20040426Post Hearing Brief.pdf

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Brad M. Purdy
Attorney at Law
Bar No. 3472
2019 N. 17th St.
Boise, ID. 83702
[phone]
FAX: [phone]
bmpurdy(?Yhotmail,com
Attorney for Petitioner
Community Action Partnership
Association ofIdaho and
American Association of
Retired Persons.
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
IDAHO POWER COMPANY FOR AUTHORITY)
TO INCREASE ITS INTERIM AND BASE
RATES AND CHARGES FOR ELECTRIC SERVICE
CASE NO. IPC-O3-
POST-HEARING BRIEF
OF COMMUNITY ACTION
PARTNERSHIP ASSOCIATION
AND AARP
INTRODUCTION
The Community Action Partnership Association of Idaho (CAP AI) and the AARP
(collectively referred to herein as the "public interest" parties) hereby submit their post-
hearing brief per the Commission s verbal ruling following the conclusion ofthe
technical hearing in this matter on AprilS , 2004.
II.IDAHO POWER'S LOW-INCOME CUSTOMERS
NEED FOR ASSISTANCE
CAP AI, through the testimonies ofTeri Ottens and Ken Robinette, presented
substantiated evidence that there exist a sizeable number ofIdaho Power customers who
meet the defmition of "low-income" as that term is defined by the state ofIdaho and the
CAPAI AND AARP POST-HEARING BRIEF
S. Government. By default, those customers fall within the Company s "residential"
class. No party to this proceeding challenged CAP AI's evidence regarding the disparity
between the need for and availability of low-income resources that currently exist within
Idaho Power s service territory.
CAP AI and AARP acknowledge that this Commission s primary mandate, and its
legal authority, does not involve addressing the needs ofIdaho s low-income citizens.
Yet, the public interest parties strongly believe that the Commission indeed has the legal
authority to take into consideration the unique needs of this sector of our citizenry in
reaching a decision on the issues raised in this proceeding, and to implement specific
measures that pertain to the consumption and pricing of electricity in a manner that will
assist Idaho Power s low-income customers.
Though lumped in with all other residential customers, the Company
impoverished customers have unique needs and characteristics that are often overlooked.
Idaho Power does not dispute that it makes little, if any, attempt to even derIDe the term
low-income customers " let alone collect and analyze data for those customers
distinguish them in any way, and shape its revenue allocation and rate design proposals
accordingly. Tr. P. 3050, lines 4-15-22 (Brilz Rebuttal cross). Nor does the Company
attempt to ascertain the electricity usage characteristics oflow-income customers. Tr. P.
3052, lines 23-25 through p. 3053, lines1-5 (Brilz Rebuttal cross).
Certainly, the Company is aware that such customers exist and the public interest
parties are not suggesting that Idaho Power is unsympathetic to their plight. "Project
Share" and the various payment options offered by the Company are evidence of its
recognition of poverty. But these resources barely make a dent in the problem. The
CAP AI AND AARP POST-HEARING BRIEF
criticism that the public interest parties respectfully levy against the Company is its lack
of understanding ofthe various characteristics oflow-income customers. Armed with
such information, the Company could do far more to improve the lives ofthese customers
while simultaneously providing benefits to its shareholders and other customers as
described below.
Low-Income Weatherization Assistance Program ("LIW
The Commission authorized the implementation of this program, and the
accumulated deferral of expenditures by Idaho Power, to begin in 1989 at funding levels
of $320 000 in Case No. IPC-89-6. As confIrmed by Idaho Power witness Susan
Fullen, over the years, funding levels have actually decreased to $212 000. Tr. P. 3112
lines 5- 7 (Rebuttal cross). In the 89-6 case, Idaho Power actually proposed increasing
LIW A funding to $500 000 annually starting in 1991, after two years of program
operation.
The Idaho Citizens' Network, the proponent ofLIWA at the time, sought higher
levels of funding. In response, the Commission stated in Order No. 22478 that: "If the
need arises in the future, we hope that Idaho Power s funding for this program would
increase." The Commission ruled that for the time being, "we find that the proposed
funding levels are a reasonable an acceptable beginning (Emphasis added). Suffice it
to say, LIW A somehow fell through the cracks and the original intentions of everyone
regarding the program have not come to :/Tuition.
