20081024Anderson Direct.pdf

BEFORE THE RECEIVED'
2089 OCT 2t. PH 3: 21
IDAHO PUBLIC UTILITIES COMMISSIO~D.AHO PUBLIC. u
UTIliTIES COMMiSSiOn
I.N THE MATTER OF THE APPLICATION )
OF IDAHO POWER COMPANY FOR ) CASE NO. IPC-E-08-10
AUTHORITY TO INCREASE ITS RATES )
AND CHARGES FOR ELECTRIC SERVICE )
TO ELECTRIC CUSTOMERS IN THE STATE )OF IDAHO. )
)
)
)
DIRECT TESTIMONY OF LYNN ANDERSON
IDAHO PUBLIC UTILITIES COMMISSION
OCTOBER 24, 2008
1
2 record.
Q.Please state your name and business address for the
3 A.My name is Lynn Anderson and my business address is
4 472 West Washington Street, Boise, Idaho.
5
6
Q.By whom are you employed and in what capacity?
A.I am employed by the Idaho Public Utilities
7 Commission as a Staff economist.
8
9
Q.What are your duties with the Commission?
A.Currently, my primary duties are evaluating energy
10 efficiency policy, opportunities, barriers, efforts and cost-
11 effectiveness, the results of which are used to make
12 recommendations to the Commission and other entities.
13 Additional duties include investigating utility applications,
14 customer petitions and conducting general research.
15
16 professional background?
q.Would you please outline your academic and
17 A.I have a Bachelor of Science degree in government
18 and a Bachelor of Arts degree in sociology, both from Idaho
19 State Dni versi ty where I also studied economics and
20 architecture. I studied engineering at Northwestern
21 University and Brigham Young University and public
22 administration and quantitative analysis at Boise State
23 University.
24 I have attended many training seminars and
25 conferences regarding utility regulation, operations,
CASE NOS. IPC-E-08-1010/24/08 ANDERSON, L. (Di) 1
STAFF
1 forecasting, marketing and program evaluation, including
2 Lawrence Berkeley Laboratory's Advanced Integrated Resource
3 Planning seminar in 1994, the Northwest Public Power
4 Association's Troubleshooting Residential Energy Use course
5 in 2001, and the International Energy Program Evaluation
6 conferences in 2003, 2005 and 2007.
7 I began my employment with the Commission in 1980
8 as a utility rate analyst. In 1983 I was appointed to the
9 position of telecommunications section supervisor and in 1992
10 I was appointed to my present position as an economist. In
11 that capacity I have been a Staff representative to the
12 Northwest Energy Efficiency Alliance, Avista Utilities'
13 External Energy Efficiency Board, Idaho Power's Energy
14 Efficiency Advisory Group, the Northwest Power and
15 Conservation Council's Demand Response Ini tiati ve, the Energy
16 Efficiency and Conservation Task Force of the Idaho Strategic
17 Energy Alliance, and to subgroups working on issues within
18 the National Action Plan for Energy Efficiency.
19 Since 1999 I have served the Commission as a policy
20 strategist for electricity and telecommunications issues on
21 an as-needed basis.
22 From 1975 to 1980 I was employed by the Idaho
23 Transportation Department where I performed benefit/cost
24 analyses of highway safety improvements and other statistical
25 analyses.
CASE NOS. IPC-E-08-1010/24/08 ANERSON, L. (Di) 2
STAFF
1 Q.What is the purpose of your testimony?
2 A.The purposes of my testimony are to provide
3 information regarding Idaho Power's efforts to promote energy
4 efficiency (aka demand-side management or DSM) and to
5 recommend that the Commission defer a prudency finding for
6 Idaho Power's DSM expenses until such time that the Company
7 is able to provide a more comprehensive evaluation package of
8 its DSM programs and efforts.
9 I also present the Staff's recalculation of the
10 fixed cost adjustment (FCA) mechanism's fixed costs per
11 customer (FCC) and fixed costs per energy (FCE).
12 Prudeney of Effieieney/DSM Expenses
13 Q.Does Idaho Power's Application or the pre-filed
14 testimony of any witness in this case ask the Commission to
15 determine prudency of the Company's past energy efficiency or
16 demand-side management (DSM) expenses?
