20040423Post Hearing Brief.pdf

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Randall C. Budge, ISB No. 1949
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHARTERED
O. Box 1391; 201 E. Center
Pocatello , Idaho 83204-1391
Telephone: [phone]
Fax: [phone]
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Attorneys for Intervenor
Idaho Irrigation Pumpers Association, Inc.
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-
IRRIGATORS' POST-HEARING BRIEF
COMES NOW the Idaho Irrigation Pumpers Association, Inc. ("Irrigators ), through counsel
of record and submits this Brief to set forth its position and arguments regarding the issues presented
as a part ofIdaho Power Company s (hereinafter "Idaho Power" or "Company ) Application for a
General Rate Increase following the hearings conducted before the Idaho Public Utilities
Commission ("Commission
INTRODUCTION
The Irrigators strongly dispute that their rates are subsidized in any way under the Tariff
Schedules currently in effect or that have previously existed pursuant to Orders of the Commission.
The so-called "Irrigation Subsidy" exists, if at all, only the context of cost-of-service methodologies
presented in this case or previous cases, the accuracy of which is questionable and disputed. The
current and all previous Tariff Schedules in effect for irrigation customers were established and exist
IRRIGATOR'S POST-HEARING BRlEF-
pursuant to Orders of this Commission which are final and binding. Irrigators pay those rates
without any subsidy whatsoever.
The Irrigators will not attempt to address all issues, given the extensive record and multitude
of issues presented. Instead the Irrigators focus primarily upon revenue and allocation issues
effecting the irrigation class and all customers in general. The Irrigators ' failure to address an issue
should not be construed as acceptance or rejection, merely that no position is asserted.
REVENUE REQUIREMENT AND PROPOSED ADJUSTMENTS
The Irrigators support the Staff's proposed adjustments , resulting in an Idaho revenue
requirement of$498, 183 182, and an overall increase of2.94 percent as reflected in Revised Exhibit
101. The Irrigators' witness Yankel scrutinized the Company s actual and budgeted non-power cost
accounts 500-953 expenses for each month for the previous five years (excluding accounts 501 547
555 and 557). This analysis reflects that the Company s expense data in the 2003 test year are
excessive, being at least 2.7 percent or $5 794 724 greater than supported by the trend analysis.
(Yankel, Direct, pp. 4-16) This analysis lends support to the expense reductions Staff recommends.
The Irrigators have also challenged the use of budgeted expense data for the test year
position other parties support. The Company has admitted that actual year-end test year expenses
is available and has presented no valid reason why it shouldn t be utilized where accuracy is the
goal.
COST -OF -SERVICE STUDIES
Purpose and Use
In this case, as in Idaho Power s three previous rate cases, the Commission is presented with
numerous cost-of-service studies based on Idaho Power s loads and resources. In each of the
IRRIGATOR'S POST-HEARING BRIEF - 2
previous cases, the Commission has selected a Weighted 12 Coincident Peak ("W12CP") method
to allocate costs among customer classes. In this case, there seems to be much greater effort and
emphasis by the Company, Staff and other parties to give great deference to the Company s Cost of
Service Study and to rely more heavily upon it in this case than in past cases. Indeed, almost all
other intervenors advocate a rapid and systematic move to setting rates based simply upon strict
adherence to the Company s ill-conceived pure cost -of-service allocation principles and inaccurate
data. These Intervenors exclude all other factors and pay lip service to the principle of "rate shock"
Generally speaking, this Commission has an objective to create rate structures that are cost-
based (IPC-94-, Order No. 25937 , p. 11 , dated March 21 , 1995). This Commission has long
recognized that cost-of-service studies are works of art, not science. They may be a starting point
or tool to aid the Commission in carrying out its statutory responsibility of establishing rates that are
fair, just, reasonable and non-discriminatory. Because of the complexity and controversy over the
use of various cost-of-service methodologies, data problems and the profound impact they may have
on customer rates, this Commission has frequently and repeatedly held that they are but one of many
factors in establishing rates.
