20071210Carlock direct.pdf

BEFORE THE
2(Jill DEC 10 Pfl 3: 35
IDAHO PUBLIC UTILITIES COMl\lU~~:l~) PUBLIC
J i ki lit;) COMMlSS10f
IN THE MATTER OF THE APPLICATION )
OF IDAHO POWER COMPANY FOR ) CASE NO. IPC-E-07-8
AUTHORITY TO INCREASE ITS RATES )
AND CHARGES FOR ELECTRIC SERVICE )
IN THE STATE OF IDAHO. )
)
)
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)
DIRECT TESTIMONY OF TERRI CARLOCK
IDAHO PUBLIC UTiliTIES COMMISSION
DECEMBER 10, 2007
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2 record.
Q.Please state your name and address for the
A.My name is Terri Carlock. My business address
4 is 472 West Washington Street, Boise, Idaho.
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Q.By whom are you employed and in what capacity?
I am the Deputy Administrator of the Utili tiesA.
7 Division at the Idaho Public Utili ties Commission. I am
8 responsible for the Accounting/Audit Section and
9 coordinating Staff's policy positions with Randy Lobb.
10 Q.Please outline your educational background and
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11 experience.
A.I graduated from Boise State University in
13 1980, with B.B.A. Degrees in Accounting and Finance. I
14 have attended various regulatory, accounting, rate of
15 return, economics, finance, and ratings programs. I
16 chaired the National Association of Regulatory Utilities
17 Commissioners (NARUC) Staff Subcommittee on Economics and
18 Finance for more than 3 years. Under this subcommittee,
19 I also chaired the Ad Hoc Committee on Diversification.
20 I am currently the Vice-Chair of the NARUC Staff
21 Subcommi t tee on Accounting and Finance. I have been a
22 presenter for the Institute of Public Utilities at
23 Michigan State University and for many other conferences.
24 Since joining the Commission Staff in May 1980, I have
25 participated in audits, performed financial analysis on
CASE NO. IPC-E-07-812/10/07 CARLOCK, T (Di) 1
STAFF
1 various companies, and have presented testimony before
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2 this Commission on numerous occasions.
Q.What is the purpose of your testimony in this
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4 proceeding?
A.The purpose of my testimony is to discuss
6 policy positions including the review of Staff positions
7 in this case. I present the Staff's recommendation
8 related to the return on equity for Idaho Power Company
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9 to be used in the revenue requirement.
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Q.Please summarize your testimony.
A.Portions of my testimony are policy related
12 and do not have specific recommendations directly
13 impacting the revenue requirement. In my testimony, I
14 recommend a return on common equity for Idaho Power in
15 the range of 9.5% - 10.5% with a point estimate of
16 10.25%. The recommended overall weighted cost of capital
17 is in the range of 7.499% - 7.985% with a point estimate
18 of 7.864% to be applied to the rate base for the test
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19 year.
21 Idaho Power witnesses Avera and Steven Keen associated
Q.Have you reviewed the testimony and exhibits of
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22 with the return components?
A.Yes. Much of the theoretical approach used by
24 witnesses Avera and Steven Keen in their testimonies and
25 exhibits is generally the same as I have used. My
CASE NO. IPC-E-07-812/10/07 CARLOCK, T (Di) 2
STAFF
1 judgment in some areas of application results in
2 different outcomes.
3 Q.What legal standards have been established for
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4 determining a fair and reasonable rate of return?
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A.The legal test of a fair rate of return for a
utility company was established in the Bluefield Water
Works decision of the United States Supreme Court and is
repeated specifically in Hope Na tural Gas.
In Bluefield Water Works and Improvement Co. v.
West Virginia Public Service Commission, 262 U. S. 679,
692, 43 S. Ct. 675 , 67 L. Ed. 1176 ( 1923), the Supreme
Court stated:
A public utility is entitled to such rates as
will permit it to earn a return on the value
of the property which it employs for the
convenience of the public equal to that
generally being made at the same time and in
the same general part of the country on
investments in other business undertakings
which are attended by corresponding risks and
uncertainties i but it has no constitutional
right to profits such as are realized or
anticipated in highly profitable enterprises
or speculative ventures. The return should
be reasonably sufficient to assure confidence
in the financial soundness of the utility and
should be adequate, under efficient and
economical management, to maintain and
support its credit and enable it to raise the
money necessary for the proper discharge of
its public duties. A rate of return may be
reasonable at one time and become too high or
too low by changes affecting opportunities
for investment, the money market and businessconditions generally.