As pointed out in the testimony of Ken Robinette, there have been several
changes to LIW A over the years, some good and some bad. Because funding levels have
decreased over 15 years, however, LIW A has not kept up with inflation, let alone the
CAPAI AND AARP POST-HEARING BRIEF
increase in the number oflow-income Idaho Power customers in need of housing
weatherization. Adjusting the original $320 000 authorized in 1989 for inflation yields
an annual amount of $483 61 0.1 This, coincidentally, is almost the same amount of
funding ($500 000) that Idaho Power suggested in the 89-6 case would be provided by
the year 1991.
Idaho Power agrees that LIW A is unique in that it is the Company s only low-
income exclusive DSM program. Tr. P. 3109, lines 21-25 through p. 3110, lines (Sue
Fullen, rebuttal). In fact, it is currently Idaho Power s only Idaho-specific DSM program
that is not a pilot. The public interest parties support the Company s involvement in
market transformation efforts such as those undertaken by the Northwest Energy
Efficiency Alliance, but the value of a DSM program whose monies and resources are
directly applied to Idaho Power customers to significantly reduce their consumption,
particularly during seasonal peaks, cannot be overemphasized.
And though other DSM measures currently funded by the Company are essential
to developing a diversified resource portfolio, their benefit to low-income customers is
somewhat attenuated. Also, the poor typically cannot avail themselves of measures that
reduce their electricity consumption and, therefore, bills. As Idaho Power Vice-President
John R. Gale put it in responding to how the poor could best reduce their energy bills: "
think that an increase in LIW A funding that would make sense after we worked through
the increase would be a -- I could see that as a good impact for the low income
customers, yes.Tr. P. 3189 lines (Rebuttal).
Throughout the hearing, Idaho Power witnesses repeatedly acknowledged the
importance and value ofLIW A. Several Company witnesses conceded that absent
1 Based upon U.S. Bureau of Labor Statistics inflation imJex.
CAP AI AND AARP POST-HEARING BRIEF
LIW A, low-income customers generally have less ability to reduce their energy
consumption. Tr. P. 3189, lines 12 (John R. Gale, Rebuttal).
LIW A is not a subsidy. As Mr. Gale testified, not only does LIW A provide
system-wide benefits in the form of reduced consumption and, thus, the avoidance of
marginally priced resources, it also results in the reduction of uncollectible accounts and
arrearages. Tr. P. 3190, lines 18 (Rebuttal). These "costs" resulting from customers
who cannot timely pay their bills also carry with them associated overhead in the form of
Company personnel time, among other things. Again, these facts were established at
hearing and have not been challenged.
CAP AI has proposed what it believes to be a reasonable request to increase
funding ofLIW A from roughly $212 000 to $1.2 million. This proposed increase is not
excessive, particularly when one takes into account that the original funding level was set
by the Commission at $320 000 15 years ago, was anticipated to increase to at least
$500 000, and has actually decreased from original levels by roughly 33%. As Mr.
Robinette and Ms. Ottens testified, there is an enormous backlog of qualified LIW
recipients.
In recent years, this Commission has ordered Idaho Power to start investing in
DSM once again. The result has been, among other things, the creation ofthe Energy
Efficiency Advisory Group ("EEAG") and the approval of a DSM tariff rider. But
these highly worthy accomplishments occurred, LIW A funding decreased while the need
for the program increased. None ofIdaho Power s other DSM investments directly
address low-income needs.
CAP AI AND AARP POST-HEARING BRIEF
It is undisputed that Idaho Power s residential customer base has increased
considerably since LIWA was fIrst implemented, and so has the number of low-income
customers in need of weatherization. The public interest parties point out that they have
been largely unrepresented in proceedings before this Commission over the better part of
the past decade. They are oflimited means and resources. As Mr. Robinette testified
CAP AI has attempted over the years through negotiations with the Company to increase
LIW A funding, without success. Had the matter been brought to the Commission
attention in past proceedings, it is entirely possible that the Commission would have
ordered an increase, at least to the levels originally authorized in 1989 and perhaps to the
$500 000 proposed by Idaho Power. In any event, a decrease ofLIW A funding over 15
years in spite of increased need for the program has created a large deficiency that
deserves attention.
During the hearing, the possibility of "rolling" LIW A into the EEAG process was
raised. While the public interest parties agree that any reasonable opportunity should be
explored, this idea did raise some concerns. As Nancy Hirsch testified, the monies
collected through the Company s current DSM rider are fully appropriated. Idaho Power
witness Susan Fullen acknowledged this. Tr. P. 3115 lines 20-25 through page 3116,
lines (Rebuttal cross). Even though current LIW A funding is woefully inadequate, at
least it's relatively certain. Under current circumstances , therefore, passing LIW A
through the EEAG process, without conditions attached dedicating a specified funding
level, would most likely result in the elimination of the program.
