20220427Comments.pdf

CHRIS BURDIN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-007 4
[phone]
IDAHO BARNO.98lO
Street Address for Express Mail:
1I33I W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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IN THE MATTER OF IDAHO POWER
COMPAI\ Y'S APPLICATION F'OR
AUTHORITY TO INCREASE ITS RATES
FOR ELECTRIC SERVICE TO RECOVER
COSTS ASSOCIATED WITH THE JIM
BRIDGER POWER PLAI\T
CASE NO.IPC.E.LI-I7
COMMENTS OF THE
COMMISSION STAFF
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STAFF OF the Idaho Public Utilities Commission, by and through its Attomey of record,
Chris Burdin, Deputy Attomey General, submits the following comments.
BACKGROT]ND
The Jim Bridger Power Plant ("Bridger") is located near Rock Springs, Wyoming and
consists of four generating units. Amended Application at 3. PacifiCorp owns two-thirds of the
facility and is its operator, while Idaho Power Company ("Company") owns the other one-third.
Id. The Company and PacifiCorp ("Co-Owners") work jointly to make decisions regarding
Bridger including required investments and the proposed retirement of Bridger. 1d Bridger is
connected to the Borah West transmission path west of the Borah Substation near American Falls,
Idaho. Id. The Company's one-third share of energy flows west over this path. 1d The Idaho-
Wyoming path ("Bridger West") consists of three 345 kV transmission lines. Id. at 4. The
Company owns 800 MW of the 2,400 MW east-to-west capacity which feeds into the Borah West
path when power is moving east to west from Bidger. Id.
1STAFF COMMENTS APRIL 27 ,2022
PROCEDURAL HISTORY
On June 3,2021, the Company applied to the Commission for authorization to accelerate
the depreciation schedule for Bridger to allow the plant to be fully depreciated and recovered by
December 31,2030. Application at l.
Clean Energy Opportunities for ldaho, City of Boise City, Industrial Customers of Idaho
Power, Idaho Conservation League, Micron Technology, and Sierra Club all intervened in this
matter. Order Nos. 35094,35102, and 351 19.
On November 17,2021, the Commission suspended the procedural schedule and discovery
until the Company filed an update or requested to set the procedural schedule once more
informationwasknown,butnolaterthanDecember3l,202l. OrderNo.35222. TheCommission
also suspended the effective date for 30 days and 5 months, or until May 3I,2022, unless the
Commission issued an earlier order accepting, rejecting, or modiffing the Company's Application.
rd.
On December 30, 202l,the Company filed a letter ("Update") with the Commission stating
that it filed its 2021lntegrated Resource Plan ("[U"'; with a preferred portfolio that also identified
the cessation of coal-fired generation in Bridger Units I and2in2023 with a natural gas conversion
of those units in 2024. Update at l. The Company also stated that the Environmental Protection
Agency ("EPA") had not yet formally acted on PacifiCorp's proposed alternative regional haze
compliance plan for Bridger Units I and 2. Id. at 2. The current PacifiCorp plan would require
emission controls by December 31, 2021, for Unit 2 and December 31,2022, for Unit l. Id. The
Company stated that on December 21,2021, Wyoming Governor Mark Gordon issued a temporary
emergency suspension extending the compliance date of Unit 2 through April 30, 2022, to give
more time for the EPA to act on the Wyoming State Implementation Plan ("SIP"). 1d The EPA
remains in discussions with PacifiCorp regarding this issue. 1d
On February 16,2022, the Company filed an Amended Application and requested the
Commission issue an order authorizing the Company to: (1) accelerate the depreciation schedule
for all coal-related Bridger investments to allow for full depreciation and recovery by December
31,2030, (2) establish a balancing account, and the necessary regulatory accounting, to track the
incremental costs and benefits associated with the Company's cessation of participation in coal-
f,rred operations at Bridger, and (3) adjust customer rates to recover the associated incremental
2STAFF COMMENTS APzuL 27,2022
annual levelized revenue requirement of $27.13 million, which would result in an overall rate
increase of 2.12 percent. Id. at l.