CASE NO. IPC-E-07-812/10/07 CARLOCK, T (Di) 3
STAFF
1 The Court stated in FPC v. Hope Natural Gas Company, 320
2 u.s. 591, 603, 64 S.Ct. 281, 88 L.Ed. 333 (1944):
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From the investor or company point of view it
is important that there be enough revenue not
only for operating expenses but also for the
capi tal costs of the business. These include
service on the debt and dividends on thestock.
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. .. By that standard the return to the equity
owner should be commensurate with returns on
investments in other enterprises having
corresponding risks. That return, moreover,
should be sufficient to assure confidence in
the financial integrity of the enterprise, so
as to maintain its credit and to attract
capital. (Citations omitted.)
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11 The Supreme Court decisions in Bluefield Water
12 Works and Hope Natural Gas have been affirmed in In re
13 Permian Basin Area Rate Case, 390 U.S. 747, 88 S.Ct 1344,
14 20 L.Ed 2d 312 (1968), and Duquesne Light Co. v. Barasch,
15 488 U. S. 299, 109 S. Ct. 609, 102 L. Ed. 2d. 646 (1989).
16 The Idaho Supreme Court has also adopted the principles
17 established in Bluefield Water Works and Hope Natural
18 Gas. See In re Mountain States Tel. & Tel. Co. 76 Idaho
19 474, 284 P.2d 681 (1955) i General Telephone Co. v. IPUC,
20 109 Idaho 942, 712 P.2d 643 1986) i Hayden Pines Water
21 Company v. IPUC, 122 ID 356, 834 P.2d 873 (1992).
22 As a result of these United States and Idaho
23 Supreme Court decisions, three standards have evolved for
24 determining a fair and reasonable rate of return:
25 (1) The Financial Integrity or Credit Maintenance
CASE NO. IPC-E-07-812/10/07 CALOCK, T (Di) 4
STAFF
1 Standardi (2) the Capital Attraction Standardi and,
2 (3) The Comparable Earnings Standard. If the Comparable
3 Earnings Standard is met, the Financial Integrity or
4 Credit Maintenance Standard and the Capital Attraction
5 Standard will also be met, as they are an integral part
6 of the Comparable Earnings Standard.
7 Q.Have you considered these standards in your
8 recommendation?
9 A.Yes. These criteria have been seriously
10 considered in the analysis upon which my recommendations
11 are based. It is also important to recognize that the
12 fair rate of return that allows the utility company to
13 maintain its financial integrity and to attract capital
14 is established assuming efficient and economic
15 management, as specified by the Supreme Court in
16 Bluefield Water Works.
17 Q.Please summarize the parent/subsidiary
18 relationships for Idaho Power Company.
19 A.Idaho Power i s common stock is not traded.
20 Idaho Power Company is a wholly owned subsidiary of
21 IDACORP. Due to this parent/subsidiary relationship
22 there is no direct equity market data available for
23 utility operations at Idaho Power. However, the utility
24 operations now represent the major operations within
25 IDACORP, making the market information representative of
CASE NO. IPC-E-07-812/10/07 CALOCK, T (Di) 5
STAFF
1 Idaho Power's operations.
2 Q.What approach have you used to determine the
3 cost of equity for Idaho Power?
4 A.I have primarily evaluated two methods: the
5 Discounted Cash Flow (DCF) method and the Comparable
6 Earnings method.
7 Q.Please explain the Comparable Earnings method
8 and how the cost of equity is determined using this
9 approach.
10 A.The Comparable Earnings method for determining
11 the cost of equity is based upon the premise that a given
12 investment should earn its opportunity costs. In
13 competi ti ve markets, if the return earned by a firm is
14 not equal to the return being earned on other investments
15 of similar risk, the flow of funds will be toward those
16 investments earning the higher returns. Therefore, for a
17 utility to be competitive in the financial markets, it
18 should be allowed to earn a return on equity equal to the
19 average return earned by other firms of similar risk.
20 The Comparable Earnings approach is supported by the
21 Bluefield Water Works and Hope Natural Gas decisions as a
22 basis for determining those average returns.
23 Industrial returns tend to fluctuate with
24 business cycles, increasing as the economy improves and
25 decreasing as the economy declines. Utility returns are
CASE NO. IPC-E- 07- 812/10/07 CARLOCK, T (Di) 6
STAFF
1 not as sensitive to fluctuations in the business cycle
2 because the demand for utility services generally tends
3 to be more stable and predictable. However, returns have
4 fluctuated since 2000 when prices in the electricity
5 markets dramatically increased. Electricity prices have
6 not seen the dramatic spikes lately so earnings are more
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7 stable.