There are other practical concerns with rolling LIW A into the EEAG process. As
outlined above, LIW A is a low-income specific program with system-wide benefits that
CAP AI AND AARP POST-HEARING BRIEF
extend beyond those associated with all other DSM programs (i., reduction of bad debt
and arrearages). The issues revolving around poverty are complicated ones involving a
level of sophistication and policy that the public interest parties assert is more appropriate
for separate treatment by the Commission.
For its part, Idaho Power has agreed to consider the possibility of increasing
LIW A funding, but at unspecified amounts, in an unspecified process, at some
unspecified point in the future. This too, raises practical concerns. Without at least
strong encouragement, if not a direct Order, from the Commission, Idaho Power
generally does not implement new DSM or increase funding levels for existing programs
of its own volition. It is possible that the decoupling proposal made by NWEC will
remove the lack of incentive the Company has to encourage customers not to use
electricity, but working through the details of such a complicated process will not occur
overnight.
The public interest parties note that during cross examination, Idaho Power
witness Susan Fullen testified that the LIW A program manager was recently reassigned.
The Company also conceded that there are two or more vacancies on the DSM staff.
This lack of staffmg causes the public interest parties concern regarding how vigorously
and effectively Idaho Power will pursue an increase in LIW A funding.
CAP AI was the only party to comment on LIW A funding. Idaho Power had the
opportunity to counter-propose different funding levels, different structuring of the
program design, administrative cost payment, etc. The Company s only response
however, was to vaguely suggest that LIW A be dealt with at some other time, in some
other manner. CAP AI put considerable effort into its proposal and an issue of
CAPAI AND AARP POST-HEARING BRIEF
importance to the Company and its ratepayers and respectfully submits that it deserves a
more meaningful response from the Company and ruling from the Commission.
Because this is a general rate proceeding, the public interest parties believe this to
be an appropriate opportunity to seek an increase in LIW A funding so that the Company
is authorized to include the increase in rates. If the decision regarding LIW A is deferred
then the Company has a strong disincentive to incur expenditures that it might not
recover. This could lead to deferring any LIW A increase request to some distant point
the future when the Company makes some other filing affecting rates and rolls the LIW
increase into that case.
In conclusion, the public interest parties urge the Commission to order Idaho
Power to increase its funding ofLIW A to the $1.2 million annual level requested and to
order Idaho Power to fund up to 100% of project costs rather than 50% as it currently
does. At an absolute minimum, the Company should be ordered to restore funding levels
to $320 000 consistent with this Commission s original Order.
It is also requested that Idaho Power pay administration costs to CAP AI of $150
per project, as opposed to current level of$75, as testified to by Mr. Robinette.
Additional arguments in support of increasing LIW A funding are contained in Section IV
ofthis brief pertaining to the long-standing irrigation subsidy.
In the event the Commission does not require Idaho Power to increase LIW A
funding at this time, the public interest parties request that, at the very least, the
Commission include appropriate language in its Order authorizing the Company to
accumulate in a deferred account, any increase in LIW A expenditures that the Company
CAP AI AND AARP POST-HEARING BRIEF
might subsequently agree to, up to a minimum of $500 000 as originally anticipated 15
years ago.
The public interest agencies also request that the Commission order Idaho Power
to begin tracking the usage characteristics of low-income customers. This could be done
by, fIrst, adopting a definition of "low-income." Then, the Company could attempt to
determine the level of usage, nature of usage and types of housing stock (and relative
energy efficiency rating) of low-income customers. This effort would be of value to the
Company and Commission in addressing low-income needs. It would also assist CAP
in implementing LIW A.
III.MONTHLY CUSTOMER MINIMUM CHARGE
Idaho Power s "cost-based approach" to rate design is the theoretical economic
basis for its proposal to more than triple its fIXed monthly customer charge.The
Company s rationale is that this approach better aligns fIXed costs with fixed prices and
variable costs with variable prices.
Dr. Power testified on behalf of AARP that there is no economic principle that
indicates that fixed costs should necessarily be collected in fixed charges. He pointed out
that all businesses have fixed costs, but most do not try to cover them with fixed charges.