These principles were artfully stated in the last Idaho Power general rate case, Case No. IPC-
94-, where the Commission stated in its Final Order No. 25880 issued on January 31 , 1995, as
follows:
However, we are aware of the limitations of any cost-of-service study,
keeping in mind, as stated by IPCo that 'the preparation of a cost-of-service study is
still a combination of art and science with the results hinging on key assumptions and
allocation methods.' The dynamic nature of a cost-of-service study is reflected in
the fact that the results of the W12 CP study in this case vary widely from the results
of the same study in IPCo' s last rate case. As we stated in an Order issued in IPCo' s
last rate case
, '
cost-of-service studies provide a useful starting point for allocating
IRRIGATOR'S POST-HEARING BRIEF - 3
revenues, but in the end we must, and do, consider other factors such as rate
continuity, equity and proportionality.'" (Order No. 21365 , p. 13.
The Commission more recently reaffirmed these principles in the 1999 A vista case, Number
WWWP-98-11 Order No. 28097 as follows:
Cost of service, however, is only one of many factors to be considered by
this Commission in tariff design, there is no required correlation.
The Idaho Supreme Court has also repeatedly recognized that cost of service is but one
criteria among many for consideration in forming a basis for rate differentiation, stating in
Grindstone Butte Mutual Canal CO. VS. Idaho Public Utilities Commission 102 Idaho 175; 627 P.2d
804:
This Court has previously determined that cost of service is but one criteria
among many for consideration in forming a basis for rate differentiation between
classes of service and between classifications of customers within a certain schedule.
In Utah-Idaho Sugar VS. Intermountain Gas Co., (supra), as between classes of
service, i., one schedule as opposed to another, the relevant criteria included the
quantity ofthe utility used, the nature ofthe use, the time of use, the pattern of use
the differences in the conditions of service, the cost of service, the reasonable
efficiency and economy of operation and the actual differences in the situation ofthe
customers for the furnishing of the service. Specifically, as between classes of
customer within a schedule, the criteria included contribution to peak load, cost of
service on peak demand days, cost of storage and economic incentives. Id. at 377
597 P.2d at 1067.
While the various criteria has been listed and discussed, the Supreme Court has clearly
indicated that the criteria listed is not exclusive with the Commission granted broad discretion to
exercise judgment in the setting of rates. The Court stated in Grindstone Butte, supra.at page 807:
We do not find one criteria to be necessarily more essential than another.
Nor do we find the criteria as listed above to be exclusive. As this Court has stated
in the past:
Each case must depend very largely upon its own special
fact~ and every element and every circumstance which increases or
depreciates the value of property, or of the service rendered, should
IRRIGATOR'S POST-HEARING BRIEF - 4
be given due consideration, and allowed that to which it is entitled.
It is, after all, very much a question of sound and well-instructed
judgment.'" (Citation omitted.
Avoiding rate shock, a principle that has universal acceptance of all parties in this case, in
conjunction with discussing any disproportionate increase of the irrigation class, has also been
recognized by the Commission as a proper consideration to be taken into account in determining a
just, fair and reasonable rate. (Case No. UPL-89-, Order No. 22976 1990 Ida.PUC Lexis 26
, p.
10.
Idaho Power well recognizes and accepts the above discussed rate making principles.
Company Witness John R. Gale, the Vice President of Regulatory Affairs responsible for the overall
policy matters relating to regulation and pricing policy decisions, recognized that a pure cost of
service approach should not be followed, and that there are many considerations that should be taken
into account in establishing class revenue allocations, including rate shock. Rebutting Intervenor
Witnesses, Mr. Higgins (Kroger), Dr. Peseau (Micron) and Dr. Powers (AARP), who have suggested
rapid and systematic approaches to fully eliminate the irrigation subsidy, Mr. Gale stated in his direct
rebuttal testimony beginning at page 25, line 25:
. . . The Idaho Commission has historically taken more than just the pure
cost of service result into account when establishing class revenue allocations, with
rate shock being one of those considerations.