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Q.Please evaluate interest rate trends.
A.The prime interest rate has decreased from
10 8.25% to the current rate of 7.5%. The federal funds
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11 rate and other rates have also decreased this year.
Q.Please provide the current index levels for the
13 Dow Jones Industrial Average and the Dow Jones Utility
14 Average.
15 A.The Dow Jones Industrial Average (DJIA) closed
16 at 13,444.96 on December 5, 2007. The DJIA all-time high
17 of 14,164.53 was reached on October 9, 2007. The Dow
18 Jones Utility Average on December 5, 2007 closed at
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19 550.13, a 52-week high.
21 industrials and utilities.
Q.Please explain the risk differentials between
22 A. Risk is a degree of uncertainty relative to a
23 company. The lower risk level associated with utilities
24 is attributable to many factors even though the
25 difference is not as great as it used to be. Utilities
CASE NO. IPC-E-07-812/10/07 CARLOCK, T (Di) 7
STAFF
1 continue to have limited competition for distribution of
2 utility services within the certificated area. With
3 limited competition for regulated services, there is less
4 chance of losses related to pricing practices, marketing
5 strategy and advertising policies. The competi ti ve risks
6 for some electric utilities and the industry as a whole
7 have changed with increasing non-utility -generation,
8 deregulation in some states, open transmission access,
9 and changes in electricity markets. However, competitive
10 risks are limited for Idaho Power utility operations.
11 The demand for utility services is relatively stable and
12 certain or increasing compared to that of unregulated
13 firms and even other utility industries.
14 Competitive risks continue to be lower for
15 Idaho Power than for many other electric companies
16 primarily because of the low-cost source of power, the
17 low retail rates compared to national averages, the Power
18 Cost Adjustment (PCA), and the Fixed Cost Adjustment
19 (FCA). The risk differential between Idaho Power and
20 other electric utilities is based on the resource mix and
21 the cost of those resources. All resource mixes have
22 risks specific to resources chosen. The demand for
23 electric utility services of Idaho Power is increasing at
24 predictable rates. This low demand risk is partially due
25 to the low-cost power and the customer mix of the power
CASE NO. IPC-E-07-812/10/07
CARLOCK, T (Di) 8
STAFF
1 users.
2 Under regulation, utilities are generally
3 allowed to recover through rates, reasonable, prudent and
4 justifiable cost expenditures related to regulated
5 services. Unregulated firms have no such assurance.
6 Utilities in general are sheltered by regulation for
7 reasonable cost recovery risks, making the average
8 utility less risky than the average unregulated
9 industrial firm.
10 Considering all of these comparisons, I believe
11 a reasonable return on equity attributed to Idaho Power
12 is 10.0% - 11.0% under the Comparable Earnings method.
13 Q.You indicated that the Discounted Cash Flow
14 method is utilized in your analysis. Please explain this
15 method.
16 A.The Discounted Cash Flow (DCF) method is based
17 upon the theory that (1) stocks are bought for the income
18 they provide (i. e., both dividends and/or gains from the
19 sale of the stock), and (2) the market price of stocks
20 equals the discounted value of all future, incomes. The
21 discount rate, or cost of equity, equates the present
22 value of the stream of income to the current market price
23 of the stock.The formula to accomplish this goal is:
D D D Pi2NN
Po =PV =-------+-------+.. .+------+------
(l+ks) i (l+ks) 2 (l+ks) N (l+ks)N
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CASE NO. IPC-E-07-812/10/07 CALOCK, T (Di) 9
STAFF
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Po =
D =
ks =
N =
Current Price
Dividend
Capitalization Rate, Discount Rate, or Required
Rate of Return
Latest Year Considered
The pattern of the future income stream is the
key factor that must be estimated in this approach. Some
simplifying assumptions for ratemaking purposes can be
made without sacrificing the validity of the results.
Two such assumptions are:(1) dividends per share grow
at a constant rate in perpetuity and (2) prices track
earnings. These assumptions lead to the simplified DCF
formula, where the required return is the dividend yield
plus the growth rate (g):
D
kg =+ g
Po
Q. Have you factored flotation costs in with your
cost of capital analysis?
