20191106Comments.pdf

EDWARD J. JEWELL
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-03 l4
IDAHO BARNO. 10466
IN THE MATTER OF THE PETITION OF
IDAHO POWER COMPANY TO STUDY THE
COSTS, BENEFITS, AND COMPENSATION OF
NET EXCESS ENERGY SUPPLIED BY
CUSTOMER ON-SITE GENERATION
RECEIVED
'ii,iilt'/-6 Pl{ 2:0t
CASE NO. IPC-E-I8-I5
COMMENTS OF COMMISSION
STAFF IN SUPPORT OF
SETTLEMENT AGREEME,NT
ON
Street Address for Express Mail:
11331 W. CHINDEN BLVD, BLDG 8, STE. 201.A
BOISE, IDAHO 83714
Attomey for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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BACKGROUND
On May 9, 2018, in Docket No. IPC-E-17-13, the Commission ordered Idaho Power
Company ("ldaho Power" or "Company") to "initiate a docket to comprehensively study the
costs and benefits ofon-site generation on Idaho Power's system, as well as proper rates and rate
design, transitional rates, and related issues ofcompensation for net excess energy provided as a
resonrce to the Company." Order No. 34046 at 3 l The Commission encouraged the parties to
work tkough these issues together in compromise. Id. a122.
On October 19,2018, the Company petitioned the Commission to open this docket to
comply with the Commission's directive in Order No. 34046.
On November 9, 2018, the Commission issued a Notice of Petition and Notice of
Intervention Deadline, notifuing the public that the petition was hled and establishing an
intervention deadline. Order No. 341 89. The Commission directed Commission Staff to confer
with parties regarding the procedural and substantive scope ofthe docket and to periodically
STAFF COMMENTS IN SUPPORT
OF SETTLEMENT AGREEMENT
NOVEMBER 6,20I9I
report back to the Commission. Id.at4. In total, one pre-hearing confbrence and eight
settlement conferences were held by the parties.
On October 11,2019,Idaho Power and Commission Staffjointly submitted a Motion to
Approve Settlement Agreement. The proposed Settlement Agreement is signed by the
Company, Commission Staff, Idaho Clean Energy Association ("lCEA'), Idaho Irrigation
Pumpers Association, Inc., Idahydro, City of Boise, Idaho Sierra Club, Industrial Customers of
Idaho Power, and Russell Schiermeier (collectively, the "Signing Parties"). One issue the
Signing Parties did not resolve in the Settlement Agreement was whethcr existing customers
with on-site generation would be subject to the terms of the Agreement. The Signing Parties
decided to submit this issue to the Commission for determination.
Under the proposed Settlement Agreement, if approved by the Commission, residential
and small general service customers ('R&SGS customers") with on-site generation who export
energy to the grid ("Schedule 6 and Schedule 8 customers") would transition from retail rate
monthly net metering to net hourly billing at an Export Credit Rate. The transition to the Export
Credit Rate would occur in increments over the next eight years. The Export Credit Rate would
be determined by the methodology set out in the proposed Settlement Agreement. Inputs to the
Export Credit Rate would be updated biennially in conjunction with the Company's Integrated
Resource Planning ("lRP") process.
The proposed Settlement Agreement would make changes to the rate paid to Schedule 6
and Schedule 8 customers for the energy that they export to the grid. No changes to rates for
consumption of electricity are included in the Settlement Agreement. Further, the proposed
Settlement Agreement would prevent ldaho Power tiom proposing to change consumption rates
for Schedule 6 and Schedule 8 customers until the Commission examines whether to change
rates or rate designs for all Idaho Power customer classes.
The Settlement Agreement contains a non-export option for Schedule 6 and Schedule 8
customers that would allow those customers to move to Schedule I or Schedule 7. as
appropriate, if they so choose.
The Settlement Agreement calls for the Commission to open an investigative docket
within 120 days of an Order approving the Settlemcnt Agrcement to examine whether it would
be reasonable to establish a single avoided cost methodology that could be applied to diftbrent
STAFF COMMENTS IN SUPPORT
OF SETTLEMENT AGREEMENT
2 NOVEMBER 6,20I9
load-serving resources on the Company's system, such as energy efficiency, demand rcsponsc,
and small and large qualifuing facilities under the Public Utility Regulatory Policies Act of 1978.