As Dr. Power points out in his testimony, there is no logical stopping point to the
Company s economic rationale. The fixed costs incurred in constructing generation and
transmission facilities, as well as all other fIXed costs including a portion of overhead, are
no less necessary than the costs of distribution in terms of providing service to the
customer. Idaho Power declared that its economic principle would, arguably, allow it to
recover all fIXed distribution costs in a fIXed monthly charge resulting in a monthly
CAP AI AND AARP POST-HEARING BRIEF
charge near the $30 mark.But, again, there is no logic for stopping with fIXed
distribution costs. They are no more or less "customer" related charges than transmission
and generation costs.
Ultimately, the Company could recover the bulk of its fIXed costs through a fixed
monthly charge. Aside from resulting in an extraordinary fIXed charge, this "all you can
eat" tariff would completely remove all incentive for customers to conserve energy. The
nexus between the level of their consumption and their bill would be so disconnected as
to be meaningless.
This Commission has also rejected the use of class contributions to a single
annual peak as the basis for allocating the fIXed costs that are classified as capacity costs.
Rather than loads at a single hour on a single day dictating the allocation of capacity
costs, a weighted average of the twelve monthly coincident peaks is used. In addition, for
most customers, it is the peak usage during each month that determines the demand
charges that are due, not peak usage at one hour during the year. Both ofthese decisions
by the Commission turn the demand allocation and charges into a type of usage charge as
opposed to a fixed charge.
Customer costs are costs that vary primarily with the number of customers served.
Stated differently, they are costs that could be avoided if a customer ceased taking
service. That is the cost causal principle behind customer costs. That definition is parallel
to energy costs that focus on the costs associated with expanding the energy-producing
capacity of the system or demand costs that focus on expanding the capacity ofthe
system to meet peak loads.
If demand costs cannot be billed directly to residential customers because demand
CAP AI AND AARP POST-HEARING BRIEF
meters are not cost-effective for loads that small, there is no logic to concluding that the
obvious way to collect those demand costs is through a customer charge.
Dr. Power points out that the Company s approach has no economic logic to it
since it ignores cost causality and focuses merely on whether a cost is fIXed or varies in
the short term with usage. The reason that the fIXed costs were incurred in the first place
simply gets ignored. Such an approach is not a cost of service approach since cost
causality is largely ignored.
In addition to the flaws in Idaho Power s economic rationale for the proposed
increase to the fixed monthly charge, it would constitute a substantial impact to low-
income customers.
There seems to be little dispute that the more costs Idaho Power recovers through
a fIXed charge, the greater certainty of revenue recovery the Company has and, thus, the
less risk. The uncertainty of revenue recovery for Idaho Power is primarily due to
changes in weather conditions. But the Company has already been significantly insulated
from this variable through the PCA. Adding to that a fixed monthly charge further locks
in the Company s revenues.
The public interest parties point out that when Idaho Power seeks a given return
on equity, implicit in its ROE calculation and proposal is business risk. As stated, the
PCA already removes much of the weather-related risk that Idaho Power faces. It is no
wonder that the Company wants to recover as much of its costs as possible through a
fIXed charge. But, as a matter of public policy, this is not in the best interests of the
Company s ratepayers.
CAP AI AND AARP POST -HEARING BRIEF
The public interest parties urge the Commission to reject this additional layer of
insulation that will not only have an undue impact on low-income customers but will
discourage conservation. Allowing Idaho Power to recover a portion of fIXed distribution
costs through a fIXed charge will no doubt be followed by a request to include all fIXed
distribution costs, followed by fIXed transmission, generation and overhead costs. As
proposed by Dr. Power, the public interest parties propose increasing the fixed residential
charge only to $3.00 per month, primarily to account for the effects of inflation since the
time the charge was first set.
IV.IRRIGATION SUBSIDY
This issue is raised each time Idaho Power files a general rate case. While cost
service analyses are undeniably an art as well as a science, and while the avoidance of
rate shock is one goal of raternaking, those two arguments have, unfortunately seemed to
serve as the only reason that Idaho Power s irrigation class has paid rates so considerably
below what they should be. In spite of the subjectivity inherent in cost of service models
they still are the foundation for revenue allocation. They have been the basis for revenue
allocation for more than twenty years. And it is undisputed that the model adopted and
relied upon by the Commission, and the various runs performed by the Company and
Staff, have consistently shown over more than two decades that the irrigators' rates are
substantially below their appropriate levels.