17 A.No, there is no such request. However, Idaho Power
18 witness Theresa Drake, in pre-filed testimony and exhibits,
19 provided a general overview of the Company's rapid expansion
20 of energy efficiency personnel and programs, its current
21 energy efficiency programs, and total annual energy and peak
22 demand savings estimated to have been achieved from DSM
23 programs in 2007. Neither the Application nor Ms. Drake
24 provided much information about cost-effectiveness or prior
25 years' estimated DSM achievements, although Ms. Drake did
CASE NOS. IPC-E-08-10
10/24/08 ANDERSON, L. (Di) 3
STAFF
1 mention that Idaho Power's Demand-Side Management 2007 Annual
2 Report was filed with the Commission on March 14, 2008.
3 Q.Were you able to evaluate prudency of Idaho Power's
4 2003-2007 DSM expenditures based on the Company's filing?
5 No, there was not sufficient information in theA.
6 filing to assess DSM prudency. Consequently, many production
7 requests and follow-up questions needed to be asked, but it
8 became apparent that the Company does not yet have sufficient
9 information to fully justify a prudency determination by the
10 Commission.
11 Q.On page 12, lines 12 and 13, of Ms. Drake's pre-
12 filed testimony are statements that Idaho Power's DSM
13 programs saved 91,145 megawatt-hours (MWh) and reduced peak
14 load by 57 megawatts in 2007. Are the veracities of those
15 numbers readily verifiable by Company information provided in
16 this case?
17 A.No. However, they are consistent with the savings
18 reported by Idaho Power on page 56 (in Appendix 3) of its DSM
19 2007 Annual Report. For clarification, it is worth noting
20 that the 91,145 MWh were the annual savings reported as
21 occurring due to program efforts in 2007, presumably less
22 than 50% of which would actually be saved in 2007. The
23 reported energy savings occurring in 2007 due to the
24 Company's DSM efforts from 2003 through 2007 are probably
25 close to, but less than, the sum of each prior year's annual
CASE NOS. IPC-E-08-10
10/24/08 ANDERSON, L. (Di) 4
STAFF
1 savings plus about one-half of 2007' s annual savings. Those
2 annual savings numbers are shown on page 70 of the same 2007
3 DSM Report. The sum of 2003-2006's savings plus half of
4 2008' s total to about 190,000 MWh saved in 2007, reportedly
5 as a result of Idaho Power's DSM efforts from 2003 through
6 2007.
7 More to the point of the question though, is
8 whether Idaho Power has provided sufficient measurement and
9 evaluation documentation of its energy savings and peak load
10 reduction estimates. The answer to that question is that the
11 Company has completed a few important program evaluations
12 and, I believe, is earnestly working on a more comprehensive
13 overall evaluation of programs. In response to Staff
14 Production Request No. 94, the Company stated that it hired a
15 full-time Energy Efficiency Evaluator in 2007 and "(p) art of
16 the duties associated with this position has been to initiate
17 a systematic review and evaluation of each demand side
18 management program Idaho Power offers." The response
19 continues with a description of the many evaluations that are
20 currently underway and concluded with the statement "As
21 factors change, or new data is obtained, these (cost-
22 effectiveness) studies are revised and updated." Thus,
23 although the new, full-time evaluator was not hired until
24 December 2007, it seems likely that within the next year or
25 so Idaho Power will have substantially completed reasonably
CASE NOS. IPC-E-08-1010/24/08 ANDERSON, L. (Di) 5
STAFF
1 comprehensive evaluations of its DSM programs and portfolio,
2 which should facilitate verification of cost-effectiveness
3 and prudency of planning, implementation and evaluation.
4 Q.Is reasonable proof of DSM cost-effectiveness
5 compared to the least-cost supply-side resource both
6 necessary and sufficient for determination of the Company's
7 prudency in planning, implementing and evaluating its
8 programs?
9 A.No. While substantially proving actually achieved
10 cost-effectiveness is an important goal, it is generally
11 recognized that some prudent utility DSM programs will not
12 achieve this standard, due to circumstances beyond utility
13 control or other factors. Furthermore, while achieving DSM
14 cost-effectiveness vis-a-vis supply-side alternatives is
15 important, it is just as important that the DSM alternatives
16 as implemented be as cost-effective as practicable from the
17 utility perspective. This does not mean that other goals
18 (e. g. customer class equity, intra-class distribution, and
19 total resource, participant and non-participant cost-
20 effectiveness) are not also important, but rather that within
21 the bounds of due consideration of all goals, the least-cost
22 DSM implementation al ternati ve is the most prudent. In other
23 words, it is not prudent to pay more for a DSM resource than
24 is necessary.