* * *
In addition, aggressively ramping up irrigation rates without an evaluation
at each step could have a severe impact on the irrigation customer class." (P.
lines 6-
Economic impacts come into play and must be considered in setting rates, particularly to
apply the principle of rate shock. Neither the Company, Staff, nor any Intervenor, including the
IRRIGATOR'S POST-HEARING BRIEF - 5
Irrigators, presented any analysis or study ofthe economic impact the rapid and systematic proposals
to move Irrigators towards the average 62 mill rate derived from the Company s 5-CP cost of service
study. While there is no economic impact evidence in the record established in the technical
proceedings, ample evidence exists in the record established at the public hearings where numerous
irrigation customers of a variety of sizes and types established an ample record of the potential, if
not obvious and certain, disaster to Irrigators and the agricultural economy if this Commission were
to make a drastic shift in rates as suggested by the Company s ill-advised cost of service study.
Such a shift in cost responsibility based upon the Company s cost of service would be a clear
and inconsistent departure from past rate-making policies and principles. Further, to begin ignoring
or giving less weight to the multitude of other factors would be a dangerous precedent that could
handcuff' future Commissions to a narrow and inflexible set of guidelines. Such could impair this
Commission s ability and need to exercise broad discretion and sound judgment in shaping public
policy.
Idaho Power s Proposed Averaging ofW12CP and 12CP Methodologies
The Company s general assertion that it is presenting the same cost allocation methods as
in past cases has been shown to be far from accurate. In her direct testimony, Company Witness
Brilz discussed the W12CP allocation method stating at page 2, lines 20-25:
This study uses the same methodology as previously filed by the Company
in Case No. U-1006-185 , Case No. U-1006-265A, and Case No. IPC-94-, and
used by the Commission in the allocation of the revenue requirement among
customer classes in those cases.
In this case, the Company in fact proposed to allocate costs using an average of a 12CP and
W12CP method. Further, the new W12CP method in this case provided for the first time ever, a "
weighting in 7 months for the purpose of allocating capacity costs, and a "0" weighting in 9 months
IRRIGATOR'S POST-HEARING BRIEF - 6
for the purpose of allocating transmission-related costs. Accordingly, for purposes of the W12CP
half ofthe equation, the Company is in effect using a 5CP or 3CP method. The Company admitted
on cross-examination by the Irrigators that it has never previously proposed to allocate costs based
on an averaging of 12CP and W12CP. Nor has the Company ever proposed, or this Commission
ever approved for Idaho Power, Avista or PacifiCorp such an average, nor utilizing "0" weighting
factors in any month. In fact, this Commission has never used a weighting factor when it utilized
a 12CP method in any A vista or PacifiCorp cases.
The effect of the Company s "0" weighting factors and methodologies is to allocate far
greater costs to the Irrigators than under past methodologies. On its face, the Company s weighting
rationale appears sound, because ofload growth during certain peak months. However, load growth
is also appearing in all months. When applied to the Irrigators, it appears particularly unfair and
unjust to charge them with the cost of growth on the Idaho Power system caused by other customers
given that the irrigation class has shown no growth whatsoever the past ten years and is projected
to have no growth in the future. The percentage of growth by class since the last case is depicted
graphically and by percentage in the Irrigator s Figure 10. (Yankel, Reb., p. 10)
In the past three Idaho Power general rate cases, the Irrigators received disproportionate and
larger increases than the overall increases to all customers in an effort to move Irrigators closer to
their perceived cost of service. Now, suddenly, in this case, if the Company s cost-of-service
methodology is accepted, the deficiency gap for Irrigators has grown to $40.5 million, which would
require a 67.1 percent increase to close. Since there has been no growth for ten years in the irrigation
class, the growth ofthe deficiency gap is directly attributable to the new allocation methodologies
and inaccurate data employed by the Company in this case.
