the energy component represents the reduction in revenue associated with the
kilowatt-hours (kWh) bid into the Irrigation Load Reduction Program. The energy component is
calculated by multiplying the kWh of reduced or conserved energy by the tariffed energy rate
applicable for the specific billing period. Brilz at 5. Second, the demand component is the
reduced revenue associated with the reduction in billed kW relating to the monthly irrigation
season bills of June through September 2001. This is the period during which the irrigation
demand charge is imposed. "Because the billed kW is directly related to the installed
horsepower at each metered service point, the basis for the computation is the difference between
the billed kW for the billing period this year ((2001)) compared to the billed kW for the same
billing period last year ((2000)).Id. at 5-6. The demand component is then computed by
multiplying the difference in billed kW between the two years by the demand charge of $3.
per kW.
Third, the load reduction offset component eliminates a potential double accounting
of reduced revenues associated with the load change that is embedded in the PCA methodology.
At the time, the rate for load change adjustment within the PCA was 1.684 cents per kWh. This
component also includes an adjustment for the delivery loss factor for energy sales to irrigation
ORDER NO. 29669
customers taking power at the secondary voltage level. This delivery loss is calculated at the
generation level rather than at the customer, or meter level. The Company utilized a loss factor
of 10.8%. Id. at 6-7. Taken together, the load reduction offset component is calculated by
multiplying the kWh of energy reduction for which customers received payment by 1.108 (to
adjust for the 10.8% loss), and then by 1.684 cents per kWh to fully reverse the load change
adjustment incorporated in the PCA mechanism. Ms. Brilz s Exhibit 2 shows the calculation of
each component for the example month of August 2001.
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 10% to account
for the 90/1 sharing adjustment incorporated in the PCA. In addition, the jurisdictional
allocation process further reduced the calculated amount by 15% to allocate costs to Oregon
customers. Id. at 12-13.
In March 2002 the Company filed its calculations for lost revenue following
completion of the Load Reduction Program that concluded in October 2001. U sing its three-part
methodology, Idaho Power calculated that its lost revenue totaled $11 587 179. The Company
applied carrying charges at 6% interest through March 31 , 2002 resulting in carrying charges of
$428 008. Thus, the Company sought to recover $12 015 187 ($11 587 179 plus $428 008) in
lost revenue from customers through the 2002 PCA mechanism. In April 2002, the Commission
issued Order No. 28992 denying recovery of lost revenue. On reconsideration the Commission
affirmed its decision to deny recovery of the lost revenue. Idaho Power subsequently appealed to
the Idaho Supreme Court.
C. The Motion to Stay on Appeal and the Carrying Charges
Contemporaneously with its appeal, the Company filed a Motion to Stay with the
Commission. In its Motion, Idaho Power expressed concern that without staying the
Commission s Orders , the Company might be precluded from later recovering the disputed
amount of lost revenue if it were to prevail on appeal. The Company also noted that it had
ceased accruing any carrying charges on the lost revenue amounts as of March 31 , 2002. The
Company did not seek the immediate recovery of lost revenue but stated it would seek recovery
of such revenue should it prevail.
In response to the Company s Motion to Stay, the Commission issued Order No.
29143. In that Order, the Commission noted that because Idaho Power does not "propose to
ORDER NO. 29669
accumulate any additional carrying charges during the pendency of the appeal " the Commission
found that a stay was not necessary. Order No. 29143 at 6.
RECENT COMMENTS
1. Public Comments. As previously mentioned, the Commission received comments
from eight members of the public. Seven comments simply opposed recovery of any lost
revenue. Most of those opposing recovery suggested that Idaho Power should absorb the loss of
the revenues. The remaining comment simply asked the Commission to "ensure the $12 million
is a legitimate figure.
Industrial Customers. of Idaho Power (ICIP)ICIP recognized that the
Commission "is mandated in this case to allow" recovery of lost revenue. ICIP Comments at
However, ICIP argued that allowing the Company to recover its lost revenue "would essentially
place the entire burden of the energy crisis (the ten percent PCA share notwithstanding) on the
backs of Idaho Power s ratepayers.Id. at 2. ICIP suggested that the lost revenue associated
with the Irrigation Buy-Back Program should be discounted "to take into account the fact that the
Company incurred no costs associated with the purported lost revenue amount of approximately
$12 million.Id.
