20231115Direct Donn English in Support of Stipulation and Settlement.pdf

BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )OF IDAHO POWER COMPANY FOR )CASE NO.IPC-E-23-11
AUTHORITY TO INCREASE ITS RATES )AND CHARGES FOR ELECTRIC SERVICE )IN THE STATE OF IDAHO AND FOR )ASSOCIATED REGULATORY )ACCOUNTING TREATMENT
DIRECT TESTIMONY OF DONN ENGLISH
IN SUPPORT OF THE STIPULATION
AND SETTLEMENT
IDAHO PUBLIC UTILITIES COMMISSION
NOVEMBER 15,2023
1 Q.Please state your name and business
2 address.
3 A.My name is Donn English.My business address is
4 11331 W.Chinden Blvd.,BLDG 8,STE 201-A,Boise,Idaho
5 83714.
6 Q.By whom are you employed and in what capacity?
7 A.I am employed by the Idaho Public Utilities
8 Commission ("Commission")as a Program Manager overseeing
9 the Accounting and Finance Department in the Utilities
10 Division.
11 Q.Please describe your educational background and
12 professional experience.
13 A.I was hired by the Commission in 2003 and I have
14 provided testimony in numerous proceedings.My educational
15 background and professional experience are provided in more
16 detail in Exhibit No.101.
17 Q.What is the purpose of your testimony in this
18 proceeding?
19 A.The purpose of my testimony is to describe the
20 Application of Idaho Power Company ("Idaho Power"or
21 "Company")for authority to increase its rates and charges
22 for electric service in Idaho,explain Staff's
23 investigation and evaluation of the Application,and
24 provide an overview of the stipulated revenue requirement.
25 Staff Witness Taylor Thomas will testify to the Cost of
CASE NO.IPC-E-23-11 English,D.(Stip)111/15/23 STAFF
1 Service,Rate Spread and Rate Design issues,and other
2 agreements discussed in the Settlement.
3 Q.How is your testimony organized?
4 A.My testimony is subdivided under the following
5 headings:
6 Background Page 2
7 Staff Investigation Page 4
8 Settlement Evaluation Page 6
9 Settlement Overview Page 7
10 Revenue/Expense Adjustments Page 7
11 Deferrals/Mechanism-Related Adj.Page 11
12 Revenue Sharing Mechanism Page 15
13 Background
14 Q.Please describe Idaho Power's original filing.
15
16 A.Idaho Power made its original filing with the
17 Commission on June 1,2023,requesting authority to
18 increase its revenue in Idaho by approximately $111.3
19 million,or 8.61%,which included a corresponding decrease
20 in the Power Cost Adjustment ("PCA")of $173.4 million and
21 a reduction to the annual Energy Efficiency Rider
22 collection of $3.5 million.The Company requested the
23 increase to be effective July 1,2023,recognizing that
24 the effective date would be suspended to January 1,2024.
25 The Company proposed a 10.4%Return on Equity ("ROE")
CASE NO.IPC-E-23-11 English,D.(Stip)211/15/23 STAFF
1 and a 4.895%cost of debt,for an overall return of 7.702%
2 and a capital structure of 51%equity and 49%debt.
3 Additionally,the Company proposed several changes to
4 the rate design intended to recover costs.Most notably,
5 the Company proposed increasing the residential monthly
6 Service Charge from $5.00 to $15.00 and increasing by
7 $10.00 each year until it reaches $35.00 after three years.
8 Q.How was this case processed after the Company's
9 filing was received?
10 A.The Commission issued a combined Notice of
11 Application,Notice of Suspension of Proposed Effective
12 Date,and Notice of Intervention Deadline ("Notice")on
13 June 23,2023.The Notice established an Intervention
14 Deadline of July 14,2023.Intervenor status was
15 subsequently granted to Clean Energy Opportunities for
16 Idaho ("CEO"),City of Boise,the Federal Executive
17 Agencies ("FEA"),the Industrial Customers of Idaho Power
18 ("ICIP"),Idaho Conservation League ("ICL"),IdaHydro,
19 Idaho Irrigation Pumpers Association,Inc.("IIPA"),
20 Micron Technology,Inc.("Micron"),NW Energy Coalition
21 ("NWEC"),and Walmart,Inc.("Walmart").These entities
22 are collectively referred to as the "Parties"along with
23 Staff and the Company.
24 The Parties participated in settlement conferences on
25 September 18,2023,and October 4-5,2023.Following the
CASE NO.IPC-E-23-11 English,D.(Stip)311/15/23 STAFF
1 settlement conferences and further discussions,agreements
2 were reached which ultimately resulted in the Stipulation
3 and Settlement ("Proposed Settlement")that was signed by
4 all Parties and filed on October 27,2023.