The Settlement Agreement acknowledges that the Commission is not bound by the
Signing Parties' Agreement. The Commission will independently review the Settlement
Agreement consistent with Commission Rules 271 -280, IDAPA 31.01 .01 .27l-280, to decide
whether to approve or reject it, or state conditions under which to accept it. The proposed
Settlement's proponents ultimately bear the burden to prove that it is just, fair, and reasonable, in
the public interest, and otherwise in accordance with law and regulatory policy.
There are pertinent legal and policy questions that impact whether the terms ofthe
Settlement Agreement can and should be applied to existing customers with on-site generation.
See also Order No. 34046 at 24. The Signing Parties did not reach agreement on these issues,
and agreed to make legal and policy argumcnts to the Commission lor its consideration and
determination.
If this Settlement Agreement is approved by the Commission it will go into effect,
regardless of the Commission's determination as to whether and under what terms the Settlement
Agreement applies to existing customers. The Cornmission will also determine how to define an
existing customer with on-site generation.
STAFF REVIEW
Staff recommends that the Commission approvc the Settlement Agreement as filed by the
Signing Parties and Staffas a reasonable resolution of many ofthe issues associated with on-site
generation from R&SGS customers. As instructed by the Commission in Order No. 34604, all
parties to the case worked diligently to reach compromise on the long list of complicated and
sometimes contentious issues. As a result. Stafl'believes that the solutions reached here are
sound, robust, and will preserve the right of customers to ofl'set their electric consumption while
holding all other customers harmless.
Although not specified in the language ofthc Seltlement, the methodology established
within it is based on a "bright line at the meter" concept: What happens behind the meter is the
customer's concern and the Company's concern is with those things that are measurable at the
meter. That means that billing for imported energy and compensation for exported energy
should be determined solely using information measured at the point ofdelivery, the meter.
STAFF COMMENTS IN SUPPORT
OF SETTLEMENT AGREEMENT
-)NOVEMBER 6. 20I9
With a host of related and sometimes overlapping issues, this principle was central to the
discussions.
Under the bright line at the meter concept, rates for consumption are appropriately
separated from the credit paid for exported energy ("Export Credit Rate"). This Settlement does
not include a change to rates for oonsumption; however, it does replace retail monthly net
metering lor Schedule 6 and Schedule 8 customers with a bill credit for net hourly exported
energy based on the avoided cost.
The crux of this Settlement is the move tiom retail monthly net metering to hourly net
billing at the Export Credit Rate, with a bright line at the meter to distinguish imports from
exports. Staff explains these and other substantive elements of the Agreement below.
Nct Hourlv Billins
Under the Agreement. Schedule 6 and Schcdule 8 customers will move from net monthly
billing to net hourly billing. Net hourly billing more accurately measures the energy Schedule 6
and Schedule 8 customers consume liom and export to the Company than net monthly billing by
more closely aligning the time period of imported and exported energy. Staffbelieves that net
hourly billing is appropriate because it aligns with the functionality of the Company's meters and
it preserves the ability of customers to ofhet their consumption, which is the intent of on-site
generation.
Under net monthly billing, customers could use kilowatt hours produced any'time in the
month to ottset kilowatt hours consumed from the Company anytime in the month. 'fhis long
netting period does not accurately refleot the customer's consumption ol'Company-supplied
energy because exported energy can "mask" consumption on a customer's bill. Shortening the
billing interval fiom net monthly to net hourly drastically decreases this problem and effectively
eliminates any meaningl'ul amount of "masking."
Signing Parties agreed that after imports and exports are netted for each hour, net energy
exports will be compensated at the Export Credit Rate, which Staffbelieves more rcasonably
represents the value ofthe net energy exported to the grid.
STAFF COMMENTS IN SUPPORT
OF SETTLEMENT AGREEMEN'I'
4 NOVEMBER 6, 2019
Mcthod olotry to Determine the Exnort Clrcdit Ratc
Signing Parties agreed to determine the Export Credit Rate based largely on the
Company's demand-side management ("DSM") avoided cost structure. Although there are
several methods for determining avoided cost values, Staff believes this is a reasonable approach
because, consistent with the bright line at the meter concept, both DSM and on-site generation
resources exist on the customer's side of the meter. Staff believes that the energy exported by
on-site generation customers is a resource that contributes to the Company's electric grid, and
therefore it is important to value the credit paid to customers tbr cxported energy in alignment
with the value of that resource to the Company's system. Staff also notes that the Commission
approved use ofthe DSM avoided cost structure as a basis tbr the energy that was to be exported
from the Company's proposed community solar project, thus demonstrating that the Commission
has found it reasonable to value solar through the DSM avoided cost structure previously. See
Order No. 33638.