3. Commission Staff.After reviewing the Company s methodology, the Staff
concurred that the three-part formula is the appropriate method to calculate lost revenue. The
Staff also noted that the current calculation of lost revenue and the carrying charge "
approximately 60% of that proposed by the Company in its original filing.Staff Comments at
5. The Staff maintained that the Irrigation Load Reduction Program was different than
traditional DSM programs because the actual energy savings are known and measurable, and
occurred in a single year at a set price. Staff calculated the amount of lost revenue that should be
recovered from Idaho ratepayers to be $11 587 179 - the same amount requested by Idaho
Power. Id.
Staff also confirmed that the appropriate carrying charge attributed to the program up
until March 31, 2002 should be $428 008. However, Staff maintained "carrying charges are not
appropriate for the period beyond March 2002 during the pendency of the appeal (April 1 , 2002
to May 31 , 2004).Id. at 6. The Staff argued the Company previously waived these carrying
charges when it stopped accruing carrying charges during the appeal.
ORDER NO. 29669
4. Idaho Irrigation Pumpers Association. The Irrigators noted they have supported
the recovery of "some level of lost revenues in this case" only because the reduced energy levels
were quantifiable and isolated in a single program. Irrigators Comments at 2. The Irrigators
suggested the Commission make three adjustments to the Company s calculations, which would
result in a lost revenue amount of $6 058 249 (computed without carrying charge). The three
adjustments are discussed in greater detail below.
First, the Irrigators recommend that the Commission make a jurisdictional adjustment
to remove Idaho Power s Oregon and Prairie Power operations. More specifically, the Irrigators
assert "Prairie Power was a separate jurisdiction of Idaho Power." Thus, the Commission should
delete the energy and demand components associated with these two areas from the calculation
of lost revenue. Id. at 1. The Irrigators proposed an adjustment of$639 597. Id. at 8.
Second, the Irrigators maintained that Idaho Power should have calculated the
demand component averaged over a number of years instead of using the difference between
calendar years 2000 and 2001. They asserted just looking at the previous year s billed demand
would not necessarily be reflective of any year in the future " especially when "irrigation usage
varies widely from year to year.Id. They suggested the Commission should use a five-year
average. Using a five-year average, the Irrigators estimated that the irrigation demand in the
year 2000 was 180/0 higher than the average over the past five years. Id. at 3. Accordingly, the
Irrigators ' demand adjustment would reduce lost revenues by $481 691.
Third, the Irrigators take issue with the PCA elements of the Company s energy
component. They maintained that Idaho Power s energy component consists of three sub-
components. The sub-component and the associated prices are:
Cents/kWh
8416
3861
9554
1831
Basic Tariff Rate
PCA Forecast Rate
PCA True-Up Rate
Total Tariff Rate
The Irrigators assert that only the basic tariff rate is appropriate for inclusion in the energy
component of the lost revenue calculation. Id. at 5.
The Irrigators stated there are three reasons why the PCA forecast rate should not be
considered as a component of lost revenue. First, they insisted the PCA forecast rate is reflective
of "anticipated" power supply costs. The second and third reasons apply both to the PCA
ORDER NO. 29669
forecast rate and to the PCA true-up rate. They argued it is inappropriate to estimate lost revenue
by using the PCA forecast and true-up rates because these PCA rate elements would go to the
Company s bottom line "and not as an off-set to the Company s PCA cost as the PCA forecast
rate and PCA true-up rate are designed to do.Id. at 6-
The Irrigators also insisted that the Company s workpapers reflect that a substantial
amount of load was actually served above the "normalized load" used to calculate the PCA
forecast rate. "Thus, in spite of the significant reductions of load by the Irrigation Buy-Back
Program, the Company is still going to collect far more PCA Forecast Rate (and true-up rate)
revenue during the irrigation season than what can be anticipated to be recorded under
normalized loads . . . (and) to balance out the previous year s costs.Id. at 6
In summary, the Irrigators calculate that the appropriate amount of lost revenue to be
recovered is $6 058 249, without carrying charges. They did not address carrying charges
beyond March 2002.
IDAHO POWER'S REPLY COMMENTS
The Company submitted its reply comments on November 19 , 2004.The
Company s reply comments addressed the comments raised by the Staff, the Industrial
Customers of Idaho Power (ICIP) and the Irrigators. In reply to the ICIP comments, the
Company asserts that ICIP provided "no analysis or substantive comments" on the calculation of
lost revenues. Reply Comments at 15.
