HomeMy WebLinkAbout20081024Carlock Direct.pdfBEFORE THE RECE r,':f".: .,. "I
ZOOS OCT 21l PM 4: 55
IDAHO PUBLIC UTILITIES COMMIS~\9tI j~U~~¡r~c;,nN
U'TII \ ¡IL.q cUr,n,"H'-'....V'1 'f:.. .~l-'li v
IN THE MATTER OF THE APPLICATION )
OF IDAHO POWER COMPANY FOR ) CASE NO.IPC-E-08-10
AUTHORITY TO INCREASE ITSRATES )
AND CHARGES FOR ELECTRIC SERVICE )
TO ELECTRIC CUSTOMERS IN THE STATE)OF IDAHO. )
)
)
)
DIRECT TESTIMONY OF TERRI CARLOCK
IDAHO PUBLIC UTILITIES COMMISSION
OCTOBER 24, 2008
1
3
2 record.
Q.Please state your name and address for the
A.My name is Terri Carlock. My business address
5
4 is 472 West Washington Street, Boise, Idaho.
6
Q.By whom are you employed and in what capacity?
A.I am the Deputy Administrator of the Utilities
7 Division at the Idaho Public Utilities Commission. I am
8 responsible for the Accounting/Audit Section and
9 coordinating Staff's policy positions with Staff
10 Administrator Randy Lobb.
11 Q.Please outline your educational background and
13
12 experience.
A.I graduated from Boise State University in
14 1980, with B.B.A. Degrees in Accounting and Finance. I
15 have attended various regulatory, accounting, rate of
16 return, economics, finance, and ratings programs ~ I am
17 currently the Vice-Chair of the National Association of
18 Regulatory Utilities Commissioners (NARUC) Staff
19 Subcommittee on Accounting and Finance. I previously
20 chaired the NARUC Staff Subcommittee on Economics and
21 Finance for more than 3 years. Under this subcommittee,
22 I also chaired the Ad Hoc Committee on Diversification.
23 I have been a presenter for the Institute of Public
24 Utili ties at Michigan State Uni versi ty and for many other
25 conferences. Since joining the Commission Staff in May
CASE NO. IPC-E- 08 - 1010/24/08 CARLOCK, T (Di) 1
STAFF
1 1980, I have participated in audits, performed financial
2 analysis on various companies, and have presented
3 testimony before this Commission on numerous occasions.
4 Q.What is the purpose of your testimony in this
5 proceeding?
6 A.The purpose of my testimony is to present the
7 Staff's recommendation related to the overall cost of
8 capital for Idaho Power Company to be used in the revenue
9 requirement in this case. I will address the appropriate
10 capital structure, cost rates and the overall rate of
11 return.
12 Q.Please summarize your testimony.
13 A.In my testimony on the overall rate of
14 return, I am recommending a return on common equity 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 7.68% - 8.18% with a point estimate of
18 8.057% to be applied to the rate base for the test year.
19 Q.Are you sponsoring any exhibits to accompany
20 your testimony?
21 A.Yes, I am sponsoring Exhibit No. 128 consisting
22 of 3 schedules.
23 Q.Have you reviewed the testimony and exhibits of
24 Idaho Power witnesses Avera and Steven Keen associated
25 with the return components?
CASE NO. IPC-E-08-1010/24/08 CARLOCK, T (Di) 2
STAFF
1 A.Yes. Much of the theoretical approach used by
2 witnesses Avera and Steven Keen in their testimonies and
3 exhibits is generally the same as I have used. My
4 judgment in some areas of application results in
5 different outcomes.
6 Q.What legal standards have been established for
8
7 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 anduncertainties ¡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
CASE NO. IPC-E-08-1010/24/08 CARLOCK, T (Di) 3
STAFF
1 reasonable at one time and become too high or
too low by changes affecting opportunities
for investment, the money market and businessconditions generally.
2
3
4 .
The Court stated in FPC v. Hope Natural Gas Company, 320
5 u.s. 591, 603, 64 S.Ct. 281, 88 L.Ed. 333 (1944):
6 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
capital costs of the business. These include
service on the debt and dividends on thestock.