IRRIGATOR'S POST-HEARING BRIEF - 7
It appears patently unfair to use a new allocation method which not only saddles the Irrigators
with a disproportionately large share of embedded costs, but also a disproportionately large share
of growth-related costs, which they did not create. The fact that the Company used demand data for
the irrigation class based upon the requirements of the drought year 2002 and yet normalized
(reduced) revenues to normal levels is an example of the mismatch of data that is being utilized to
contribute to the unfair and unreasonable result found in the Company s cost of service study. Ifthe
principle of cost causation is to be followed, which virtually all witnesses advocated in this case, it
can only mean that the Company s cost allocation methodologies must be rejected and new
methodologies found and employed that better allocate the costs of growth to the Residential and
Commercial Schedules 7 and 19 and Special Contract Customer Micron that are fueling growth-
related costs, not the Irrigators who have not.
W12CP - Weighting Factor Adjustments
Should the Commission choose to rely upon W12CP allocation, the Irrigators urge that the
weighting factors be based upon sound and reliable data. Such data was presented by the Irrigators
in their rebuttal testimony (Yankel, Reb. P. 16 line 1 through p. 17 line 8) changed to correlate with
the Integrated Resource Plan ("IRP"
The Company s W12CP weighting factors are simply arbitrarily selected values that are not
even derived from the data they are claimed to represent. The Company contended its 2002 IRP
identified five capacity deficit months (June, July, August, November and December) that are
driving the need for additional peaking resources. (Brilz, Dir., p. 15 , lines 8-24.) In relying on the
IRP to formulate its weighting factors, the Company focused on the five-year time frame of2003-
IRRIGATOR'S POST-HEARING BRIEF - 8
2007 and the Seventieth Percentile Water and Load Condition.! However, that IRP clearly and
repeatedly states that Idaho Power had capacity deficits in only the four months of June, July,
November and December. Nowhere does August appear as a deficit month, and it appears to have
been arbitrarily selected. (Exhibit 314, Figure 5) Further, there is no correlation between the size
of the capacity deficits identified in the IRP and the weighting factors the Company chose.
On cross-examination from the Irrigators, Mr. Said could not explain the use ofthe month
of August or why the weighting factors didn t correlate with the IRP and deferred to Ms. Brilz. She
explained that the IRP had been "updated" to remove Gannet after that plant was cancelled, which
then added August as a deficit month. Later in the proceeding, the supporting documentation was
supplied which consisted of the Company s "Report to IPUC on replacing the Gannet Power
Purchase Agreement". However, the so-called IRP Update Report shows no update ofthe "Capacity
Deficit for 70th Percentile Water and Load" without Gannett, which was now claimed to be the
source of the Company s 5 deficit months used to formulate its weighting factors. Instead, the
bottom graph on page 8 reflects 90th percentile water. Further, the Update Report depicting the
capacity deficit with Gannett should be identical to the same graph in the original 2002 IRP, yet is
substantially different, as can be seen by comparing Exhibit 314, Figure 5 with Exhibit 315, page
, top graph. Ifthat is in fact the IRP Update Report being relied on, as the Company witness (Said
or Brilz) contended during cross-examination, the year 2007 reflects six capacity deficit months
which include the months of September and October, but not November.
It can be clearly concluded that the Company either misinterpreted its own IRP or simply did
not rely upon it to identify the capacity deficit months and the weighting factors as it should have.
Response to Federal Executive Agency s Request 1-d at page 6.
IRRIGATOR'S POST-HEARING BRIEF - 9
The deficit months the Company utilizes simply do not correlate with the deficit months specifically
identified in the IRP. Nor do the weighting factors correlate with the size ofthe identified deficits.
For these reasons the Company s W12CP is inaccurate and unreliable and should be disregarded.
Alternatively, if weighting factors are going to be utilized, the values offered by the Irrigators ofthe
highest marginal price paid for short-term or intermediate-term firm power at the hour of each
monthly system peak is far more reliable and reflective of actual peak costs on the system.