The Company requested that its proposed rates take effect June 1, 2022. Id. The Company
also requested that the Commission set a public comment deadline of April 29, 2022, a
simultaneous reply comment deadline of May 13,2022, and a Company reply deadline of May 18,
2022. Id. at ll.
THE APPLICATION
The Company represented that it has made numerous investments into Bridger to ensure
environmental compliance and routine maintenance and repairs are completed. Id. at 4. The
Company requested a prudence determination on the incremental Bridger coal-related investments
from January 1,2012, through December 31,2020.1 Id. The Company represented that its
investments for environmental compliance make up nearly 50 percent of the total Bridger
investments made since January 1,2012. Id. at 5. The Company also represented that it funded
l5 investments greater than $1 million for operational maintenance costs. See Id.
The Company represented that changing conditions have resulted in earlier than expected
exit from participation in Bridger operations. Id. The Company's 2019 IRP proposed Bridger
exits in 2022,2026,2028, and 2030.2 Id. at 5-6. The Company's 202! IRP3 included the
conversion of Bridger Units I and 2 from coal to natural gas by the summer of 2024 with a 2034
exit date, and the exit of coal-fired operations in Units 3 and 4 by year-end2025 and2028. Id. at
6. The Company claimed that the 2021 IRP indicates that an earlier exit from coal-fired generation
at Bridger would be more economical. Id. The Company stated that a depreciable life of year-end
2030 for all Bridger Units is appropriate "as it [would] help minimize revenue requirement impacts
to customers." Id. The Company estimated that it would exit coal-fired operations of Bridger
completely by 2028. Id.
The Company estimated that Bridger would require incremental coal-related investments
to maintain operations prior to the decommissioning of the facility. Id. However, because the
specific timing and exact amounts of future investments are unknown, the Company proposed that
the Commission establish a balancing account to allow flexibility for the recovery of the remaining
rSee Case No. IPC-E-l l-08
2 See Case No. IPC-E-19-19
3 See Case No. IPC-E-21-43
JSTAFF COMMENTS APRIL 27,2022
Bridger investment revenue requirement. Id. at 6-7. The Company stated that under the balancing
account approach,
the Company replaces the base rate revenue recovery associated with [the
Company's] existing coal-related investment in Bridger with a levelized revenue
requirement and tracks it in the Bridger balancing account, smoothing revenue
requirement impacts associated with the exit of Bridger coal-fired operations and
allowing for full recovery of Bridger coal-related costs near the time [the Company]
ceases participation in coal-fired operations.
Id. at 7. The Company represented that this approach aligns the cost recovery period with the
Company's remaining participation in coal-fired operations more closely and ensures that
Customers would "pay no more or no less than the actual coal-related O&M and capital coal-
related costs of the Bridger plant beginning June 1,2022." Id. The Company further believed that
the balancing account approach would accelerate depreciation expenses related to its Bridger-
related investments. Id. The Company proposed that the Commission track the coal-related
investment return and associated depreciation expenses, as well as the decommissioning costs,
through the balancingaccornt. Id.
The Company requested an accounting order that allows the Company to make necessary
accounting entries, including a regulatory asset account that would match Generally Accepted
Accounting Principles ("GA.AP") revenue recognition with actual monthly patterns of coal-related
revenue requirement. Id. at 8. The Company stated that regulatory accounts would be required to
adjust the financial statement impacts resulting from Bridger-related GAAP accounting and
income tax results. Id
The Company requested recovery of the coal-related levelized revenue requirement that
includes costs of accelerating the depreciation of Bridger, the retum associated with coal-related
capital investments net of accumulated depreciation forecasted through the Company's
participation in Bridger, interim decommissioning costs associated with Bridger, and O&M
savings associated with non-fuel coal-related O&M reductions. 1d The Company totaled these
costs to $27,127,333. The Company submitted the following table to present the differences
between each component as quantified in the Company's initial request and the amounts that
refl ected Bridger' s investment levelized revenue requirement:
4STAFF COMMENTS APRIL 27,2022
June 2021
Request
February 2022
Amended Request
Vo Change
Plant Investment $73,470,945 $52,121,340 (2e.1)
Interim Decomm. Costs $59,318 s64,449 8.6
O&M Savings ($5,736,719)($4,391,349)(23.s)
Levelized Rev. Req.s67,793,544 $47,794,440 Qe.s)
Rev. Req. in Rates ($36,96,815)($20,667,107)(44.1)
Net Change $30,825,729 $27,127,333 (12.0)
The Company proposed to allocate the increase related to Bridger's balancing account
using the jurisdictional separating study method. Id. at 9. The Company requested that the
incremental revenue requirement increase of $27.13 million be recovered from all customer classes
through a uniform percentage increase to all base rate components except the service charge. Id.