7
8
9
10 . .. 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.)
11
12
13
14 The Supreme Court decisions in Bluefield Water
15 Works and Hope Natural Gas have been affirmed in In re
16 Permian Basin Area Rate Case, 390 U.S. 747, 88 S.Ct 1344,
17 20 L.Ed 2d 312 (1968), and Duquesne Light Co. v. Barasch,
18 488 U. S. 299, 109 S.Ct. 609, 102 L.Ed.2d. 646 (1989).
19 The Idaho Supreme Court has also adopted the principles
20 established in Bluefield Water Works and Hope Natural
21 Gas. See In re Mountain Sta tes Tel. & Tel. Co. 76 Idaho
22 474, 284 P.2d 681 (1955) i General Telephone Co. v. IPUC,
23 109 Idaho 942, 712 P. 2d 643 1986) i Hayden Pines Wa ter
24 Company v. IPUC, 122 ID 356, 834 P.2d 873 (1992).
25 As a result of these United States and Idaho
CASE NO. IPC-E-08-10
10/24/08 CARLOCK, T (Di) 4
STAFF
1 Supreme Court decisions, three standards have evolved for
2 determining a fair and reasonable rate of return:
3 (1) The Financial Integrity or Credit Maintenance
4 Standardi (2) the Capital Attraction Standardi and,
5 (3) The Comparable Earnings Standard. If the Comparable
6 Earnings Standard is met, the Financial Integrity or
7 Credi t Maintenance Standard and the Capital At traction
8 Standard will also be met, as they are an integral part
10
9 of the Comparable Earnings Standard.
12
11 recommendation?
Q.Have you considered these standards in your
A.Yes. These cri teria have been thoroughly
13 considered in the analysis upon which my recommendations
14 are based. It is also important to recognize that the
15 fair rate of return that allows the utility company to
16 maintain its financial integrity and to attract capital
17 is established assuming efficient and economic
18 management, as specified by the Supreme Court in
20
19 Bl uefield Wa ter Works.
Q.Please summarize the parenti subsidiary
22
21 relationships for Idaho Power Company.
A.Idaho Power i s common stock is not traded.
23 Idaho Power Company is a wholly owned subsidiary of
24 IDACORP. Due to this parent/subsidiary relationship
25 there is no direct equity market data available for
CASE NO. IPC-E-08-1010/24/08 CARLOCK, T (Di) 5
STAFF
1 utility operations at Idaho Power. Idaho Power is the
3
2 primary subsidiary of IDACORP at this time.
Q.Why is the return on equity calculation
4 important?
5 A.The return on equity and the overall rate of
6 return provides the method for calculating the return
7 authorized. This return provides the level of
8 compensation to investors for the use of the capital
9 invested in the utility plant and equipment to serve
10 customers. The actual return investors receive is
11 derived from dividends and growth in stock price when the
12 shares are sold. Since the direct required return is not
13 a contractual calculation, the authorized return on
15
14 equi ty serves as the proxy.
Q.What approach have you used to determine the
17
16 cost of equity for Idaho Power?
A.I have primarily evaluated two methods: the
18 Discounted Cash Flow (DCF) method and the Comparable
20
19 Earnings method.
Q.Please explain the Comparable Earnings method
21 and how the cost of equity is determined using this
23
22 approach.
A.The Comparable Earnings method for determining
24 the cost of equity is based upon the premise that a given
25 investment should earn its opportunity costs. In
CASE NO. IPC-E-08-1010/24/08 CARLOCK, T (Di) 6
STAFF
1 competitive markets, if the return earned by a firm is
2 not equal to the return being earned on other investments
3 of similar risk, the flow of funds will be toward those
4 investments earning the higher returns. Therefore, for a
5 utility to be competitive in the financial markets, it
6 should be allowed to earn a return on equity equal to the
7 average return earned by other firms of similar risk.
8 The Comparable Earnings approach is supported by the
9 Bluefield Water Works and Hope Natural Gas decisions as a
10 basis for determining those average returns.