1. Reply to the Staff.While Idaho Power recognized that the Staff is in agreement
with recovery of the calculated amount of lost revenue and the carrying charges through March
2002, the Company also asserted that it is entitled to receive carrying charges at 6% in the
amount of $1 506 333 for the period April 1 , 2002 through May 31 , 2004 (during the appeal). In
addition, the Company requested carrying charges in the amount of $695 230 for the period of
June 1 , 2004 through May 31 , 2005 (June 1 , 2005 being the date that the 2005 PCA rates go into
effect). Idaho Power Reply Comments at 6, 16.
Idaho Power maintained that Staff misconstrued the Company s statement that it was
no longer calculating interest during the pendency of the appeal to mean that Idaho Power agreed
to forego interest during the period even if the Company was successful on its appeal. Id. at 6-
The Company stated the reason it discontinued the booking of the carrying charges was to
comply with financial accounting requirements. Idaho Power insisted that not allowing the
ORDER NO. 29669
Company to recover the carrying charges during the pendency of the appeal would, in effect
penalize the Company for appealing the Commission Orders that were eventually set aside by the
Court. Id. at 7.
2. Reply to the Irrigators Idaho Power takes issue with the Irrigators ' three
adjustments. The Company objected to the Irrigators' proposal to use a five-year average to
calculate the demand component. Idaho Power maintained that unlike energy usage, irrigation
demand is not weather sensitive. "If an irrigation pump is operative 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." Reply Comments
at 9.
Idaho Power also pointed out that the demand component of the Company s three-part
methodology is not based on irrigation class data. The Company stated that the RFPs issued to
irrigation customers in February 2001 was used to compute the base consumption amount for
each customer unless there was a change in pumping horsepower. Id. at 10. The Company
insisted that the five-year average "would cause a mismatch between the data used to calculate
the base energy usage and the data used to the calculate the demand component." Id. The
Company s methodology calculated the demand component "on a customer-by-customer
month-by-month, and service point-by-service point basis. The Company s methodology,
. .
closely ties the calculation of the revenue impact with the actual behavior of each customer
participating in the voluntary Irrigation Load Reduction Program.Id. at 11. In essence, using a
five-year average would understate the amount of reduced revenue that would be recovered
through the PCA.
Idaho Power next asserted removing the PCA forecast and true-up elements of the
energy component is inappropriate and unreasonable. Idaho Power maintained the PCA
components are an integral part of the Commission approved energy rate included in the
Company s Tariff Schedule 24 and effective during the 2001 irrigation season. Id. The
Company characterized the Irrigators ' PCA adjustments as "less certain" than the base rates. Id.
at 12. However, Idaho Power insisted the Irrigators have again failed to note that the Company
calculation of lost revenue is based upon the actual data of participating irrigators and not the
entire irrigation class. Id. at 12-13.
ORDER NO. 29669
Idaho Power argued the PCA forecast and true-up components must be included in
the energy component. Idaho Power maintained that 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(sJ." Id. at 13 (emphasis
added). Idaho Power recognized the PCA forecast rate "may overstate or understate power
supply costs thus the need for a true-up" component. Id. at 13.
Idaho Power next addressed the Irrigators' observation that loads grew in spite of the
Irrigation Load Reduction Program. Idaho Power argued that changes in load are accounted for
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.Id. at 4. The Company
asserted the Irrigators made the same error on both the forecast and true-up components of the
PCA. Thus, Idaho Power urged the Commission to reject the Irrigators' PCA adjustments to the
energy component.
In summary, Idaho Power urges the Commission to award it lost revenue in the
amount of $11 587 179. In addition, the Company seeks recovery of the carrying charges at 6%
from April 1 , 2002 to May 31 , 2005 totaling another $2 629 571. If the Commission decides that
further proceedings are necessary, then the Company requests, at a minimum, that the
Commission award it the undisputed amount suggested by the Irrigators of $6 058 249 plus
carrying charges. The Company suggests that the Commission set a hearing to address the
amounts in dispute if it is unable to award the Company its total request. Reply Comments at
16-17. The table below summarizes Idaho Power s request.