Determining the appropriate value of customer-generatcd exported energy, including both
the energy and capacity values, was one of the most difficult and contentious aspects of moving
from retail net metering to an avoided cost structure. While parties generally agreed that the
Export Credit Rate should be based on avoided cost, a signilicant arnount of time and efTort was
spent exploring a variety ofmethods and inputs to calculate a fair compensation value.
Avoided Enersy Value
Signing Parties agreed to use the DSM avoided cost structure and actual exported
energy-rather than modeled data-to determine the compensation Schedule 6 and Schedule 8
customers should receive for the avoided energy value of energy that they export. Staff believes
it is reasonable to use DSM avoided cost rates fbr the avoided energy value because l) the DSM
avoided energy valucs are determined through the Company's IRP process. which provides an
integrated assessment ofthe Company's resource options and is dcveloped through a public
process, and 2) the DSM avoided energy cost rates segment the year into five pricing periods,
which is intended to reflect the differing seasonal value of the resource. 1'he Export Credit Ratc
paid to Schedule 6 and Schedule 8 customers will be a flat ratc calculated using the encrgy
weighted value of the five seasonal pricing periods currently used to value DSM resources.
As part of the compromise, the DSM avoided cost energy value was decreased by 100/o to
reflect the non-firm availability of exported energy from on-site generators. The methodology
STAFF COMMENTS IN SUPPORI'
OF SETTLEMENT AGREEMENT
5 NOVEMBER 6,20I9
used to calculate this adjustment is not specitied as part of this Settlement. Stalfbelieves it is
reasonable to provide parties an opportunity to advocate for a methodology to determine this
value in a future proceeding.
Avoided Capacity Vglae
The method for determining the avoided capacity value component ofthe Expot Credit
Rate is based on the DSM Capacity Resource identified in the most recently approved IRP. The
DSM Capacity Resource is currently a Simple Cycle Combustion Turbine ("SCCT"), but the
identified resource may change in future IRP's.
In the DSM pricing methodology, the capacity value is determined by applying the SCCT
value to the approximately 520 hours that constitute the DSM Summer On-Peak pricing period.
The load shape ofeach DSM measure determines how much capacity value, or peak contribution
fbctor, is assigned to each measure.
However, Signing Parties agreed to a different method for calculating the capacity value
ofon-site generation; they agreed to determine Schedule 6 and Schedule 8 on-site generation's
peak conlribution factor using the highest 100 hours of marginal system load. Those highest 100
hours ofsystem load were then netted of large-scale solar resources to determine the capacity
value ofon-site generation exported energy.
'['he value of the DSM Capacity Resource was calculated using the Company's first
capacity deficit year and levelized over the presumed25-year life ofthe resource. Although
there are a variety of methods for calculating the capacity value of exported energy liom
Schedule 6 and Schedule 8 on-site generation, Staff believes this approach is a reasonable
compromise that fairly reflects the value these customers provide to the system.
Avoided Transmission & Distrihution Line Losses
Both the energy value and the capacity value were increased by 8.1% to reflect avoided
transmission and primary distribution line losses. This adjustment was based on the Company's
2012 System Losses study and is part of the Company's standard methodology for valuing DSM
resources. Staff believes that this adiustment is appropriate because Schedule 6 and Schedule 8
on-site generation is coJocated with customer consumption at the secondary distribution level,
which means it avoids primary distribution and transmission line losses associated with
transporting energy from generating locations to load centers. Because the energy produced by
Schedule 6 and Schedule 8 customers is used by other customers at the secondary distribution
STAFIT COMMENTS IN SUPPORT
OF SETTLEMEN'I' AGREEMENT
6 NOVEMBER 6,20I9
level, secondary distribution line losses are not avoided and therefore not included in the
adjustment.