The Company represented that it would submit to the Commission its annual adjustment
mechanism filings, the Fixed Cost Adjustment ("FCA") and Power Cost Adjustment ("PCA") on
March 15,2022, and April 15,2022, respectively. In the Company's FCA filing, the Company
would request the incremental revenue requirement of approximately $27.13 million; the
Company stated that it would include a set of proposed tariff sheets speciffing the proposed rates
in its filing. Id. at9-10.
STAFF REVIEW
Staff reviewed the Company's Application and Amended Application and all discovery
responses. Based on its review, Staff recommends the Commission find that capital investments
through 2020 for the Jim Bridger power plant were prudently incurred. Staff further recommends
approval of the accelerated depreciation rates and the establishment of a balancing account, and
necessary regulatory accounting, to track any variation from the 2020 revenue requirement. Staff
does not support a change in rates at this time. Staff s comments below provide an explanation of
its positions.
1. Prudence of Capital Investments
Staff believes the investments made to the Jim Bridger Power Plant during the period from
January l,2|lz,through December 31,2020, are reasonably prudent, but it is unclear whether the
Company was adequately involved with the plant co-owner and operating partner, PacifiCorp, to
assure these projects were implemented in a least-cost manner. Staff utilized a four-prong
5STAFF COMMENTS APRIL 27,2022
approach in its review to ensure that the prudence of the Company's investments were examined
in detail on the highest cost projects while providing a broad review of total plant investment. Staff
performed: (1) a detailed examination of all projects over $1 million to ensure that these projects
were necessary and least cost; (2) an analysis of the total investment amount normalized by the
capacity of each unit to ensure the unit and overall amount of plant investment are comparable; (3)
a review of any project cost ovemrns that might indicate that the projects were not implemented
in a cost-effective manner; and (4) an examination of the Company's due diligence efforts with
PacifiCorp to assure these projects were implemented in a least-cost manner.
a. Capital Investment Need of Projects over $1 million
Staff reviewed the list of projects provided by the Company in Exhibit No. 3 totaling
$266.3 million. The two primary drivers of capital investments in the Bridger facility from20l2
through 2020 were to meet environmental compliance and to maintain unit reliability. The
Company provided justification and project descriptions for each of the twenty-four capital
investments that cost over $1 million for the Company's share of the investment. Of these
investments, 9 were needed to meet regulatory compliance ($122.9 million) and 15 were needed
to maintain unit reliability ($45.6 million).
The two largest investments were the Unit 3 and Unit 4 Selective Catalytic Reduction
("SCR") systems constructed to comply with Federal Regional Haze Regulations costing the
Company $112.1 million in total. The largest investment for plant reliability was $13.5 million
for the upgrade of the two low pressure steam turbines for Unit 2 to improve the unit's efficiency.
In total, Staffperformed a detailed review of $168.5 million of the Company's $266.3 million in
investments during this period included for recovery. Staff believes that the justification of need
for all of these projects was reasonable.
b. Unit Comparison
Staff performed a comparison of the Company's share of Bridger unit investments,
normalized by each unit's nominal net capacity to ensure the overall amount of investment was
consistent between units. Because of the relatively small differences in the construction and age
of each unit, Staff was able to verifu that the total investment for each unit was comparable when
adjusting for the capacity of each unit and the additional SCR investments made to Units 3 and 4.
Staff compared the relative differences in the number of projects and Company investment
by plant arealunit as seen in the table below.