25 Q.Putting aside the question of prudency, are Idaho
CASE NOS. IPC-E-08-10
10/24/08 ANDERSON, L. (Di) 6
STAFF
1 Power's DSM programs cost-effective compared to supply-side
3
2 resources?
A.I believe that most of the Company's DSM programs
4 will likely prove to be cost-effective compared to supply-
5 side resources. Idaho Power generally selects its DSM
6 programs based, in part, on expected cost-effectiveness from
7 the total resource and utility perspectives. Exhibit No.
8 148, from the Company's response to Staff's Production
9 Request No. 96, shows preliminarily cost-effectiveness
10 analyses from those two perspectives, compared only to
11 supply-side resources (i.e. not compared to alternative DSM
12 costs). It is important to note that Staff considers these
13 analyses as preliminary and in need of further refinement.
14 For example, it is not entirely clear in these analyses how
15 net-to-gross factors were included in the benefit
16 calculations, or whether non-electricity savings are
17 included, or whether tax credits are assumed to reduce total
18 resource costs. Staff expects such intricacies of actual
19 achieved program cost-effectiveness will become more
20 transparent as many of the Company's formal program
21 evaluations are completed.
22 Q.Given your recommendation that the Commission defer
23 its determination regarding Idaho Power's DSM prudency, why
24 is it important to discuss cost-effectiveness and prudency
25 issues?
CASE NOS. IPC-E-08-1010/24/08 ANDERSON, L. (Di) 7
STAFF
1 A.As the costs of supply-side resources have risen,
2 the value of demand-side resources has also risen, the
3 consequence being that utilities are spending many millions
4 of dollars more on DSM programs. Gi ven the much higher level
5 of DSM expenditures, it is increasingly important that the
6 utilities, other parties and the Commission have clear
7 concepts of what constitutes DSM prudency.
8 Idaho Power's original and supplemental responses
9 to Staff's Production Request Nos. 99 and 100 demonstrate the
10 need for "prudency" clarification. For example, in response
11 to Staff's request that Idaho Power provide examples where
12 the Company chose least-cost DSM alternatives, the Company
13 did not provide any such examples. Instead, it said that it
14 considers alternative demand-side costs and reiterated its
15 prior response that priorities in addition to cost-
16 effecti veness are that DSM programs have a customer focus, be
17 equitably distributed, and be earnings neutral.
18
20
19 Commission?
Q.Is earnings neutrality an important DSM goal of the
A.Not exactly. The lack of earnings neutrality was
21 recognized by the Commission as a DSM concern in its approval
22 of Idaho Power's 3-year pilot for a fixed-cost adjustment
23 (FCA) mechanism, but I'm not aware of any Commission Orders
24 stating utility DSM programs should be earnings neutral. In
25 fact, in Order No. 22299 issued in 1989, the Commission said
CASE NOS. IPC-E-08-10
10/24/08 ANDERSON, L. (Di) 8
STAFF
1 "We certainly do not obj ect to considering lost revenue as
2 one of the many variables to be considered in determining
3 (DSM) price, but we rej ect it as a controlling factor."
4 (p.16).
5 Q.Does Idaho Power currently have a formal business
6 plan for implementing DSM programs?
7 A.No. Idaho Power's last formal business plan for
8 DSM is dated April 15, 2003. In response to Staff's
9 Production Request No. 115, the Company explained its "multi-
10 dimensional approach to DSM business planning," which
11 includes DSM potential studies, long-term IRP planning,
12 strategic planning, budget planning, consultation with the
13 Energy Efficiency Advisory Group (EEAG), and concluding with
14 "governance by the Energy Efficiency Guiding Council." This
15 final decision-making Council is comprised of Idaho Power's
16 senior management and representatives of the Energy
17 Efficiency Department. Although the Company provided some,
18 but not all, minutes of EEAG meetings, it provided no similar
19 records of Energy Efficiency Guiding Council meetings where
20 the final DSM decisions are actually made. While the lack of
21 a current, formal DSM business plan may not necessarily be
22 imprudent, that omission combined with the lack of access to
23 meeting minutes where final DSM decisions are made, results
24 in less decision-making transparency and does raise some
25 concerns.
CASE NOS. IPC-E-08-10
10/24/08 ANDERSON, L. (Di) 9
STAFF
1 Q.What additional information are you providing and
2 why is it important?