Additionul Inputs to the Exporl Credit Rate
Staff notes that some important, but likely lower dollar components of the Export Credit
Rate, specifically avoided transmission and distribution capacity, integration costs, and
environmental benefits, were included as zero-dollar placeholders with the specific amounts to
be determined in future proceedings. Staffbelieves that conducting the necessary analysis to
include the I'air values for these line-items would have greatly delayed, and perhaps derailed, the
parties agreeing to a Settlement. Staff maintains that assigning zero-dollar placeholders for now,
but preserving the opportunity for parties to advocate for different values in future proceedings,
is the most eillcient way to expeditiously resolve the larger and more critical issues in this casc.
Based on this methodology and inputs derived from the Company's 2017 IRP, the Export
Credit Rate, were it not subject to the transition period to be discussed later, would initially be
set at $44.06/MWh for Schedule 6 customers and $49.56/MWh for Schedule 8 customers.
Export Credit Ratc Offsets
Signing Parties agreed that credits for exported energy can offset energy and Power Cost
Adjustment ("PCA') charges on Schedule 6 and Schedule 8 customer bills, but the export credits
cannot offset service charges, the Fixed Cost Adjustment ('FCA'), the Energy Efficiency Rider,
or franchise fees. Staffbelieves these limits are reasonable.
STAFF COMMENTS IN SUPPORT
OF SETTLEMENT AGREEMENT
7 NOVEMBER 6,2019
Updates to the Exnort Credit Rate
The avoided cost inputs to the Export Credit Rate will be updated every two years in a
separate docket to become effective concurrent with or shortly afier each new IRP is
acknowledged. Staffbelieves that these regular updates and associated reviews will provide
timely data to maintain a current Export Credit Rate. and transparency to help ensure that
Schedule 6 and Schedule 8 customers are fairly compensated fbr the resource they provide to the
system.
Export Credit Rate Exrrcnse
Signing Parties agreed that the Export Credit Rate paid to on-site generators would
be collected through the PCA. Because the Export Credit Rate tbr the power supplied by
Schedulc 6 and Schedule 8 customers is generally outside the control ofthe Company and may
vary from year to year, Staffbelieves it is reasonable to collect this expense through the PCA.
As later explained, this Settlement Agreement includes an eight-year transition period
from the Blended Base Energy Rater to the Export Credit Rate. During that transition period, the
difference between the Blended Base Energy Rate and the Export Credit Rate will be collected
through the FCA. Because the FCA only applies to R&SGS customers, no other customer
classes will be impacted by this transition. Staff believes this is a reasonablc way to ease rate
shock for on-site generating customers while restricting those impacts to only those customers
eligible to padcipate in Schedules 6 and 8.
Ratc Stability
Signing Parties agreed that the Company n'ould not propose modifications to rates or rate
design for Schedule 6 and Schedule 8 customers until a future proceeding in which the
Commission determines whether to change rates or rate design fbr all customer classes. Stafl'
believes this provides time for Schedule 6 and Schedule 8 customers to adjust to the Export
Credit Rate and net hourly billing before being faced with the possibility ofchanges to rates for
consumption as well.
Transition Period
The Settlement Agreement includes an eight-year transition period from compensation
at the Blended Base Energy Rate to compensation at the Export Credit Rate. Beginning on
January 1,2020, Schedule 6 and Schedule 8 customers will receivc the Blended Base Energy
Rate as compensation for net hourly cxports. Every two years beginning January I , 2022, the
difference between the Blended Base Energy Rate and the Export Credit Rate will be reduced
by 25%, Beginning January 1, 2028, all Schedule 6 and Schedule 8 customers will be
compensated for exported energy at the Export Credit Rate.
STAI,-F COMMENTS IN SUPPORT
OF SETTLEMENT AGREEMENT
8 NOVEMBER 6,20I9
I The Blended Base Encrgy Rate is determincd by dividing the dollar value of thc cnergy billed to the customer by the
total nurnber ofconsumed kWh. This is, efl'ectively, an energy-weighted average olthe Company's tiered ratcs.
Staffunderslands that any decrease in the compensation rate fbr exported energy is
difficult for on-site generation customers because it materially impacts the economics oftheir
investment. However, Staffbelieves that a reasonable transition period with incremental, but
substantial, movement toward the Export Credit Rate provides gradualism for customers and will
allow installers time to adapt their business models to the new value propositions associated with
on-site generation in Idaho Power's service teritory.