6STAFF COMMENTS APRIL 27,2022
Table No. I
AREA
DESCRIPTION
NOMINAL
NET
CAPACITY
AREA
PROJECT
COT]NT
AREA
PROJECT
COSTS
AVERAGE
PROJECT COST
PER MW
COMMON PLANT 405 $43,429,474
UNIT #1 177 MW 108 s22,261,717 $125,772
UNIT #2 180 MW 94 s36,742,959 $204,128
UNIT #3 174 MW 126 $79,734,598 $458,245
UNIT #4 r75 MW 113 $84,101,381 $480,579
TOTAL PLANT 706 MW 9464 $266,270,128 $377,153
When examining the average project cost per mega-watt ("MW"), Units 3 and 4 were
significantly higher than Units I andZ. This can be attributed to the installation of SCRs on Unit
3 in 2015 and Unit 4 in20l6. The SCR system investment cost for Units 3 and 4 totaled $53.6
million and $58.5 million, respectively.s By removing the SCR cost from the comparison, the
average project cost per MW dropped to $150,212 and $146,203 for Unit 3 and 4, respectively.
These costs are consistent with the amounts for Units I and2. The Company also identified 405
common plant projects totaling $43.4 million indicating a $107,233 average cost per project for
the Company over this period. Staff analysis indicates the unit costs are comparable and overall
plant investments are justified.
c. Project Cost Overruns
Staff identified plant projects exceeding $1 million in value where actual project costs
exceeded the original budget appropriations amount. The Company identified 19 projects totaling
$68.3 million where actual investment cost exceeded the original appropriations by more than l0
percent. The cost overrun for these projects totaled $14.5 million with an average ovemrn of 21
percent and a range of between 10 and 39 percent. Staff reviewed the Company's explanations
describing why the projects exceeded the approved budget and concluded that the cost oveffuns
were justified.
a The difference in the project count identified in the Application is attributed to several projects where costs were
spread across one or more units or to the common plant.
5 The values of $53.6 million for Unit #3 and $58.5 million for Unit 4 are a filtered reference from Exhibit No. 3,
which differs from page 2l of Adelrnan's Direct Testimony that shows $62.92 million for Unit 3 and $66.91 million
for Unit 4.
7STAFF COMMENTS APRIL 27,2022
d. Company Plant Oversight
The Company has an obligation to its customers to provide adequate oversight of all
investment in plants managed by it operating partners and ensuring that projects are implemented
at least-cost to customers. This becomes imperative as Bridger nears retirement and the economic
exit dates are currently not aligned in the IRP of both utilities. See Table No. 2 infra. Staff is
concerned that the Company's interests may not be adequately represented while making
investment decisions, which is especially concerning as the Company exits its interests in
generating units and as units are eventually retired. In addition, Staff has historically had issues
with tracing evidence related to the Company's due diligence efforts in managing its operating
partner's investments in co-owned plants.6 Staff recommends that the Company establish a
formalized process to document the circumstances, the Company's justifications, and the final
decisions made for these types of investment decisions.
Documentation shows that the Company is involved in the decision-making process for
project need and budget tracking, but it relies heavily on its operating partner and co-owner
PacifiCorp for project management, project implementation, and project construction.
PacifiCorp analyzes and proposes the need for capital projects and annually provides a 3-
year short-term and lO-year long range forecast of capital projects to the Company.T During mid-
year budget review meetings, the co-owners assess the proposed projects contained within a capital
plan. The plant operator also provides details of the project, its need, and any consequence if the
project is not completed. The Company also participates with the co-owner in quarterly ownership
meetings, where each current year capital budget is reviewed and discussed, along with any
proposed adjustments to the remaining project work. During these meetings, Staff expects the
Company to be actively involved in reflecting its differing view of project investment need given
the different exit/retirement dates between the two Companies. However, the Company has
provided little documentation to date showing how it was involved in these meetings and how its
needs differ from the managing partner.
6 See Mike Louis, Di, IPC-E-13-16,p.32; Staff Comments, IPC-E-19-08, p. 9; Staff Comments, IPC-E-19-32,
pp.6-8.
7 Company response to Staff Production Request No. 25.
8STAFF COMMENTS APRIL 27,2022
Given the significant dollar amount requested by the Company for recovery and the $740
millions total investment made by the Company over the life of the plant, Staff believes that
additional oversight by the Company is warranted. This added oversight is especially needed as
the plant draws closer to retirement. Staff believes direct oversight should include more frequent
onsite inspection of capital projects with field reports documenting project activity and progress.
This oversight would be in addition to the Company's involvement for determining capital project
need, budgeting, and verification of payment. Without increased oversight there is less certainty
that capital investments made at the plant will be completed at a least-cost to customers.