3 A.Exhibi t No. 149, copied directly from Idaho Power's
4 Appendix 2 in its 2007 DSM Annual Report, shows the Company's
5 expenses and funding sources for its various DSM efforts in
6 2007. This exhibit provides an indication of program
7 magni tudes and an appreciation for the various and sometimes
8 mixed funding sources, two of which are not under the
9 regulatory authority of the Idaho Commission. However, the
10 amounts shown are neither entirely complete nor 100%
11 accurate. For example, a significant missing piece is the
12 additional $380,000 amount due to the Northwest Energy
13 Efficiency Alliance (NEEA) that was credited from Idaho Power
14 funds being held by NEEA (IPC' s 3rd Supplemental Response to
15 Staff's Production Request No. 89). And the Company noted
16 that relatively minor corrections would be necessary in
17 future DSM Annual Reports (IPC' s 200 Supplemental Response to
18 Staff's Production Response No. 89). Due in part to Idaho
19 Power's late responses to production requests and other Staff
20 priorities, the Company's DSM expenses from 2003 through 2007
21 have not yet been audited.
22 Exhibit No. 150 shows the Company's total system
23 annual direct DSM expenses (including direct overhead),
24 indirect overhead expenses, and total DSM expenses for each
25 year from 2003 through 2007.This exhibit shows two
CASE NOS. IPC-E-08-1010/24/08 ANDERSON, L. (Di) 10
STAFF
1 important trends. First, Idaho Power's DSM programs have
2 been increasing very rapidly - the total DSM expenses in 2007
3 are nearly six times higher than those in 2003. Second, the
4 indirect overhead program expenses increased nearly 10-fold
5 from 2003 to 2007. From just 2006 to 2007, indirect overhead
6 expenses increased 147%, more than four times faster than the
7 33% increase in direct program expenses. Although the
8 disproportionate indirect overhead expense increases are not
9 necessarily alarming, they probably warrant close monitoring.
10 As discussed earlier in my testimony, Idaho Power
11 has only recently begun a more thorough and comprehensive
12 program evaluation process. While this process may further
13 increase indirect as well as direct overhead expenses, it
14 should also provide necessary information for Idaho Power and
15 other parties to better assess actual program implementation
16 processes and results, and for the Company to make
17 improvements to programs, processes and assumptions where the
18 evaluations show such changes are appropriate.
19 Q.Do you have any other concerns regarding Idaho
21
20 Power's DSM prudency?
A.I have quite a few, mostly relatively minor,
22 questions and concerns, many or most of which I expect will
23 be addressed by the Company's completion of program
24 evaluations, or which Staff can otherwise pursue outside this
25 rate case process.
CASE NOS. IPC-E-08-1010/24/08 ANERSON, L. (Di) 11
STAFF
1 Q.Please summarize your recommendations regarding the
2 prudency of Idaho Power's expenses for its energy efficiency
3 efforts from 2003 through 2007.
4 Staff recommends that the Commission deferA.
5 determination of prudency until such time that Idaho Power
6 has sufficiently evaluated its DSM programs and processes and
7 files a request for prudency determination. This filing
8 could occur within a general rate case application, a tariff
9 rider application, or a stand-alone application.
10 Staff further recommends that the Idaho Power
11 should be expected to provide with its filing a reasonable,
12 appropriate and credible evaluation of each DSM program, and
13 an overall evaluation of the Company's DSM decision-making
14 processes, including its use of program evaluations to
15 improve programs and processes. Transparency of financial
16 accounting, data, assumptions, calculations and decision-
17 making is paramount for Staff's and the Commission's
18 investigation of prudency.
20
19 Fixed-Cost Adjustment (FCA) Recalculation
Has the Staff recalculated the fixed cost perQ.
21 customer (FCC) and fixed cost per energy (FCE) for
22 residential and small commercial customer classes as required
23 for continuation of the fixed cost adjustment (FCA) pilot
25
24 mechanism?
A.Yes, this has been done using Staff's proposed
CASE NOS. IPC-E-08-1010/24/08 ANERSON, L. (Di) 12
STAFF
1 revenue requirements and rate designs for Schedules 1, 4, 5
2 and 7 and Idaho Power's model for these calculations as
3 presented by Idaho Power witness Tim Tatum's Exhibit No. 71
4 and explained in his pre-filed testimony on pages 54-60.