Suffice it to say, that the millions of dollars per year in irrigation subsidy, could
be spent to weatherize many low-income homes with the associated system-wide
benefits. There is no system-wide benefit resulting from the irrigation subsidy.
CAPAI AND AARP POST-HEARING BRIEF
When this Commission sets rates, it relies solely upon the cost of service model as
a starting point, and then takes into account policy objectives such as rate shock. As set
forth below, the Idaho Supreme Court has explicitly recognized cost of service as a basis
for setting rates, but not the concept of rate shock. In any event, every revenue allocation
decision made by the Commission begins with, and is based in large part upon, cost of
service. And art or not, there is simply no justification for allowing a 67% subsidy to
continue. While the degree of the subsidy varies somewhat with each rate case, it is
always quite large. There comes a point when the results of these analyses are so
consistent that one must assume that, subjectivity notwithstanding, there is a truth being
revealed.
Regarding rate shock, the public interest parties pointed out during the hearing
that there is the equally important statutorily imposed objective of fairness and the
objective of recognizing the impact that revenue allocation has on not just irrigators, but
low-income customers as well. Low-income ratepayers receive a rate shock every month
when they pay an electric bill containing a 67% subsidy for one select customer class.
The poor would certainly welcome such a subsidy.
During the hearing, the irrigators pointed out the disproportionate effect that a rate
increase can have on customers within their diverse class. During cross-examination,
Idaho Power witness Gale conceded that a rate increase to the residential class can have
the same disproportionate effect. Tr. P. 3193 lines 10-19 (Rebuttal). Idaho Power makes
no effort to identify and distinguish low-income customers from other residential
customers. Because of their financial limitations, the poor have very little opportunity
CAP AI AND AARP POST-HEARING BRIEF
other than LIW A to reduce their consumption, such as the time-of-day irrigation DSM
program.
Unlike its proposed cap on the increase to the irrigation customers, no similar cap
was provided to the residential class. No special consideration was given to low-income
customers when Idaho Power proposed bringing the residential class to 105% of its cost
of service. This isn t possible when the Company doesn t even try to defme the term
low- income.
With all due respect, from a legal standpoint, there is simply no other way to
describe the subsidy than as "preferential ratemaking" in violation ofIdaho Code ~~ 61-
301 , 315 and 502 prohibiting rates that are unjust, unreasonable, discriminatory or
preferential. The irrigation subsidy has been so large for so many years, that to call it
anything other than preferential would be to deny reality.
In Homebuilders v. Washington Water Power, 107 Idaho 415, 690 P.2d 350
(1984), the Idaho Supreme Court held:
The authority ofthe Commission to fIX rates and charges, however
is not unbridled. A utility is forbidden to treat a customer
preferentially through its rates and charges, or to maintain
unreasonable differences in its rates and charges as between classes
of service. I.C. ~ 61-315 provide
107 Idaho at 419 (Emphasis added).
If a 67% difference in rates relative to cost of service is not unreasonable, it is
difficult to imagine the magnitude of difference that would be considered so. Even Idaho
Power s revenue allocation proposal will not eliminate this unreasonable difference.
According to Exhibit 61 , Idaho Power proposes bringing most classes to 105% of cost of
service while setting irrigators' rates at 75%, a difference of30%. The public interest
CAP AI AND AARP POST-HEARING BRIEF
parties submit that 30% is an unreasonable difference. To the same extent that cost of
service is inexact and reliance upon it carries the risk of setting irrigation rates too high,
the same argument applies to all other customer classes.
Incidentally, the Supreme Court noted in Homebuilders:
Any such difference (discrimination) in a utility s rates and charges
must be justified by a corresponding classification of customers that
is based upon factors such as cost of service quantity of electricity
used, differences in conditions of service, or the time, nature and
pattern of the use.
Id. at 421 (Emphasis added).
Thus, the Supreme Court has explicitly recognized cost of service as a basis for
setting rates. By contrast, the Supreme Court has never specifically endorsed the concept
of "rate shock avoidance" to justify unreasonable differences in rates.
The public interest parties appreciate the sensitive nature of this issue, and do not
make these comments lightly or in disrespect to the Commission or anyone else, but poor
people cannot afford to subsidize anyone. They struggle to provide the basic necessities
for themselves and their families. It is time for the irrigation subsidy to end.