11 Industrial returns tend to fluctuate with
12 business cycles, increasing as the economy improves and
13 decreasing as the economy declines. Utility returns are
14 not as sensitive to fluctuations in the business cycle
15 because the demand for utility services generally tends
16 to be more stable and predictable. However, returns have
17 fluctuated since 2000 when prices in the electricity
18 markets dramatically increased. Electricity prices have
19 not seen the dramatic spikes lately so earnings are more
20 stable.
21 Q.Please evaluate interest rate trends.
22 A.The prime interest rate has decreased in the
23 last year since Idaho Power's last rate case from 7.75%
24 to the current rate of 4.5%. The federal funds rate and
25 other rates have also decreased this year.
CASE NO. IPC-E-08-1010/24/08 CARLOCK, T (Di) 7
STAFF
1 Q.Please provide the current index levels for the
2 Dow Jones Industrial Average and the Dow Jones Utility
3 Average.
4 A.The Dow Jones Industrial Average (DJIA) closed
5 at 8519.21 on October 23, 2008. The DJIA all-time high
6 of 14,000 was reached on July 19, 2007. The Dow Jones
7 Utility Average closed at 348.10 on October 23, 2008. The
8 52-week high was 552.74 for the Dow Jones Utility
10
9 Average.
11 industrials and utilities.
Q.Please explain the risk differentials between
12 A. Risk is a degree of uncertainty relative to a
13 company. The lower risk level associated with utilities
14 is attributable to many factors even though the
15 difference is not as great as it used to be. Utilities
16 continue to have limited competition for distribution of
17 utility services within the certificated area. With
18 limited competition for regulated services, there is less
19 chance of losses related to pricing practices, marketing
20 strategy and advertising policies. The competitive risks
21 for electric utilities have changed with increasing non-
22 utili ty generation, deregulation in some states, open
23 transmission access, and changes in electricity markets.
24 However, competi ti ve risks are limited for Idaho Power
25 utility operations. The demand for electric utility
CASE NO. IPC-E-08-1010/24/08 CARLOCK, T (Di) 8
STAFF
1 services is relatively stable and certain or increasing
2 compared to that of unregulated firms and even other
3 utili ty industries.
4 Competitive risks continue to be lower for
5 Idaho Power than for many other electric companies
6 primarily because of the low-cost source of power, the
7 low retail rates compared to national averages, the PCA,
8 and the FCA. The proposed changes to the PCA (Case No.
9 IPC-E-08-19) on the sharing percentage and the load
10 growth adjustment are seen as positive by institutional
11 investors and the investment community. This case
12 presents the settlement of parties, but has not been
13 decided by the Commission. The risk differential between
14 Idaho Power and other electric utili ties is based on the
15 resource mix and the cost of those resources. All
16 resource mixes have risks specific to resources chosen.
17 The demand for electric utility services of Idaho Power
18 is increasing at predictable rates. This low demand risk
19 is partially due to the low embedded power cost, the risk
20 management program to manage power costs and the customer
21 mix of the power users.
22 Under regulation, utilities are generally
23 allowed to recover through rates, reasonable, prudent and
24 justifiable cost expenditures related to regulated
25 services. Unregulated firms have no such assurance.
CASE NO. IPC-E-08-10
10/24/08 CARLOCK, T (Di) 9
STAFF
1 Utilities in general are sheltered by regulation for
2 reasonable cost recovery risks, even if it isn' t 100%,
3 making the average utility less risky than the average
4 unregulated industrial firm.
5 As everyone is aware, current market trends and
6 earnings levels have dramatically declined. I believe
7 Idaho Power continues to be in a better position than
8 many to fund its capital requirements. The current
9 credit and investment markets are making capitalization
10 more difficult for all. In my opinion, as investors
11 reevaluate their investment portfolios, utility stocks
12 with the primary operation being the utilitYi will be
13 favored over higher risk operations. On July 10, 2008
14 Idaho Power issued 10 -year First Mortgage Bonds at
15 6.025%. This issuance meets current needs at a
16 reasonable rate and places Idaho Power in a reasonable
17 position to meet near-term needs with its credit lines.