2. New Depreciation Rates
Staff believes it is reasonable for the Company to identifu December 31,2030, as the end
of the depreciable life of coal assets for Bridger. Based on the Company's 2021 IRP, Staff
recognizes that the conversion of Units I and 2 to natural gas will extend the economic life of
coflrmon plant and capital investments needed for natural gas operation to the end of 2034. The
complexity of staggered individual unit closures at the end of 2023 for Units 1 and 2 as coal
generators and their conversion to natural gas in 2024, 2025 for Unit 3, and 2028 for Unit 4
reasonably supports a2030 date asthe depreciable life forall coal assets at Bridgerminimizing
the impact to ratepayers.
Although the Company has identified each unit's exit date for Bridger in the 2021 IRP, it
has not developed contractual terms necessary to allow for the potential earlier exit of a Bridger
unit by one of its co-owners. Larkin, Supp DI page 5. The terms of an earlier exit by one of the
co-owners may shift the economics of a unit closure date. In the latest IRPs for both utilities, the
difference in the unit exit dates are as much as 12 years for Unit 3 and 9 years for Unit 4 as seen
in the table below.
8 Idaho Power Company Depreciation Study Jim Bridger Plant dated December 31,2020.
9STAFF COMMENTS APRIL 27,2022
Table No.2
JIM BRIDGER POWER PLANT
IDAHO
POWER
2O2I IRP
EXIT
YEAR
PACIFICORP2021 IRP
EXIT YEAR
DIFFERENCE
IN YEARS
uNrT I (GAS CONVERSION 2024)2034 2037 J
uNrT 2 (GAS CONVERSTON 2024)2034 2037 J
UNIT 3 2025 2037 -12
LTNIT 4 2028 2037 -9
COMMON PLANT 2034 2037 -J
Depending on the structure of an exit agreement, the utility desiring to exit early may be
responsible to invest capital to maintain unit reliability and regulatory compliance for the
remaining co-owner while not receiving any benefit. Given that the co-owners have not defined
the contractual terms for exiting a unit, these additional costs are currently unknown and likely not
included in the cost of Bridger in the Company's IRP. This adds uncertainty that could change the
exit dates when these costs are included. Until these costs are considered in future IRPs, the
Company may need to adjust the depreciable life of coal assets for Bridger. Staff recommends
that the Company include costs identified in an exit agreement with PacifiCorp as soon as practical
and include these costs in future IRPs to eliminate it as a source of error in its IRP analysis.
Depending on changes to the exit dates in the IRP, the Company should also re-evaluate the
depreciable life of Bridger and file changes with the Commission if warranted.
3. Balancing Account
Staff believes that a balancing account is appropriate to track any difference in the annual
revenue requirement for the coal-related assets at Bridger. With a prudency determination through
2020, as recommended in this case, Staff believes that the 2020 revenue requirement should be
used as the base, and any differences from the 2020 revenue requirement should be recorded in
the balancing account year. The revenue requirement includes operations costs, depreciation costs,
and the return on net plant in service. However, the balance in the deferral, both positive and
negative, should not be subject to any carrying charges or retum. The fact that the Company is
authorized recovery of these amounts should be sufficient, as without this authorrty to create a
balancing account, the Company would not be able to recover these amounts short of annual
STAFF COMMENTS 10 APRIL 27,2022
general rate cases. In addition, with return on net plant in service already being included in the
calculation of revenue requirement and recorded in the balancing account, to include another return
in the deferral balance would be allowing the Company to earn additional return on its investment.
Staff believes it is appropriate for capital investments to be reviewed for prudency at
regular intervals. Considering the large uncertainties in the future of Bridger, Staff recommends
the Commission order the Company to submit reports to the Commission referencing projected
expenditures for Bridger after every lntegrated Resource Plan is acknowledged.
4. Rate Changes
Staff does not recommend any changes to the Company's rates in this case. There are
several uncertainties surrounding the future of Bridger. It remains possible that Units I and 2
could both be forced to close by the end of 2022. They could also potentially operate until 2028
and beyond. In addition, Idaho Power does not have an agreement with its operating partner to
exit the plant early. Staff does not support including estimates in rates when the future is this
uncertain.