5 Staff Investigation
6 Q.What type of investigation did Staff conduct to
7 evaluate the Company's rate increase request?
8 A.Staff's approach in any general rate case is to
9 extensively review the Company's Application and
10 associated testimony and workpapers,identify adjustments
11 to the proposed revenue requirement,and prepare to file
12 testimony for a fully litigated proceeding.There were 15
13 Staff members analyzing this case consisting of auditors,
14 engineers,utility analysts,and compliance investigators.
15 Additionally,five supervisors reviewed the results of all
16 analysis.
17 Staff auditors reviewed the Company's test year
18 results of operations,capital budgets,capital spending
19 trends,operations and maintenance ("O&M")expenses and
20 trends.Additionally,Staff verified all of the Company's
21 calculations and assumptions with regard to the overall
22 revenue requirement.The auditors reviewed thousands of
23 transactions,selected samples,and performed transaction
24 testing in accordance with standard audit procedures.
25 Staff reviewed the Company's labor expenses,incentive
CASE NO.IPC-E-23-11 English,D.(Stip)411/15/23 STAFF
1 plans,and employee benefits to ensure the appropriate
2 level of expenditures are included in rates.
3 Staff reviewed both completed and proposed
4 Company investments to determine the prudency of capital
5 additions.Expenditures including insurance expense,
6 salaries,and O&M expenses were also examined.
7 Additionally,Staff investigated the Company's cost of
8 capital,capital structure,cost of service,revenue
9 normalization,and proposed rate design.In total,Staff
10 submitted over 300 production requests,performed an onsite
11 audit of the Company's books,and held several meetings
12 with Company personnel as a part of its comprehensive
13 investigation.
14 Following its investigation,Staff proposed over
15 40 separate revenue requirement adjustments during
16 settlement discussions.Many of which were either
17 completely or partially accepted by the Company.
18 Settlement Evaluation
19 Q.How did Staff determine that the overall Proposed
20 Settlement was reasonable?
21 A.In every settlement evaluation,Staff and other
22 parties must examine the risks of losing positions at
23 hearing and determine if the settlement is a better overall
24 outcome.Staff must evaluate each individual adjustment
25 and determine the likelihood of the Commission accepting
CASE NO.IPC-E-23-11 English,D.(Stip)511/15/23 STAFF
1 or rejecting Staff's rationale for the adjustment.
2 Ultimately,Staff's intent in every settlement conference
3 is to negotiate the best possible outcome for customers.
4 Q.Does Staff support the Proposed Settlement as
5 reasonable?
6 A.Yes,after a comprehensive review of the
7 Company's Application,a thorough audit of the Company's
8 books and records,an analysis of the Company's class cost
9 of service study,and extensive negotiations with the
10 Parties to the case,Staff supports the Proposed
11 Settlement.The Proposed Settlement offers a reasonable
12 balance between the Company's opportunity to earn a
13 reasonable return on its investment and affordable rates
14 for customers.Staff believes the Proposed Settlement is
15 in the public interest;is fair,just,and reasonable;and
16 should be approved by the Commission.
17 Settlement Overview
18 Q.Would you please briefly describe the terms of
19 the Proposed Settlement?
20 A.The Proposed Settlement provides for a reduction
21 in the Company's requested revenue requirement.Instead
22 of the Company's proposed increase of $111.3 million
23 (8.61%),under the Proposed Settlement,retail revenues
24 for Idaho customers will increase by $54.7 million (4.25%)
25 effective January 1,2024.For residential customers,the
CASE NO.IPC-E-23-11 English,D.(Stip)6
11/15/23 STAFF
1 monthly Service Charge will increase from $5.00 to $10.00
2 on January 1,2024.On January 1,2025,the monthly Service
3 Charge will increase to $15.00.For Small General Service
4 customers,the Service Charge will increase from $5.00 per
5 month to $25.00 per month.Other specific rate design
6 issues in the Proposed Settlement are discussed in greater
7 detail in Staff Witness Thomas'testimony.
8 Revenue/Expense Adjustments
9 Q.Please explain how the Proposed Settlement
10 addresses the Company's cost of capital.
11 A.The Parties agree to a 9.6%ROE and a 7.247%
12 overall rate of return applied to an Idaho jurisdictional
13 rate base of $3,816,351,478.The Company's cost of debt
14 and capital structure were not specified in the Proposed
15 Settlement.The impact of this cost of capital adjustment
16 is a reduction of $23,461,105 to the Company's requested
17 increase.Staff believes the overall cost of capital
18 adjustment is reasonable.However,Staff's review included
19 a different capital structure and 9.5%ROE when justifying
20 the agreed terms in this area.