Irrigators' Recommendation
During the past three Idaho Power general rate cases, the parties have extensively analyzed
and scrutinized the input data the Company employed for purposes of its cost-of-service studies, and
explored a number of different alternatives. Unfortunately, other than the Irrigators, the level of
scrutiny has simply not existed in this case as most everyone chose to accept as "gospel" the input
data, methodologies and results from the Company s cost -of-service studies. For these reasons, the
Irrigators urge the Commission to initiate a separate proceeding to thoroughly investigate and
analyze cost-of-service issues. This would permit a thorough investigation ofthe quality, quantity
and validity of the load research data the Company uses as input to its cost-of-service study.
would also permit an understanding, scrutiny and alternative runs of the Company s Loadstar Load
Research Data Program and the Company s cost-of-service program, which is totally lacking in this
case. The Company chose to ignore the problems encountered by the Irrigators' Witness Yankel in
his efforts to understand these "black boxes . The Irrigators urge the Commission to consider
spreading rates on an equal percentage basis in the meantime. Once the investigation has been
completed, many questions should be answered and the Commission will have a more accurate and
reliable basis upon which to move rates towards cost of service should it so choose, either at that
IRRIGATOR'S POST-HEARING BRIEF -
time or during more regular general rate cases, which Idaho Power anticipates in the next several
years, as its capital expenditure program is initiated.
The Company did not accurately identify the deficit months or apply proper weighting
factors based upon the IRP , the results of their W12CP Allocation Study are inaccurate and
unreliable and should be rejected. Furthermore, the Company s cost of service study completely
mismatches irrigation peak demands from a drought year with "normalize" year revenues.
Additionally, it assigns underground distribution plant to Irrigators when everyone agrees that
Irrigators do not use this type of plant that has been extensively installed in recent years.
If the Commission is not willing to initiate a separate proceeding to investigate cost of study
issues as suggested, the Irrigators recommend the use of a 12CP allocation methodology. This
would be consistent with the 12CP methodology the Company used for the Jurisdictional Separation
Study.
The Commission should also correct the mismatches between demand assignment to the
Irrigators and the use of normalized revenues, as well as remove all allocation of underground-
related distribution costs. These steps would not correct all of the inadequacies with the Company
cost of services study, but would be a step in the right direction using data and issues that should
have little or no controversy.
CLASS REVENUE ALLOCATION
The parties have presented the Commission with three separate and distinct alternatives for
approaching revenue allocation between the customer classes. The Company and Staff propose a
case-by-case analysis of allocation issues, using a 12CP method to allocate between the jurisdictions
and an average 12CP and W12CP (with new allocators weighting only five months) to allocate cost
IRRIGATOR'S POST-HEARING BRlEF-
between the customer classes. Both propose that more than just cost of service be considered in
setting rates. To avoid rate shock the Company proposes a 25% cap to Irrigators, while the Staff
proposes a 15% cap. The Irrigators propose that any increase be spread on an even percentage basis
with a separate proceeding initiated to thoroughly investigate cost of service issues. Most other
Intervenors, including Micron, AARP and Kroger, propose a rapid and systematic increase to the
Irrigators based upon only the results of the Company s inaccurate cost of service methodology.
Brief comment will be provided on each separate proposal.
Company Proposal.
The Company places near exclusive reliance on its cost of service proposals to allocate
revenues to the classes. Yet, the Company apparently lacks confidence in the results of its W12CP
method. Otherwise, it would not have initiated in this case a process that averaged the W12CP with
a 12CP method to achieve its calculated result. Never before has the Company proposed, nor this
Commission approved, an averaging of allocation methods, nor the use of "0" monthly allocators.