18 Company credit lines extend through 2012.
19 Nationally the electric utility industry as
20 shown on Exhibit No. 128, Schedule 1 has seen common
21 equity ratios decline from 46% at 12/31/2006 to 45% at
22 12/31/2007 and 44% at 6/30/2008. This means long-term
23 debt ratios increased over the respective time periods i
24 54%, 55% and 56%. Company witness Avera, Exhibit No. 26
25 shows similar historical averages with 43.3% equity and
CASE NO. IPC-E-08-10
10/24/08
CARLOCK, T (Di) 10
STAFF
1 55.7% debt. This exhibit also shows proj ected average
2 ratios of 47.6% equity and 51.9% debt. The capital
3 structure recommended for Idaho Power Company is
4 approximately 49% common equity and 51% long-term debt.
5 The recommended equity ratios for Idaho Power are better
6 than the national average, historical and projected,
7 reflecting lower risk for Idaho Power.
8 Authorized returns by State Commissions for
9 electric utilities during 2007 and the First Quarter of
10 2008 range from 9.1% in New York to 11.25% in Georgia.
11 During this period, 25 states decided cases authorizing
12 rates of return on equity. Many of the decisions, 14 out
13 of 25 or 56%, authorized a return on equity between 9.5%
14 and 10.5%.
15 Considering all of these comparisons, I believe
16 a reasonable return on equity attributed to Idaho Power
17 is 9.5% - 10.5% under the Comparable Earnings method.
18 Q. You indicated that the Discounted Cash Flow
19 method is utilized in your analysis. Please explain this
20 method.
21 A.The Discounted Cash Flow (DCF) method is based
22 upon the theory that (1) stocks are bought for the income
23 they provide (i. e., both dividends and/or gains from the
24 sale of the stock), and (2) the market price of stocks
25 equals the discounted value of all future incomes. The
CASE NO. IPC-E-08-1010/24/08 CARLOCK, T (Di) 11
STAFF
1 discount rate, or cost of equity, equates the present
3
2 value of the stream of income to the current market price
4
5
6
7
8
9
10
11
of the stock.The formula to accomplish this goal is:
D D D P
1 2 N N
Po =PV =-------+-------+. . . +------+------
(l+ks) 1 (l+ks) 2 (l+ks)N (l+ks) N
Po =
D =
ks =
N =
Current Price
Dividend
Capitalization Rate, Discount Rate, or Required
Rate of Return
Latest Year Considered
12 key factor that must be estimated in this approach. Some
The pattern of the future income stream is the
13 simplifying assumptions for ratemaking purposes can be
14 made without sacrificing the validity of the results.
15 Two such assumptions are:( 1) dividends per share grow
16 at a constant rate in perpetuity and (2) prices track
17 earnings. These assumptions lead to the simplified DCF
18 formula, where the required return is the dividend yield
19 plus the growth rate (g):20 D
21
22
ks = + g
Po
Q.Have you factored flotation costs in with your
24
23 cost of capital analysis?
A.Yes, I have considered direct flotation costs
25 in my analysis by increasing the dividend yield component
CASE NO. IPC-E-08-1010/24/08 CARLOCK, T (Di) 12
STAFF
1 of the DCF analysis. Because only direct costs should be
2 considered, I have used a flotation factor of 2% assigned
3 to the utility operations. This practice continues to be
4 reasonable with recent issuances and expected near-term
5 issuances placed though the Company's Investment Plans
6 where the actual flotation costs are substantially lower
7 than direct market issuances. I have therefore adjusted
8 the DCF formula to include the direct flotation costs as
9 "df" .
10
11
Dks = ( - - - (1 + df)) + g
Po
12 Q.What is your estimate of the current cost of
13 capi tal for Idaho Power using the Discounted Cash Flow
14 method?
15 A.The current cost of equity capital for Idaho
16 Power, using the Discounted Cash Flow method with IDACORP
17 data, is between 8.9% - 9.8%. The low range of 8.9% is
18 calculated using an analyst target stock price of $31 and
19 the growth rate of 5%.