21 Q.Will you please explain rate base adjustments
22 identified in the Proposed Settlement?
23 A.In its Application,the Company annualized large
24 capital projects that were placed in service during 2023
25 to include in its proposed rate base at End of Period
CASE NO.IPC-E-23-11 English,D.(Stip)711/15/23 STAFF
1 ("EOP")values.The Proposed Settlement removes the
2 Company's annualization adjustments,effectively including
3 those capital projects in rate base at an Average of
4 Monthly Averages ("AMA")value instead of EOP.
5 Additionally,Plant Held for Future Use ("PHFU")was also
6 removed from the Company's proposed rate base.The test
7 year methodology adjustment and the PHFU adjustment
8 decrease the Company's proposed revenue requirement by
9 approximately $8.3 million.Q.Please describe the
10 Battery Augmentation adjustment.
11 A.The final rate base adjustment removes the
12 Battery Augmentation projects for the Black Mesa and
13 Hemingway Battery Energy Storage Systems ("BESS")from the
14 Company's proposed rate base.This adjustment removes
15 approximately $2.3 million from the revenue requirement.
16 To offset the revenue impact of this adjustment,the
17 Company will be provided the opportunity to accelerate the
18 amortization of additional Accumulated Deferred Investment
19 Tax Credits ("ADITC").
20 Q.Please explain the expense adjustments outlined
21 in the Proposed Settlement.
22 A.The first expense adjustment relates to Company-
23 owned employee housing.Idaho Power provides housing for
24 employees in remote areas where it can be difficult to
25 attract qualified employees.To entice potential employees
CASE NO.IPC-E-23-11 English,D.(Stip)8
11/15/23 STAFF
1 to work in those remote areas,the Company offers one year
2 of free rent in a Company-owned residence.This adjustment
3 imputes the revenue that could have been received if Idaho
4 Power charged the market rate for rent on these properties.
5 The impact of this adjustment is a $136,485 reduction to
6 the revenue requirement.
7 Q.Please explain the adjustments for employee-
8 related expenses.
9 A.The Parties agreed to two separate adjustments
10 regarding employee labor costs.The first adjustment
11 removes the long-term "Pay at Risk"payments tied to the
12 financial performance of the Company for officers and
13 senior managers.Because the metrics to determine the
14 award and calculation of these incentive payments were
15 based on financial criteria that benefit shareholders,it
16 is appropriate to remove this amount from customers'rates.
17 The second employee labor adjustment removes a portion of
18 the Company's 2022 General Wage Adjustment ("GWA")and the
19 entirety of the 2024 GWA.The two adjustments reduced the
20 Company's rate request by approximately $14.4 million.
21 Q.Will you please discuss the remaining expense
22 adjustments?
23 A.The remaining expense adjustments are comprised
24 of an adjustment to the Company's proposed uncollectible
25 expense,miscellaneous adjustments,and a non-specific
CASE NO.IPC-E-23-11 English,D.(Stip)911/15/23 STAFF
1 rate reduction adjustment.The Company proposed an
2 Uncollectible Expense adjustment that used a 10-year
3 average of actual bad debt expenses.The Parties agreed
4 to reduce the Company's 10-year average to an amount that
5 is consistent with the Company's recent bad debt
6 experience.
7 The Miscellaneous Expense adjustments remove expenses
8 associated with 1)a portion of the Company's billing
9 inserts that did not provide specific benefits to
10 customers,2)injuries and damages caused by employee
11 actions,3)Company airplane flights not associated with
12 providing service to customers and the associated
13 maintenance,4)advertising to enhance the Company's image,
14 5)certain credit card expenses lacking documentation
15 and/or for purchases that did not provide service to
16 customers,6)unrealized benefits of the Company's mobile
17 application,and 7)board of directors'compensation and
18 expenses.
19 The Proposed Settlement also includes a Non-Specific
20 adjustment of approximately $4.2 million.This adjustment
21 accounts for a portion of the value of other adjustments
22 proposed by Staff and intervenors not specifically accepted
23 by the Company and is used to arrive at the stipulated
24 revenue increase of 4.25%.