5 For residential customers (Sch. 1, 4 and 5),
6 Staff's recalculated fixed cost per customer (FCC) is $428.01
7 per year and the fixed cost per energy (FCE) is 3. 3045ç per
8 kilowatt~hour.
9 For small commercial customers (Sch. 7), Staff's
10 recalculated FCC is $282.05 per year and the FCE is 4. 6167ç
11 per kilowatt-hour.
12 Q.Does this conclude your direct testimony in this
13 proceeding?
14
15
16
17
18
19
20
21
22
23
24
25
Yes, it does.A.
CASE NOS. IPC-E-08-1010/24/08 ANDERSON, L. (Di) 13
STAFF
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Case No. IPC-E-08-10
L. Anderson, Staff
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Ex.hibit Nü:-T48
Case No. IPC-E-08-10
L. Anderson, Staff
10/24/08 Page 3 of 3
Demand-Side Management Idaho Power Company
Appendix 2. 2007 DSM Expenses by Funding Source (Dollars)
Idaho Oregon
Sector/Program Rider Rider SPA IPC Total Program
Energy Efficiency/Demand Response
Residential
AlC Cool Credit...,...........,.., ....,..,...,.... ,. ,.,..2,421,461 0 0 4,692 $2,426,154
Appliance Program ........,......,.... ,.,....,.,..,.,.., .8,746 460 0 69 $9,275
Energy House Calls ...,. ,..........,..... ,.,......,.....251,743 3,349 80,830 450 $336,372
ENERGY STARcI Homes Northwest..:.,.,..,451,775 12,249 0 11,020 $475,044
Heating and Cooling Efficiency,...,... ,...... '....482,051 3,289 0 2,871 $488,211
Oregon Residential Weatherization.,.,....,.,.,0 0 0 3,781 $3,781
Rebate Advantage.,.,..,..,.,..........,.,.........,.,..58,854 4,609 25,073 733 $89,269
ENERGY STARcI Lighting.,..,..........,...,..,..,.,519,818 11,787 15,595 10,445 $557,646
WAQC,..".,.........."..,..........,.,.".".,....,....,.,.,.0 0 28,035 1,295,588 $ 1,323,624
Commercial/Industrial
Commercial Building Effciency..,.,..,.......,.,.,661,485 5,766 0 1,781 $669,032
Easy Upgrades ,.........,.,.........,.....,..,......,.,..,680,376 28,014 0 3,105 $711,494
Oregon Commercial Audit...,..... ,....,...,.,.,. ,.0 1,800 0 181 $1,981
Custom Effciency...,...,.,.,...,..,......,.............,3,032,047 110,634 0 19,185 $3,161,866
Irrigation
Irrigation Efficiency Rewards,.......,. ....,..,...,.1,881,116 93,924 0 26,922 $ 2,001,961
Irrigation Peak Rewards.....,...:...,......;....,....,1,520,106 54,747 0 41,028 $ 1,615,881
Energy Efficiency/Demand Response Total 11,969,578 330,627 149,534 1,421,852 $13,871,592
Market Transformation
NEEA.....,..,',.,.,.,.,',..,.,..,..,..,.,.".".,....,.,.".,.,846,898 44,574 0 1,868 $893,340
Market Transformation Total 846,898 44,574 0 1,868 $893,340
Other Programs and Activities
Commercial
Commercial Education Initiative.,.,........ ...,.,.25,427 1,314 0 82 $26,823
Other
BPA CRC Renewables .....,....,....,.,..,.,.,......,0 0 31,645 0 $31,645
Distribution Effciency Initiative(a):............,...6,514 343 0 2,130 $8,987
. DSM Direct Program Overhead,.,...,.....,..,...54,339 2,465 0 105 $56,909
LEEF(b) ..."..,."....,..........."..,."....,.,.........::...7,571 (50)0 0 $7,520
Other Programs and Activities Total 93,851 4,072 31,645 2,317 $131,885
Indirect Program Expense
DSM Accounting and Analysis............,.,..,.,.564,129 29,367 0 139,006 $732,503
Energy Efficiency Advisory Group....,......,..,2,488 109 0 0 $2,597