20 (($1.20/$31) 1.02) +5%
21 The high range of 9.8% is calculated using a current
22 stock price of $25.64 and a growth rate of 5%.
23 (($1.20/$25.64)1.02)+5%
24 Due to ongoing capital requirements, I believe a dividend
25 yield of 4.4% with an average growth rate of 5% is
CASE NO. IPC-E-08-10
10/24/08 CARLOCK, T (Di) 13
STAFF
1 reasonable and representative resulting in a DCF return
3
2 on equity of 9.4%.
4
Q.How is the growth rate (g) determined?
A.The growth rate is the factor that requires the
5 most extensive analysis in the DCF method. It is
6 important that the growth rate used in the model be
7 consistent with the dividend yield so that investor
8 expectations are accurately reflected and the growth rate
9 is not too large or too small.
10 I have used an expected growth rate of 4% - 6%.
11 This expected growth rate was derived from an analysis of
12 various historical and proj ected growth indicators,
13 including growth in earnings per share, growth in cash
14 dividends per share, growth in book value per share,
15 growth in cash flow and the sustainable growth.
16 Q.What are the costs related to the capital
18
17 structure for debt?
The cost of debt of 5.927% is shown on ExhibitA.
19 No. 128, Schedule 2. The actual debt costs vary slightly
20 from this projection but result in an insignificant,
21 0.001%, change in the weighted debt cost. This
22 information is not yet public so I have not used it due
23 to the minor difference.
24 Q.What capital structure has Staff used for Idaho
25 Power to determine the overall cost of capital?
CASE NO. IPC-E-08-1010/24/08 CARLOCK, T (Di) 14
STAFF
1 A.Exhibi t No. 128, Schedule 3 shows the capital
2 structure, debt cost utilized and the overall rate of
3 return. Staff has accepted the estimated December 31,
4 2008 capital structure and debt cost as shown on Company
5 wi tness Keen Exhibit Nos. 27 and 28 as reasonable. The
6 actual capital structure and debt cost rates at June 30,
7 2008 and September 30, 2008 vary slightly. The current
8 market availability of funds will impact the capital
9 structure with slightly more debt being utilized so the
10 capital structure of 50.7% debt and 49.3% equity as shown
11 on Exhibit No. 128, Schedule 3 is reasonable.
12 Q.You indicated the cost of common equity range
13 for Idaho Power is 9.5% - 10.5% under the Comparable
14 Earnings method and 8.9% - 9.8% under the Discounted Cash
15 Flow method. What is the cost of common equity capital
16 you are recommending?
17 A.The fair and reasonable cost of common equity
18 capital I am recommending for Idaho Power and is in the
19 range of 9.5% - 10.5%. Although any point within this
20 range is reasonable, the return on equity granted would
21 not normally be at either extreme of the fair and
22 reasonable range. I utilized a point estimate of 10.25%
23 in calculating the overall rate of return for the revenue
24 requirement.
25 Q.What is the basis for your point estimate being
CASE NO. IPC-E-08-1010/24/08 CARLOCK, T (Di) 15
STAFF
2
1 10.25% when your range is 9.5% - 10. 5%?
3 utilized is based on a review of market data and
A.The 10.25% return on equity point estimate
4 comparables, average risk characteristics for Idaho
5 Power, operating characteristics and the capital
6 structure. A point above the midpoint recognized the
7 requirement for system capital investments to serve
9
8 customers.
11
10 recommended for Idaho Power?
Q.What is the overall weighted cost of capital
A.The overall weighted cost of capital
12 recommended by Staff is in the range of 7.68% - 8.18%.
13 For use in calculating the revenue requirement, a point
14 estimate consisting of a return on equity of 10.25% and a
15 resulting overall rate of return of 8.057% was utilized
16 as shown on Schedule 3, Exhibit No. 128.
17 Q.Does this conclude your direct testimony in
19
18 this proceeding?
20
21
22
23
24
25
A.Yes, it does.