Calculated Amount of Lost Revenue
Carrying charges to 3/02 (6%)
Carrying charges 4/02 to 6/04 (6%)
Carrying charges 6/04 to 6/05 (6%)
Total Request
$11 587 179
$ 428 008
$ 1 506 333
695.230
$14 216 750
DISCUSSION AND FINDINGS
Pursuant to the Supreme Court's opinion, the remaining question for the Commission
is the computation of the lost revenues. Idaho Power proposed using a three part methodology to
calculate the lost revenues associated with the Irrigation Load Reduction Program. In its
ORDER NO. 29669
comments Staff reiterated its belief that the proposed methodology "is reasonable and appears to
capture all the relevant costs and cost offsets associated with the program.Staff Comments at
5. The Irrigators do not oppose the use of proposed methodology, but recommend three
adjustments. Based upon this apparent agreement and our review of the methodology, we find
that the proposed methodology is a reasonable and fair mechanism to calculate lost revenue.
Staff noted, the methodology should allow Idaho Power to recover its relevant cost on a revenue
neutral basis. We next address the three adjustments recommended by the Irrigators.
1. The Jurisdictional Adiustment.The Irrigators first proposed an adjustment of
$639 597 to the Company s calculation of lost revenue. We find the proposed adjustment is
redundant, especially as it relates to the Oregon jurisdiction. As adopted, the lost revenue
methodology recognizes the allocation between the Oregon and Idaho jurisdictions. This 15%
adjustment for the Oregon jurisdiction is reflected in both the Company and Irrigators
calculations. In addition, the Irrigators did not explain the Prairie Power adjustment. In Order
No. 24398, the Commission authorized Idaho Power to purchase the assets of Prairie Power
Cooperative in 1992. The former Prairie Power customers were (at the time) a small load and
are now incorporated into the general rate schedules. Former Prairie Power customers will pay
2005 PCA rates. Consequently, we are not persuaded that this jurisdictional adjustment is
appropriate.
2. The Demand Component.Instead of simply comparing the demand between the
participants in their 2001 irrigation season to their 2000 billed kW, the Irrigators proposed that
the Company use a demand component averaged over five years (from 1996 to 2000) based upon
consumption for the entire class of irrigators. Using the five-year average would reduce the
Company s lost revenue by $481 691.
We decline to adopt the Irrigators demand adjustment. The proposed demand
calculation was based upon those service points actually participating in the Irrigation Load
Reduction Program rather than the entire class of irrigators. Reply Comments at 9. Rather than
using the five-year average, we find that comparing the participants demand in 2001 with their
demand data for the 2000 irrigation season is a better gauge of irrigation demand for those
participating in the program. We find the Company s proposal of computing the demand
component based upon a participating customer-by-customer, month-by-month, and service
ORDER NO. 29669
point-by-service point basis to be more appropriate. Consequently, we decline to adopt the
Irrigators demand component adjustment.
3. The PCA Adiustments. The Irrigators' final adjustment concerns the energy
component. The energy rate used by the Company and Staff to compute the lost revenue was
183 cents per kW. This was the three element, in-season irrigation rate for May through
September 2001. The Irrigators' adjustment would remove the two PCA rate elements (totaling
1.3415 cents/kWh) and would only use the basic tariff rate when calculating the lost revenue
attributable to the energy component.
The Irrigators arguments against recovery of the PCA elements can generally be
characterized in two ways. First, the PCA forecast and true-up rates are calculated based upon
normalized load. Actual revenues collected has little relationship to recovery of actual power
supply costs incurred. With or without a buy-back program there is no true up of the true-up, the
Company simply keeps the revenues it receives. Second, by including the two PCA elements
the Company will over-collect these PCA revenues and this additional revenue will simply be a
windfall to the Company.Based upon our review we are not persuaded that this PCA
adjustment is fair or reasonable.
The Irrigators contend that if the PCA elements are not removed, then the Company
will recover more revenue than it anticipated from its PCA forecast rate and more than it was
entitled to from its PCA true-up rate. However, we find that this is not the case. In particular
the Company s methodology uses a 1999 level of energy consumption to calculate the PCA true-
up rate rather than the normalized level of consumption calculated in the 1993 rate case. The
difference between using the 1993 and the 1999 data results in a true-up deficit rather than a
true-up windfall. Consequently, we reject the Irrigators' adjustment to eliminate the true-up rate.
The same can be said for recovery of the 2001 forecast power supply costs. While
the PCA forecast rate in 2001 generated more revenue than the Company anticipated, the
Company ultimately failed to recover 2001 power supply costs once 2002 true-up revenue was
combined with the 2001 forecast revenue. We find there is no windfall by including the PCA
forecast rate. Idaho Power is not over-compensated with respect to power supply cost recovery
and was in a greater deficit situation than it otherwise would have been because of the Irrigation
Load Reduction Program. Consequently, we do not adopt the PCA adjustment. We find it
ORDER NO. 29669
reasonable to allow recovery of lost revenue associated with the PCA forecast and PCA true-up
elements of the energy rate as calculated by the Company and supported by the Staff.