Smart Inverters
While sma( inverters have the potential to provide valuablc benefits to the Company's
system, Staff remains concemed that some functions of smart inverters could allow the Company
to dramatically limit behind-the-meter energy production without the customer's knowledge or
permission. To allay these concerns, Idaho Power agreed to use only the default settings until
the Commission approves alternate settings. Staff bclicves that requiring Commission approval
before altering the default settings will provide Staff and other interested stakeholders an
opportunity to study and make rccommendations about how to reasonably optimize smart
inverters to benefit the Company's system while not harming R&SGS customers.
Return Trins
The Company has become concemed that the number of rctum trips it is required to
make to approve new on-site generation systems has been increasing. In order to reduce the
number of return trips, the Company and ICEA have agreed to work together to help installers
understand how to improve the process so multiple trips are not required. Signing Parties agreed
that if the number ofretum trips is not reduced, Idaho Power will lile a tariffadvice asking the
Commission to implement a cost-based charge for this service. Staff believes it is not only
reasonable, but preferable, to address this issue with process improvements first, and only
implement an additional fee ifthose process improvemenls are not successful in reducing the
number of retum trips.
Non-Exrrort Orltion
Consistent with the direction in Order No. 34147, parties considered the feasibility,
safety, and operational issues associated with creating a non-export option for R&SGS customers
STAFF COMMENTS IN SUPPORT
OF SETTLEMENI' AGREEMENT
9 NOVEMBER 6.20I9
with on-site generation who do not export any energy to the Company's system. Although some
details ofthe interconnection process for these customers are lefl to a separate proceeding.
Signing Parties agreed that non-exporting R&SGS customers should be allowed-at their
discretion but with proper equipment verilication-to move baok to Schedules I and 7 tiom
Schedules 6 and 8.
Staffbelieves this is consistent with the Commission's determination that the
distinguishing characteristic of net metering customers is their bi-directional relationship with
the grid. See Order Nos. 34046 at 17 -18, 34147 at I 5- I 6. Because non-exporters do not have a
bi-directional relationship, Staffbelieves it is reasonable they remain in the same customer class
as other customers who have a one-way relationship with the grid.
Existing On-Sitc Generation Customers
While Signing Parties recommend that the Settlement Agreement apply to new R&SGS
on-site gcneration customers, this Agreement does not provide any recommendations on whether
its terms apply to existing Schedule 6 and Schedule 8 customers. Staffbelieves it is reasonable
for parties to make arguments regarding that issue to the Commission in a separate procecding.
If the Commission determines that this Settlement applies to existing Schedule 6 and
Schedule 8 customers, Signing Parties agree that those existing customers will be converted to
Net Hourly Billing and that any existing kilorvatt hour credits eamed by those oustomers will be
converted to bill credits at the Blended Base Energy Rate.
Follow-on Docket Resardin Avoided Cost Mcthodoloel,
Settlement discussions on how to calculate the avoided cost of Schedule 6 and Schedule 8
customers' exported energy deepened the realization among parties that there are currently
several significantly different ways to calculate the avoided cost value for resources on the
Company's system. Staflbelieves it is reasonable to investigate the possibility ofa single
avoided cost methodology that can be adjusted based on the specific attributes ofeach resource
in order to more accurately and evenly value the resources on the Company's system. Ifthat
investigation results in a method for calculating avoided costs that is subsequently approved by
the Commission, Staff anticipates that the new method would apply to the value of exported
energy supplied by Schedule 6 and Schedule I customers.
STAFF COMMENTS IN SUPPORT
OF SETTLEMENT AGREEMENT
l0 NOVEMBER 6,20I9
STAFF'RECOMMENDATION
Staff recommends that the Commission approve the proposed Settlement Agreement
without modification or amendment as just, fair, reasonable, and in the public interest. Staff
recommends that the Commission issue this approval by December 27,2019, to be effective on
January 1,2020.
RESPECTFULLY submitted this day ol'November,20l9.