The "0" allocators effectively result in a 5CP for capacity-related costs and 3CP for transmission-
related costs. As a result, costs are heavily and unfairly weighted to Irrigators. It is the use ofthese
new methodologies (combined with other data problems) that create the size and gap of the so-called
irrigation subsidy . To mitigate the 67.1 percent increase that the Company s cost of service study
would place upon the Irrigators, the Company recognizes the rate principle of rate shock avoidance
should be applied. Thus, the Company proposes that the Irrigation rate increase should be limited
to 25 percent or 1.5 times the average jurisdictional increase.
The difficulty with the Company s proposal is illustrated by Exhibit 44, page 6. This exhibit
shows the impact of the Company s rate design proposal on Schedule 24 by reason ofthe diversity
IRRIGATOR'S POST-HEARING BRIEF -
of the irrigation class. Exhibit 44 shows that only 23 percent of the class would actually receive a
25 percent increase, while the increase to the remaining 77 percent of the class would be greater than
25 percent, with 46 percent ofthe class receiving an increase ranging from 32 to 50 percent. Rate
shock must be viewed from the perspective ofthe impact on individual irrigators, not merely from
the class as a whole perspective.
Staff Proposal.
Staff appears to accept the Company s input data based upon the Loadstar program, together
with the Company s cost of service proposal, all with little or no scrutiny of the input data nor
concern about the total lack of transparency of these complex models. Staff also appears to support
a strong cost of service move and addresses the concern over rate shock to the irrigation class by
proposing a 15 percent limit.
While the Staff's proposed 15 percent cap on irrigation rates on its face seems moderate
compared to the Company s 25 percent cap, it is not necessarily so in practical application. The
Company s proposed 25% cap raises irrigation rates 8 percentage points or approximately 50 percent
more than the jurisdictional average rate increase of 17.9 percent. On the other hand, the 15 percent
cap the Staff proposes is 5 times greater than the 2.94 percent jurisdictional average increase Staff
proposes.
In evaluating any move of the Irrigators towards their perceived cost of service, the
Commission should (n the exercise of its judgment) give appropriate consideration towards how the
increase affects individual customers in the class, the overall percentage increase, and how the
increase compares to the overall jurisdictional average increase.
Pure Cost of Service.
IRRIGATOR'S POST-HEARING BRlEF-
The proposal ofIntervenors Micron, AARP and Kroger to systematically move the Irrigators
to the Company s suggest sed rate levels should be rejected. There is no guarantee their proposals
to systematically increase rates to Irrigators would be accurate now or over the time of
implementation. Cost of service issues and changes in class revenue allocation can best be examined
at a point in time on a case-by-case basis. Farmers are under extreme pressure with low commodity
prices, rising water and fuel costs, making it clear that a sudden increase in rates would be
economically disastrous to the class as well as the agricultural economy.
Irrigators' Proposal.
The Irrigators believe that the Company s Load Research Data and Cost of Service Study
must be put in an electric format that is understandable and transparent to all parties so that they can
be fully scrutinized. That has not happened in this case. The Company and Intervenors have chosen
to simply ignore the Irrigators' concerns on these issues. Given the cost of service questions raised
in this case, the Irrigators believe the time is now appropriate to initiate a separate proceeding to
comprehensively study the data used as input to the Cost of Service Study as well as cost of service
methodologies. The Irrigators propose that any rate increase be spread evenly between the customer
classes until such time as more accurate and reliable information is available.
Irrigation Subsidy
While the term "irrigation subsidy" has been regularly discussed and repeated in this case
it only exists in the context of the present and past cost of service studies conducted by the
Company. Each of these studies was different, with each study placing more weight on the Irrigation
demand. In fact, the present and past irrigation rates are simply not subsidized as a matter oflaw.
Irrigation rates, like those of all other customers, are set in tariff established by order of the
IRRIGATOR'S POST-HEARING BRIEF - 14
Commission based upon many factors - a cost of service study supplied by the Company being just
one of those factors.