The lack of immediate recovery should not harm the Company financially. According to
the IdaCorp 2021 Amual Report, the Company earned a9.2Yo Retum on Equity ("ROE") in
2021. In the confidential response to Production Request No. 3, the Company used an estimated
future test year to calculate the impact of having the proposed rate increase denied. The
Company's analysis showed that it would have a very small impact to their ROE. Staff believes
this will not significantly impact the Company's current financial position. However, if the
Company believes the small reduction to its ROE will cause a financial impact, it can file a
general rate case to address its financial standing. The Company's last general rate case was
filed in 2011 and since that time the Company has been able to maintain its financial standing
without the need to adjust base rates. Staff believes at this point in time the balancing account
will capture any differences in revenue requirement and ensure the Company recovers no more
and no less than the actual costs of associated with the closure of Bridger.
STAFF COMMENTS 11 APRIL 27,2022
STAT'F RECOMMENDATIONS
Staff recommends that the Commission:
o Determine that the capital investments in Jim Bridger through 2020 are prudently
incurred.
o Order the Company to establish a formalized process to document the circumstances,
the Company's justifications, and the final decisions made for capital investments in
its partner plants.
o Establish the accelerated depreciation rates proposed in the Company's Application
which fully depreciate the coal assets of the Jim Bridger Power Plant by December 31,
2030.
o Authorize the use of a balancing account, and necessary regulatory accounting, to
record differences between the 2020 revenue requirement and actual revenue
requirement for the coal related assets at the Jim Bridger Power Plant.
o Reject the Company's request to change rates at this time.
Respecttully submitted this z"/,day of April2022.
UJ LJI,
Chris Burdin
Deputy Attorney General
Technical Staff: Joe Terry
Rick Keller
Kevin Keyt
i:umisc/commentVipce2 1. I Tdhjtkskrk comments
STAFF COMMENTS 12 APRIL 27,2022
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 27TH DAY OF APRIL 2022, SERVED
THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN CASE NO.
IPC-E-2I-I7, BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
LISA NORDSTROM
IDAHO POWER COMPANY
PO BOX 70
BOrSE ID 83707-0070
E-MAIL : [e-mail]
dockets@ idahopower. com
PETER J RICHARDSON
RICHARDSON ADAMS PLLC
515 N 27TH STREET
BOISE ID 83702
E-MAIL: [e-mail]
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
710 N 6TH ST
BOISE ID 83702
E-MAIL: [e-mail]
ROSE MONAHAN
ANA BOYD
SIERRA CLUB
21OI WBSTER ST STE I3OO
OAKLAND CA946I2
E-MAIL : [e-mail]
ana.boyd@,si erracIub. org
KELSEY JAE
LAW FOR CONSCIOUS LEADERSHIP
920 N CLOVER DR
BOISE ID 83703
MATT LARKIN
IDAHO POWER COMPANY
PO BOX 70
BOISE rD 83707-0070
E-MAIL: [e-mail]
DR DON READING
6070 HILL ROAD
BOISE ID 83703
E-MAIL: dreading@,mindspring.com
ED JEWELL
DEPUTY CITY ATTORNEY
BOISE CITY ATTORNEYS OFF
PO BOX 500
BOrSE rD 83701-0500
E-MAIL : [e-mail]
ej [e-mail]
MICHAEL HECKLER
COURTNEY WHITE
CLEAN ENERGY OPPORTUNITIES FOR
IDAHO
3778 PLANTATION DR, SUITE 102
BOISE ID 83703
E-MAIL:
mike@cl eanenergyopportunities.com
[e-mail]
JIM SWIER
MICRON TECHNOLOGY INC
8OO SOUTH FEDERAL WAY
BOISE ID 83707
E-MAIL: [e-mail]-MAIL:tae.com
CERTIFICATE OF SERVICE
AUSTIN RUESCHHOFF
THORVALD A NELSON
AUSTIN W JENSEN
HOLLAND & HART LLP
555 tTrH ST STE 3200
DENVER CO 80202
E-MAIL : [e-mail]
trel spn@hollandhart. com
awj ensen@hollandhaxt. com
ac lee(Eho I landhart. com
gl [e-mail]
CERTIFICATE OF SERVICE