25 Deferrals/Mechanism-Related Adjustments
CASE NO.IPC-E-23-11 English,D.(Stip)10
11/15/23 STAFF
1 Q.Will you please explain the Deferrals and other
2 Mechanism-Related Adjustments?
3 A.Yes,the final set of adjustments are made to
4 the Company's proposed revenue requirement to adjust for
5 either the timing of recovery for the Company or amounts
6 moved to other mechanisms for recovery.The first of these
7 adjustments relates to the Company's Energy Efficiency
8 Rider ("Rider")funded activities.In Order No.33908,
9 the Commission established a 2%cap on wage increases
10 funded through the Rider to address Staff's concerns that
11 Rider-funded labor expenses increase annually without the
12 scrutiny labor expenses receive during a general rate case.
13 Rather than continue with capping the annual wage increases
14 in the Rider,the Company proposed to move all Rider-funded
15 labor expenses (approximately $3.5 million)to base rates.
16 The Company also proposed a corresponding decrease in the
17 Schedule 91,Energy Efficiency Rider,from the current 3.1%
18 to 2.25%.
19 The Parties agree that the Energy Efficiency Rider-
20 funded labor should be funded through base rates.
21 Additionally,the Parties agree that existing obligations
22 for the Low-Income Weatherization Assistance Program ($1.2
23 million)and low-income education ($125,000)should be
24 moved from base rates to the Rider.By funding these
25 income-qualified programs through the Rider,interested
CASE NO.IPC-E-23-11 English,D.(Stip)1111/15/23 STAFF
1 parties can request changes to the Commission Ordered
2 funding levels without having to wait until the Company
3 files a general rate case.To account for approximately
4 $1.3 million in low-income program funding shifted from
5 base rates to the Rider,the Parties agree to increase the
6 Company's proposed Rider collection rate from 2.25%to
7 2.35%.
8 Q.What are the terms of the Proposed Settlement
9 regarding the Company's participation in the Western
10 Resource Adequacy Program ("WRAP")?
11 A.Consistent with Order No.35920 in Case No.IPC-
12 E-23-08,the Parties agree that the Company will defer its
13 test year WRAP expenses in a regulatory asset account for
14 future recovery when the Company can show realized
15 benefits.This reduced the Company's revenue requirement
16 by $585,182.
17 Q.Please describe the Intervenor Funding
18 Amortization?
19 A.The Company deferred all intervenor funding
20 ordered since its 2011 general rate case and proposed to
21 recover the balance in this case.The Parties agree to
22 amortize the deferral balance over seven years,which
23 reduces the Company's revenue requirement by $235,319.
24 Q.Please describe how the Proposed Settlement
25 accounts for the Company's Wildfire Expenses and
CASE NO.IPC-E-23-11 English,D.(Stip)1211/15/23 STAFF
1 Amortization?
2 A.The Parties agree to remove various one-time
3 wildfire-related costs that will not continue in the
4 future,reducing the revenue requirement by $328,055.The
5 Parties also agree to allow Idaho Power to continue to
6 defer incremental vegetation management expenses and
7 incremental insurance expenses above the 2022 actuals
8 amount until the earlier of the Company's next general rate
9 case or 2025.Additionally,expenses related to the
10 Covered Wire Evaluation pilot and the Vegetation Management
11 Satellite and Aerial Patrols pilot will continue to be
12 deferred through 2025.
13 The Company proposed to begin amortizing a portion of
14 the wildfire deferral in this case.The Parties agree to
15 begin amortizing the total balance of the wildfire deferral
16 over seven years,which will increase the Company's revenue
17 requirement.Staff was concerned about a pancaking effect
18 in future rate cases and believes that amortization of the
19 full balance is reasonable.The balance will be offset by
20 $400,000 of grants received for the Fire Mesh and
21 Vegetation Management Satellite projects.The net effect
22 of all wildfire expense and amortization adjustments is an
23 increase of approximately $1.6 million to the Company's
24 revenue requirement.
25 Q.Please describe the Net Power Supply Expense
CASE NO.IPC-E-23-11 English,D.(Stip)1311/15/23 STAFF
1 ("NPSE")adjustment?
2 A.This adjustment was made to update the modelling
3 assumptions related to wheeling that reduces the Company's
4 filed NPSE by $5,651,170.Net of the PCA Transfer
5 Adjustment proposed by the Company in its Application,this
6 adjustment results in a net reduction to the Company's
7 revenue requirement of $291,972.
8 Revenue Sharing Mechanism
9 Q.Please describe the Company's revenue sharing
10 mechanism and the terms in the Proposed Settlement
11 regarding the mechanism and ADITC?