RATE DESIGN
The Irrigators oppose the Company s proposal to increase the "in season" demand charge
from $3.58 per KW to $5.40 per KW and to increase the customer charge from $10.07 per month
to $25.00 per month. Irrigators propose the customer charge and demand charge increases for
Irrigators should not exceed the system average rate increase. This properly places monetary impact
on the one cost component over which Irrigators have control. Further, it avoids even greater
disparities of rate increases upon individual irrigators within the class based on their size and use
patterns.
RESPECTFULLY SUBMITTED this 22nd day of April, 2004.
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHARTERED
RANDALL C. BUDGE
IRRIGATOR'S POST-HEARING BRIEF -
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 23rd day of April, 2004, I mailed a true and complete
copy of the foregoing document, postage prepaid, to each of the following:
Barton L. Kline
Monica B. Moen
Idaho Power Company
O. Box 70
Boise, Idaho 83707-0070
E-mail: bkline~idahopower.com
mmoen~idaho power.com
John R. Gale
VP-Regulatory Affairs
Idaho Power Company
O. Box 70
Boise, Idaho 83707-0070
E-mail: rgale~idahopower.com
Lisa Nordstrom
Weldon Stutzman
Deputy Attorney Generals
Idaho Public Utilities Commission
472 W. Washington (83702)
O. Box 83720
Boise, Idaho 83720-0074
E-mail: lnordst~puc.state.id.
wstutzm~puc. state.id. us
Peter J. Richardson, Esq.
Richardson & O'Leary
99 E. State St., Suite 200
O. Box 1849
Eagle, Idaho 83616
E-mail: peter~richardsonand oleary. com
Don Reading
Ben Johnson Associates
6070 Hill Road
Boise, Idaho 83703
E-mail: dreading~mindspring.com
Anthony Yankel
29814 Lake Road
Bay Village, Ohio 44140
E-mail: yankel~attbi.com
Lawrence A. Gollomp
Assistant General Counsel
United States Department of Energy
1000 Independence Ave., SW
Washington, D.c. 20585
E-mail: lawrence.gollomp~hq.doe.gov
Dennis Goins
Potomac Management Group
5801 Westchester Street
Alexandria, VA 22310-1149
Mail: dgoinspmg~aol.com
Dean J. Miller
McDevitt & Miller LLP
O. Box 2564
Boise, Idaho 83701
E-mail: joe~mcdevitt-miller.com
Jeremiah J. Healy
United Water Idaho, Inc.
O. Box 190420
Boise, Idaho 83719-0420
E-mail: jerry.healy~unitedwater.com
IRRIGATOR'S POST-HEARING BRIEF - 16
William M. Eddie
Advocates for the West
O. Box 1612
Boise, Idaho 83701
E-mail: billeddie~rmci.net
Conley E. Ward
Givens Pursley LLP
601 W. Bannock St.
O. Box 2720
Boise, ID 83701-2720
E-mail: cew~givenspursley.com
Brad M. Purdy
Attorney at Law
2019 N. 17th Street
Boise, Idaho 83702
E-mail: bmpurdy~hotmail.com
Michael L. Kurtz
Kurt J. Boehm
Boehm, Kurtz & Lowry
37 E. Seventh St., Suite 2110
Cincinnati, OH 45202
E-mail: mkurtzlaw~aol.com
IRRIGATOR'S POST-HEARING BRIEF -
Nancy Hirsh
NW Energy Coalition
219 First Ave. South, Suite 100
Seattle, Washington 98104
E-mail: nancy~nwenergy.org
Dennis E. Peseau, Ph.
Utility Resources, Inc.
1500 Liberty Street S., Ste 250
Salem, Oregon 97302
E-mail: dennytemp~yahoo.com
Michael Karp
147 Appaloosa Lane
Bellingham, Washington 98229
E-mail: michael~awish.net
Thomas M. Power
Economics Dept. Liberal Arts Bldg 407
University of Montana
32 Campus Drive
Missoula, MT 59812
E-mail: tom.power~mso.umt.edu
RANDALL C. BUDGE