A. Yes, I have considered direct flotation costs
in my analysis by increasing the dividend yield component
of the DCF analysis. Because only direct costs should be
considered, I have used a 2% flotation factor. I have
therefore adjusted the DCF formula to include the direct
flotation costs as "df".
CASE NO. IPC-E-07-812/10/07 CARLOCK, T (Di) 10
STAFF
1 Dks= (--- (l+df)J+g
Po2
3 Q.What is your estimate of the current cost of
4 capital for Idaho Power using the Discounted Cash Flow
5 method?
6 A.The current cost of equity capital for Idaho
7 Power, using the Discounted Cash Flow method with
8 comparable companies is between 7.7% - 11.7%. Due to
9 ongoing capital requirements, I believe a dividend yield
10 of 4.2% with an average growth rate of 5.2% is reasonable
11 and representative resulting in a DCF return on equity of
12 9.4% for utility comparable companies. The Discounted
13 Cash Flow for Idaho Power using Value Line information
14 for IDACORP is 7.1% with a dividend yield of 3.77% with
15 an average growth rate of 3.3%
16 Q.How is the growth rate (g) determined?
17 A.The growth rate is the factor that requires the
18 most extensive analysis in the DCF method. It is
19 important that the growth rate used in the model be
20 consistent with the dividend yield so that investor
21 expectations are accurately reflected and the growth rate
22 is not too large or too small.
23 I have used an expected growth rate of 3% - 4%.
24 This expected growth rate was derived from an analysis of
25 various historical and proj ected growth indicators,
CASE NO. IPC-E-07-812/10/07 CARLOCK, T (Di) 11
STAFF
1 including growth in earnings per share, growth in cash
2 dividends per share, growth in book value per share,
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3 growth in cash flow and the sustainable growth.
Q.What capital structure has Staff used for Idaho
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5 Power to determine the overall cost of capital?
A.Staff witness Donn English has prepared the
7 exhibi ts for the capital structure, debt cost utilized
8 and the overall rate of return. Staff utilized the
9 embedded capital structure at June 30, 2007 consisting of
10 51.437% debt and 48.563% common equity as shown on Staff
11 Exhibit No. 115, page 1. I agree with Mr. English's
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12 recommendations in these areas.
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14 structure for debt?
Q.What are the costs related to the capital
A.The cost of debt is discussed in detail by
16 Staff witness English and is shown as 5.612% on Staff
17 Exhibit No. 115, page 2.
18 Q.You indicated the cost of common equity range
19 for Idaho Power is 10.0% - 11.0% under the Comparable
20 Earnings method and 7.1% - 11. 7% ~nder the Discounted
21 Cash Flow method. What is the cost of common equity
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22 capital you are recommending?
A.The fair and reasonable cost of common equity
24 capi tal I am recommending for Idaho Power is in the range
25 of 9.5% - 10.5%. Although any point within this range is
CASE NO. IPC-E-07-812/10/07 CALOCK, T (Di) 12
STAFF
1 reasonable, the return on equity granted would not
2 normally be at either extreme of the fair and reasonable
3 range. I utilized a point estimate of 10.25% in
4 calculating the overall rate of return for the revenue
5 requirement.
6 Q.What is the basis for your point estimate being
7 10.25% when your range is 9.5% - 10. 5%?
8 A.The 10.25% return on equity point estimate
9 utilized is based on a review of market data and
10 comparables, average risk characteristics for Idaho
11 Power, operating characteristics and the capital
12 structure.
13 Q.What is the overall weighted cost of capital
14 recommended for Idaho Power?
15 A.The overall weighted cost of capital
16 recommended by Staff is in the range of 7.499% - 7.985%.
17 For use in calculating the revenue requirement, a point
18 estimate consisting of a return on equity of 10.25% and a
19 resulting overall rate of return of 7.864% was utilized
20 as shown on Staff Exhibit No. 115, page 1.
21 Q.Have you reviewed all of the Staff
22 recommendations in this case?
23 A.Yes, I have and I believe all of the
24 recommended Staff adjustments are consistent with the
25 overall Staff policy.
CASE NO. IPC-E-07-8
12/10/07 CARLOCK, T (Di) 13
STAFF
1 Q.Please provide an overview of how the Staff's
2 case fits in with historical ratemaking practices.