J.J
Deputy A General
Technical Staff: Stacey Donohue
Michael Morrison
Umisc/comments/ipcel E. l5ejsd Senlement comments
STAF'I-- COMMENTS IN SU PPORT
OF SETTLEMEN]' AGREEMENT
l1 NOVEMBER 6,20I9
/*^^b
I HEREBY CERTIFY THAT I HAVE THIS 6TH DAY OF NOVEMBER 2019,
SERVED THE FOREGOING SETTLEMENT COMMENTS OF THE COMMISSION
STAtr'F, IN CASE NO. IPC-8.I8.I5, BY MAILING A COPY THEREOF, POSTAGE
PREPAID, TO THE FOLLOWING:
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
7IO N 6TH STREET
BOISE ID 83702
E-MAIL: botto@idahoconsqrvatioqorg
ERIC L OLSEN
ECHO HAWK & OLSEN PLLC
POBOX6lt9
POCATELLO ID 83205
E-MAIL: [e-mail]
C TOM ARKOOSH
ARKOOSH LAW OFFICES
PO BOX 2900
BOISE ID 8370I
E-MAIL: tom.arkoosh
erin. cecil (darko o sh. com
YVONNE R HOGLE
ROCKY MOUNTAIN POWER
1407 WN TEMPLE STE 320
SALT LAKE CITY UT 84I I6
E-MAIL: Yvonne.hosl
ELECTRONIC SERVICE ONLY
AL LIINA
al una@earthi ustice.ore
NICK TIIORPE
BRIANA KOBOR
VOTE SOLAR
358 S 700 E STE 8206
SALT LAKE CITY UT 84I02
ifioorD.com E-MAiL: [e-mail]
ANTHONY YANKEL
I27OO LAKE AVE
UNIT 2505
LAKTWOOD OH44IO7
E-MAIL: [e-mail]
TED WESTON
ROCKY MOLTNTAIN POWER
1407 WN TEMPLE STE 330
SALT LAKE CITY UT 84I I6
E-MAIL:ted.weston[d)cificom.com
DAVID BENDER
EARTHJUSTICE
39I6 NAKOMA RD
MADISON WI 5371 I
E-MAIL: dbenderf4)earrhiustice.org
h
t1r trce.or
CERTIFICATE OF SERVICE
CERTIFICATE OF SERVTCE
LISA D NORDSTROM
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: [e-mail]
TIM TATUM
CONNIE ASCHENBRENNER
IDAHO POWER COMPANY
PO BOX 70
BOISE rD 83707-0070
E-MAIL: [e-mail]
[e-mail]
ELECTRONIC ONLY
dockcts@idahopou,cr.coni
ABIGAIL R GERMAINE
BOISE CITY ATTORNEY'S OFFFICE
PO BOX 500
BOISE ID 83701-0500
E-MAIL ne clI olboise.or
JIM SWIER
MICRON TECHNOLOGY INC
8OOO S FEDERAL WAY
BOISE ID 83707
E.MAIL:cron.coln
PETER J RICI{ARDSON
RICHARDSON ADAMS PLLC
515 N 27TTI STREET
PO BOX 7218
BOISE ID 83702
E-MAIL: Deter(Aichardsonadams.com
PRESTONN CARTER
GIVENS PURSLEY LLP
60I W BANNOCK STREET
BOISE ID 83702
E-MAIL: presloncarter@qi venspursley.com
DR DON READING
6070 HILL ROAD
BOISE ID 83703
E-MAIL: [e-mail]
RUSSELL SCHIERMEIER
29393 DAVIS ROAD
BRTINEAU ID 83604
E-MAIL: [e-mail]
SECRETARY
CERTIFICATE OF SERVICE
KELSEY JAENUNEZ
IDAHO SIERRA CLUB
920 CLOVER DR
BOISE ID 83703
E-MAIL: [e-mail]
F DIEGO RIVAS
NW ENERGY COALITION
I IOI 8TH AVE
HELENA MT 59601
E-MAIL: [e-mail]
ZACK WATERMAN
MIKN HECKIER
IDAHO SIERRA CLUB
503 W FRANKLIN ST
BOISE ID 83702
E-MAIL: [e-mail]
[e-mail]
AUSTIN RESCHHOFF
THORVALD A NELSON
HOLLAND & HART LLP
555 7rr ST STE 3200
DENVER CO 80202
E-MAIL: [e-mail]
tnelson@hollandhart. com