Special Accounting Entries..........,.....,......,.,10,516 439 19,507 $30,462
Indirect Program Expense Total 577,133 29,915 19,507 139,006 $765,561
Totals $13,487,460 $409,188 $200,686 $1,565,043 $15,662,378
(a)IPC portion of Distribution Effciency Initiative expenses wil be reversed in 2008,
(b) Oregon currrection fo~'.2006 entry for bulbs purchased and used in Idaho,
EXhibit N():i 49
Case No. IPC-E-08-10
L. Anderson, Staff
10/24/08
Page 54 Annual Report 2007
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Idaho Power's Total System DSM Expenses 2003 - 2007
(Including Idaho tariff rider and base ratesi Oregon and BPA)
Total and Indirect from IPC's 2007 DSM Annual Report, p. 71
Direct DSM Program Expenses
(Including Direct Overhead)
% Increase
2003 $2,566/229
2004 $3,807/689 48%
2005 $6,523/349 71%
2006 $11,174/181 71%
2007 $14/896/817 33%
5-year $38,968,265
Indirect Overhead DSM Expenses
% Increase
2003 $78,526
2004 $148/610 89%
2005 $177,624 20%
2006 $309/832 74%
2007 $765/561 147%
5-year $1,480/153
Total Direct and Indirect DSM Expenses
% Increase
2003 $2,644/755
2004 $3,956/299 50%
2005 $6/700/973 69%
2006 $11,484/013 71%
2007 $15/662,378 36%
5-year $40,448,418
Exhibil:No. 150
Case No. IPC-E-08-10
L. Anderson, Staff
10/24/08
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 24TH DAY OF OCTOBER 2008,
SERVED THE FOREGOING DIRECT TESTIMONY OF LYNN ANDERSON, 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
POBOX 70
BOISE ID 83707-0070
E-MAIL: bkline§idahopower.com
lnordstrom§idahopower.com
dwalker§idahopower.com
PETER J RICHARDSON
RICHARDSON & O'LEARY
PO BOX 7218
BOISE ID 83702
E-MAIL: peter§richardsonandoleary.com
RANDALL C BUDGE
ERIC L OLSEN
RACINE OLSON NYE ET AL
PO BOX 1391
POCATELLO ID 83204-1391
E-MAIL: rcb§racinelaw.net
elo§racinelaw.net
MICHAEL L KURTZ ESQ
KURT J BOEHM ESQ
BOEHM KURTZ & LOWRY
36 E SEVENTH ST STE 1510
CINCINATI OH 45202
E-MAIL: mkurz§BKLlawfrm.com
kboehm§BKLlawfirm.com
BRAD MPURDY
ATTORNEY AT LAW
2019 N 17TH ST
BOISE ID 83702
E-MAIL: bmpurdy§hotmail.com
JOHN R GALE
VP - REGULATORY AFFAIRS
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: rgale§idahopower.com
DR DON READING
6070 HILL ROAD
BOISE ID 83703
E-MAIL: dreading§mindspring.com
ANTHONY Y ANKEL
29814 LAKE ROAD
BAY VILLAGE OH 44140
E-MAIL: yankel§attbi.com
KEVIN HIGGINS
ENERGY STRATEGIES LLC
PARKS IDE TOWERS
215 S STATE ST STE 200
SALT LAKE CITY UT84lll
E-MAIL: khiggins(fenergystrat.com
LOTH COOKE
ARTHUR PERRY BRUDER
UNITED STATE DEPT OF ENERGY
1000 INDEPENDENCE AVE SW
WASHINGTON DC 20585
E-MAIL: lot.cooke(fhq.doe.gov
arhur. bruder(fhq.doe. gOY
CERTIFICATE OF SERVICE
DWIGHT ETHERIDGE
EXETER ASSOCIATES INC
5565 STERRTT PLACE, SUITE 310
COLUMBIA MD 21044
E-MAIL: detheridge(qexeterassociates.com
DENNIS E PESEAU, Ph.D.
UTILITY RESOURCES INC
1500 LIBERTY STREET SE, SUITE 250
SALEM OR 97302
E-MAIL: dpeseau(qexcite.com
. CONLEY E WARD
MICHAEL C CREAMER
GIVENS PURSLEY LLP
601 W BANNOCK ST
PO BOX 2720
BOISE ID 83701-2720
E-MAIL: cew(qgivenspursley.com
KEN MILLER
CLEAN ENERGY PROGRAM DIRECTOR
SNAKE RIVER ALLIANCE
PO BOX 1731
BOISE ID 83701
E-MAIL: kmiler(qsnakeri verallance.org
jJ~~.\s
SECRETARY
CERTIFICATE OF SERVICE