Having rejected the Irrigators' adjustments we find the Company is entitled to
recover its lost revenue in the amount of$11 587 179 as proposed by the Company and agreed to
by the Staff.
4. The Carrying Charge We next turn to the interest rate for the carrying charge. It
appears undisputed that Idaho Power is entitled to carrying charges calculated at 6% up to March
, 2002. The Company and the Staff agree that this results in a carrying charge up to that time
of$428 008. We concur with these calculations and find that the Company should be allowed to
recover $428 008 in carrying charges at 6% until March 31 , 2002.
The Staff and the Company disagree whether the Company should recover carrying
charges during the pendency of the appeal, from April 1 , 2002 through May 31 , 2004. The
Company argued that it should be allowed to recover carrying charges in the amount of
506 333 at 6% during the appeal period. Reply Comments at 16. The Staff did not address
the period from the remittitur to the 2005 PCA effective date.
Based upon our review of the comments and our prior Orders, we find it reasonable
for Idaho Power to recover carrying charges during the pendency of the appeal and up to the time
that it will begin to recover its lost revenue in the 2005 PCA year. The Supreme Court set aside
our Orders and awarded the Company lost revenue. It would be unreasonable and inappropriate
to deny the Company carrying charges for that period of time.
Although we find that the Company is entitled to carrying charges from April 1 , 2002
through May 31 , 2005, we find that Idaho Power has used the wrong rate to calculate the
carrying charges. Typically, the carrying charges are applied to deferral accounts that are
normally recovered the following year, e., the PCA mechanism. In this case, Idaho Power
proposes to recover its lost revenue and carrying charges in the 2005 PCA case. In Order No.
24806, the Commission noted that carrying charges for the PCA are based upon the utility
customer deposit rate found in the Commission s Customer Relations Rule 106 IDAPA
31.21.01.106. Although the deposit rate for calendar year 2001 was 6% interest, the rate
decreased in subsequent years.
While we recognize that the carrying charges have decreased since 2001 , we also
recognize the Company has not been able to recover its lost revenue. Balancing the decline in
ORDER NO. 29669
carrying charges with the longer period before recovery, we find that the appropriate interest rate
for the carrying charges given the unique facts of this case should be 4%. Consequently, we find
that it is appropriate for the Company to recover carrying charges at 4% from April 1 , 2002
through May 31 , 2005 in the amount of $1,467 695.
In summary, we adopt the Company s three-part methodology for calculating lost
revenue. We decline to accept the Irrigators proposed adjustments and the Staff s argument
regarding carrying charges. Consistent with the Court's decision, Idaho Power is authorized to
recover lost revenue and carrying charges as set out below:
Lost Revenue
Carrying Charge to 3/31/02 (6%)
Carrying Charge from 4/1/02 to 5/31/05 (4%)
TOT AL
$11 587 179
$ 428 008
$ 1.467.695
$13 482 882
ORDER
IT IS THEREFORE ORDERED that Idaho Power s Application to adopt its three-
part methodology to calculate lost revenue is granted.
IT IS FURTHER ORDERED that Idaho Power is authorized to recover lost revenue
in the amount of$13 482 882, including carrying charges as set out in greater detail above. This
amount shall be included in the Company s 2005 PCA case.
THIS IS A FINAL ORDER. Any person interested in this Order (or in issues finally
decided by this Order) or in interlocutory Orders previously issued in this Case No. IPC-01-
(On Remand) may petition for reconsideration within twenty-one (21) days of the service date of
this Order with regard to any matter decided in this Order or in interlocutory Orders previously
issued in this Case No. IPC-01-34 (On Remand). Within seven (7) days after any person has
petitioned for reconsideration, any other person may cross-petition for reconsideration. See
Idaho Code 9 61-626.
ORDER NO. 29669
DONE by Order of the Idaho Public Utilities Commission at Boise, Idaho this 9+-A.
day of December 2004.
JJ~
MARSHA H. SMITH, COMMISSIONER
DENNIS S. HANSEN, COMMISSIONER
ATTEST:
Co ission Secretary
bls/O:IPCEO 134 dh2
ORDER NO. 29669