Incidentally, the Company s assurances that there will be additional rate cases
and possible revenue allocation adjustments, filed in the next 5-8 years is little
consolation to the other customer classes. Idaho Power did not guarantee when it would
file its case, nor that there would be a cost of service study performed and relative change
in irrigation rates proposed. The Company could, as it did when it sought rate base
inclusion of its Milner and Swan Falls rebuilds, simply ask for a proportionate rate
increase after it completes its next generation facility, or completes the Hells Canyon
relicensing process, and then seeks to have the investment ratebased. Those customers
CAP AI AND AARP POST-HEARING BRIEF
paying the bill for the irrigators should not be expected to be content with such a lack of
assurance for the better part of another decade.
The Commission has recognized the problem and made attempts in past rate cases
to reduce the subsidy, tempered heavily by the desire to avoid rate shock. Unfortunately,
despite these earnest efforts, the subsidy has only grown. The public interest parties
believe that the time has come to take more drastic steps to eliminate it. They believe
that the proposal offered by Dr. Power is a fair and reasonable one. First, Dr. Power
assumes, for the purpose of his proposal, that cost of service studies are accurate only to
within a plus or minus 33% margin of error. This allows for considerable inaccuracy in
the model. Dr. Power does not propose bringing irrigation rates all the way to cost of
service, only to 33% below cost of service. This still allows a subsidy and addresses the
argument that cost of service studies are inherently subjective.
Second, Dr. Power proposes phasing-in the irrigation rate increase over five years
a substantial amount oftime. This addresses the rate shock argument. The Company and
Staff propose a much smaller increase, a strategy that, frankly, has resulted in an increase
in the subsidy between the present case and the 94-5 rate case. Other parties propose an
increase to irrigators' rates that would immediately bring them to 100% of cost of
service. The public interest parties submit that Dr. Power s proposal strikes a balance
but represents the minimum increase that should be ordered.
There appears to be the belief among certain members of the public that irrigators
are paying for growth in the residential class. This perception was pointed out during the
hearing. There was no evidence presented, however, to substantiate this belief. New
residential development pays for line extension costs under a specific tariff, just as do the
CAP AI AND AARP POST-HEARING BRIEF
kwh per month and, therefore, the majority ofthose customers will be given the right
price signal.
RESPECTFULL Y SUBMITTED, this 26th day of April, 2004.
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CAP AI AND AARP POST-HEARING BRIEF
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT, I HAVE THIS 26th DAY OF APRIL, 2004
SERVED THE FOREGOING POST-HEARING BRIEF OF COMMUNITY ACTION
PARTNERSHIP AND AARP, IN CASE NO. IPC-03-, BY MAILING A COpy
THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
Barton L. Kline
Monica B. Moen
Idaho Power Company
O. Box 70
Boise, ID. 83707
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John R. Gale
Idaho Power Company
O. Box 70
Boise, ID. 83707
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Lisa Nordstrom
Deputy Attorney General
Idaho Public Utilities Commission
472 W. Washington St.
Boise, ID. 83702
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Peter J. Richardson
Richardson & O'Leary
99 East State Street, Suite 200
O. Box 1849
Eagle, ID. 83616
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Don Reading
Ben Johnson Associates
6070 Hill Rd.
Boise, ID. 83703
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Randall C. Budge
Racine, Olson, Nye, Budge & Bailey
201 E. Center
Pocatello, ID. 83204
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Anthony Yanke I
29814 Lake Road
Bay Village, OH. 44140
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CAP AI AND AARP POST-HEARING BRIEF
Lawrence A. Gollomp
1000 Independence Ave., SW
Washington, D.C. 20585
Dennis Goins
Potomac Management Group
5801 Westchester St.
Alexandria, VA 22310-1149
Dean J. Miller
O. Box 2564
Boise, ID. 83701
Jeremiah J. Healey
O. Box 190420
Boise, ID. 83719-0420
William M. Eddie
O. Box 1612
Boise, ID. 83701
Nancy Hirsch
219 First Ave. South, Suite 100
Seattle, W A. 98104
Conley E. Ward
601 W. Bannock St.
Boise, ID. 83702
Dennis Pesau
1500 Liberty St., Suite 250
Salem, OR. 97302
Michael L. Kurtz
Kurt J. Boehm
Boehm, Kurtz & Lowry
36 E. Seventh St., Suite 2110
CAPAI AND AARP POST-HEARING BRIEF
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Cincinnati, OH 45202
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Brad M. Purdy
'-..-)
CAPAI AND AARP POST-HEARING BRIEF