3 A.The Staff's recommendations in this case expand
4 upon the historical ratemaking practices proposed by
5 Staff or adopted by this Commission. The basis of
6 Staff's recommendations continue to be based on auditable
7 data, plant that is used and useful, adjustments that are
8 known and measurable all to develop a revenue requirement
9 and rates that are fair, just and reasonable for the
10 Company and customers.
11 As expressed by other Staff witnesses, the
12 preferred test year is based on an historical period. A
13 test year based on actual data allows the Commission
14 Staff, and other parties, the best opportunity to
15 evaluate a utility's revenue requirement. Staff takes
16 its charge very seriously to recommend a revenue
17 requirement and rates that are fair, just and reasonable.
18 As part of the revenue requirement calculation, plant in
19 service must be used and useful and adjustments for
20 future changes must be known and measurable. While these
21 principles are very important it is also necessary for
22 utilities to be financially viable and have the ability
23 to attract capital at reasonable rates. This is the
24 balancing act that the Commission must provide. The
25 Company and customers intervening in a case may present a
CASE NO. IPC-E- 07 - 812/10/07 CARLOCK, T (Di) 14
STAFF
1 fair case, but still has its own best interests to
2 preserve and protect.
3 The matching principle is another long
4 established, ratemaking concept where costs and revenues
5 must match. This applies to expenses and the return on
6 plant to serve customers. Proforma adj ustments to an
7 historical test year, or any test year, must abide by
8 this matching principle for rates to be set that are
9 just, fair and reasonable for all customers and the
10 Company.
11 The Staff's proposed test year with its rate
12 base, expenses and revenues focuses on these concepts.
13 Plant in service is annualized for proj ects over $2
14 million (system cost) placed in service during the test
15 year. This annualization includes plant in rate base as
16 if it were in service for the full year. Plant placed in
17 service beyond the test year ending June 30, 2007 has
18 been proformed into the results of operations to match
19 the in service date between July and December 31, 2007.
20 Al though some proj ects are not yet in service at the time
21 of writing this testimony, the projects are under
22 construction and the costs have been included at a known
23 and measurable level. To match the rate base extended
24 beyond the average test year rate base, revenues must
25 also be adjusted. This matching has been accomplished by
CASE NO. IPC-E-07-812/10/07 CARLOCK, T (Di) 15
STAFF
1 utilizing the average revenues for 2007 to match the
2 average customer levels to be served by the annualized
3 and proformed plant. The maj or expense categories
4 associated with this plant level have also been adjusted
5 for matching and proforma purposes. Major expense
6 categories include power supply costs, labor costs based
7 on June 2007 employee levels and wages, and depreciation
8 expense.
9 Q.Why are proforma adjustments reasonable and
10 necessary?
11 A.Proforma adjustments are necessary to reflect
12 changes going forward and to reduce regulatory lag.
13 Proforma adj ustments are reasonable when they meet the
14 known and measurable principle and the matching
15 principle. The Staff proforma adjustments, as well as
16 the final recommended revenue requirement meet these
17 principles.
18 Q.How has Staff addressed regulatory lag?
19 A.As explained above and in the testimony of
20 other Staff witnesses, the annualizing and proforma
21 adjustments to rate base and expenses reflect the most
22 current information that is known and measurable. These
23 adjustments reduce regulatory lag without violating
24 established ratemaking principles. Regulatory lag is a
25 utility risk that has historically been considered when
CASE NO. IPC-E-07-812/10/07 CARLOCK, T (Di) 16
STAFF
1 establishing the authorized return on equity. The return
2 on equity proposed in this case continues to reflect risk
3 levels that, in Staff's opinion, cover any remaining
4 regulatory lag.
5 Q.Are there additional measures that could be
6 utilized to reduce regulatory lag?
7 A.Not in this case. The available information is
8 not adequate to make additional adjustments. Under other
9 circumstances, there may be additional adjustments that
10 would also be justifiable and reasonable. The need to
11 further reduce regulatory lag in this case is also not
12 adequately addressed in this case. One component needed
13 to adequately evaluate regulatory lag is the
14 quantification of harm caused from regulatory lag weighed
15 against the cqst of any measures taken to reduce
16 regulatory lag.
17 Capital expenditure requirements in the future
18 may cause regulatory lag and financial pressure that
19 should be addressed. Therefore, in a future case, Staff
20 believes there may be future plant adjustment measures
21 that can be based on actual data that will meet the known
22 and measurable principle and the matching principle.
23 These possibilities will need to be more fully explored
24 with test year data that can be verified. The Idaho
25 Power fully forecasted 2007 test year in this case does
CASE NO. IPC-E-07-812/10/07 CARLOCK, T (Di) 17
STAFF
1 not meet that criterion.