CASE NO. IPC-E-08-1010/24/08
CARLOCK, T (Di) 16
STAFF
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Exhibit No. 128
Case No. IPC-E-08-1O
T. Carlock, Staff
10/24/08 Schedule 1 of 3
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IDAHO POWER COMPANY
COMPOSITE COST OF CAPITAL
December 31, 2008 Capitalization
(1 )(2)(3)(4)(5)
Line Capitalization Structure Embedded Weighted
No Amount Percent Cost Cost
1 Long-term Debt 1,240,460,000 50.730%5.927%3.007%
2 Preferred Stock 0 0.000%0.000%0.000%
3 Common Equity 1,204,781,346 49.270%10.250%5.050%
4 Total Capitalization $2,445,241,346 100.000%8.057%
Exhibit No. 128
Case No. IPC-E-08-10
T. Carlock, Staff
10/24/08 Schedule 3 of 3
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 24TH DAY OF OCTOBER 2008,
SERVED THE FOREGOING DIRECT TESTIMONY OF TERR CARLOCK, IN CASE
NO. IPC-E-08-1O, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
BARTON L KLINE
LISA D NORDSTROM
DONOV AN E WALKER
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: bkline(iidahopower.com
lnordstrom(iidahopower .com
dwalker(iidahopower .com
PETER J RICHARDSON
RICHARDSON & O'LEARY
PO BOX 7218
BOISE ID 83702
E-MAIL: peter(irichardsonandoleary.com
RANDALL C BUDGE
ERICLOLSEN
RACINE OLSON NYE ET AL
PO BOX 1391
POCATELLO ID 83204-1391
E-MAIL: rcb(iracinelaw.net
elo(iracinelaw.net
MICHAEL L KURTZ ESQ
KURT J BOEHM ESQ
BOEHM KURTZ & LOWRY
36 E SEVENTH ST STE 1510
CINCINATI OH 45202
E-MAIL: mkurz(iBKLlawfrm.com
kboehm(iBKLlawfrm.com
BRAD MPURDY
ATTORNEY AT LAW
2019N 17TH ST
BOISE ID 83702
E-MAIL: bmpurdy(ihotmail.com
JOHNRGALE
VP - REGULATORY AFFAIRS
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: rgale(iidahopower.com
DR DON READING
6070 HILL ROAD
BOISE ID 83703
E-MAIL: dreading(imindspring.com
ANTHONY Y ANKEL
29814 LAKE ROAD
BAY VILLAGE OH 44140
E-MAIL: yanel(iattbi.com
KEVIN HIGGINS
ENERGY STRATEGIES LLC
PARKS IDE TOWERS
215 S STATE ST STE 200
SALT LAKE CITY UT 84111
E-MAIL: khiggins(ienergystrat.com
LOT H COOKE
ARTHUR PERRY BRUDER
UNITED STATE DEPT OF ENERGY
1000 INDEPENDENCE AVE SW
WASHINGTON DC 20585
E-MAIL: lot.cooke(ihq.doe.gov
arhur. bruder(ihq.doe. gOY
CERTIFICATE OF SERVICE
DWIGHT ETHERIDGE
EXETER ASSOCIATES INC
5565 STERRTT PLACE, SUITE 310
COLUMBIA MD 21044
E-MAIL: detheridgeØ)exeterassociates.com
DENNIS E PESEAU, Ph.D.
UTILITY RESOURCES INC
1500 LIBERTY STREET SE, SUITE 250
SALEM OR 97302
E-MAIL: dpeseauØ)excite.com
CONLEY E WARD
MICHAEL C CREAMER
GIVENS PURSLEY LLP
601 W BANNOCK ST
PO BOX 2720
BOISE ID 83701-2720
E-MAIL: cewØ)givenspursley.com
KEN MILLER
CLEAN ENERGY PROGRAM DIRECTOR
SNAKE RIVER ALLIANCE
PO BOX 1731
BOISE ID 83701
E-MAIL: kmilerØ)snakeriverallance.org
ygWl~.~
SECRETARY
CERTIFICATE OF SERVICE