2 Q.Please provide a short explanation of how the
3 role of rating agencies and ratings themselves fit into
4 the ratemaking process?
5 A.At the risk of being overly simplified, I will
6 provide a very short and limited view of this
7 interaction. The rating agencies service is very
8 important for investors and companies to assist in the
9 reasonable exchange of investment funds. These capital
10 investments may be in the form of debt or equity.
11 Investors rely on ratings to assess risk. It is this
12 risk assessment that provides the Company with the rating
13 that will be a critical piece of information to establish
14 its borrowing costs.
15 The relationship between the rating agencies
16 and Commissions is somewhat circular. Parties in cases
17 before the Commission utilize ratings and rating agency
18 reports to evaluate external views of the Company and
19 make recommendations to the Commission on the return on
20 equity. Rating agencies evaluate Commission orders to
21 determine how decisions impact earnings volatility.
22 Orders that provide rate or regulatory guarantees, or
23 establish mechanisms to adjust rates, reduce volatility
24 associated with that limited area. Orders that deny
25 recovery often increase volatility and risk.
CASE NO. IPC-E-07-812/10/07 CARLOCK, T (Di) 18
STAFF
1
2 agency review and may impact ratings. If the Company is
Commission decisions are a piece of the rating
3 downgraded, borrowing costs and investor supplied capital
4 costs increase resulting in increased costs to the
5 Company and customers.
6 In this case, Staff's recommendations do not
7 accept the Company's requested forecast test year, but
8 they do expand on historical recovery approaches without
9 violating regulatory principles. Therefore, Staff's
10 recommendations reduce volatility but not as far as the
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11 Company might believe will occur with its request.
Q.Does this conclude your direct testimony in
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13 this proceeding?
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A.Yes, it does.
CASE NO. IPC-E-07-812/10/07 CALOCK, T (Di) 19
STAFF
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 10TH DAY OF DECEMBER 2007,
SERVED THE FOREGOING DIRECT TESTIMONY OF TERR CARLOCK, IN CASE
NO. IPC~E~07~8, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
BARTON L KLINE
LISA D NORDSTROM
IDAHO POWER COMPANY
POBOX 70
BOISE ID 83707~0070
EMAIL: bklineCiidahopower.com
InordstromCiidahopower. com
PETER J RICHARDSON
RICHARDSON & O'LEARY
PO BOX 7218
BOISE ID 83702
EMAIL: peterCirichardsonandolear.com
ERIC L OLSEN
RACINE OLSON NYE BUDGE & BAILEY
PO BOX 1391
POCATELLO ID 83204
EMAIL: eloCiracinelaw.net
MICHAEL L KURTZ ESQ
KURT J BOEHM ESQ
BOEHM KURTZ & LOWRY
36 E 7TH ST SUITE 1510
CINCINATI OH 45202
EMAIL: mkurtzCiBKLlawfrm.com
kboehmCiBKLlawfirm.com
DENNIS E PESEAU PH.D.
UTILITY RESOURCES INC
1500 LIBERTY ST SUITE 250
SALEM OR 97302
EMAIL: dpeseauCiexcite.com
JOHN R GALE
VP - REGULATORY AFFAIRS
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707~0070
EMAIL: rgaleCiidahopower.com
DR DON READING
6070 HILL ROAD
BOISE ID 83703
EMAIL: dreadingCßmindspring.com
ANTHONY Y ANKEL
29814 LAKE ROAD
BAY VILLAGE OH 44140
EMAIL: tonyCßyankel.net
CONLEY E WARD
MICHAEL C CREAMER
GIVENS PURSLEY LLP
PO BOX 2720
BOISE ID 83701~2720
EMAIL: cewCßgivenspursley.com
LOTH COOKE
UNITED STATES DEPARTMENT OF
ENERGY
1000 INDEPENDENCE AVE SW
WASHINGTON DC 20585
EMAIL: lot.cookeCßhq.doe.gov
CERTIFICATE OF SERVICE
DALE SWAN
EXETER ASSOCIATES INC
5565 STERRTT PL SUITE 310
COLUMBIA MD 21044
EMAIL: dswanCßexeterassociates.com
(ELECTRONIC COPIES ONLY)
Dennis Goins
E~ Mail: dgoinspmgCßcox.net
Arhur Perr Bruder
E~Mail: arthur.bruderCßhg.doe.gov
CERTIFICATE OF SERVICE