12 A.In Order No.30978,the Commission approved a
13 stipulation that created a revenue sharing mechanism based
14 on the Company's actual earned ROE each year.This
15 mechanism has been modified and extended through several
16 orders since inception.The mechanism provides benefits
17 to customers if the Company's actual earned ROE for any
18 given year is greater than a predetermined ROE.When the
19 actual earned ROE exceeds the allowed ROE,the Company
20 returns a portion of the excess earnings to customers,
21 either through a rate reduction in the Company's PCA or an
22 offset to the Company's pension deferral.If the Company's
23 actual earned ROE is below a certain threshold,the Company
24 is authorized to accelerate the amortization of ADITC,up
25 to $25 million annually,to improve its actual ROE.
CASE NO.IPC-E-23-11 English,D.(Stip)1411/15/23 STAFF
1 Under the terms of the Proposed Settlement,the
2 Parties agreed to continue the mechanism,modified to
3 include an additional amount of Investment Tax Credits
4 ("ITC")equal to the incremental ITC generated from the
5 Company's investment in the Black Mesa and Hemingway BESS
6 projects.The Parties also agree to remove the $25 million
7 cap on the annual accelerated amortization of ITC.The
8 Proposed Settlement establishes a threshold of 9.12%that
9 the Company's ROE must be below for it to accelerate the
10 amortization of ITCs.If the Company's ROE is above 9.6%,
11 revenue sharing will be provided as a benefit in the PCA.
12 The Company will no longer be required to use a portion of
13 the excess earnings to offset its customer-funded pension
14 obligations.
15 Q.Do you have any other comments on the Proposed
16 Settlement?
17 A.Yes.The Proposed Settlement is a result of
18 detailed analysis and thoughtful negotiations by all
19 Parties.The Proposed Settlement results in a mitigated
20 rate increase for customers,a reasonable resolution on
21 several contested issues while identifying areas requiring
22 additional discourse to resolve.The Proposed Settlement
23 represents a compromise between the Parties to establish
24 just,fair,and reasonable rates while providing the
25 Company with additional cash flows necessary to finance
CASE NO.IPC-E-23-11 English,D.(Stip)1511/15/23 STAFF
1 its electric utility operations.Staff recommends that
2 the Commission approve the Proposed Settlement,signed by
3 all Parties,as filed.
4 Q.Does this conclude your testimony in this
5 proceeding?
6 A.Yes,it does.
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
CASE NO.IPC-E-23-11 English,D.(Stip)1611/15/23 STAFF
Professional Qualifications
of
Donn English
Program Manager -Accounting and Finance
Idaho Public Utilities Commission
EDUCATION
Mr.English graduated from Boise State University in 1998 with aBachelorofBusinessAdministrationdegreeinAccounting.Hisstudiesconcentratedoncorporatefinanceandtaxation.He was
a member of the Alpha Beta Psi honor society for Accountingstudents.He completed the Annual Regulatory Studies Program,
the Advanced Regulatory Studies Program,and the Accounting andRatemakingCourseofferedthroughtheInstituteofPublic
Utilities at Michigan State University.Additionally,heregularlyattendsmeetingandconferencessponsoredbytheNationalAssociationofRegulatoryCommissioners(NARUC)and theSocietyofUtilityandRegulatoryFinancialAnalysts.
In 2001,Mr.English became a designated member of the AmericanSocietyofPensionProfessionalsandActuaries(ASPPA)and wasawardedtheprofessionaldesignationofQualifiedPensionAdministrator(QPA)and Qualified 401(k)Administrator (QKA).Mr.English was also a member of the Association of Certified
Fraud Examinators.
BUSINESS EXPERIENCE
Prior to joining the Idaho Public Utilities Commission (IPUC),
Mr.English was a Trust Accountant with a pensionadministration,actuarial,and consulting firm in Boise,Idaho.
In 1999,he was promoted to Pension Administrator,and in 2001hewaspromotedtoPensionConsultant.In that capacity,Mr.English performed actuarial calculations and the required non-discrimination calculations for hundreds of qualified retirementplans.He completed and filed Form 5500s and represented
clients during audits by the Department of Labor and the
Internal Revenue Service.He also participated on the taskforcethatwrotequestionsfortheASPPAadministratorandactuarialexams.
Exhibit No.101
Case Nos.IPC-E-23-11
D.English,Staff
11/15/23 Page 1 of 2
Mr.English joined the IPUC in 2003 as a Staff Auditor.In
2016,he was promoted to Audit Team Lead,and in 2018 he became
the Program Manager for the Accounting and Finance Department
within the Utilities Division.In 2020,Mr.English accepted
the responsibility of supervising the Technical Analysis and
Energy Efficiency team and was the Program Manager for that team
until 2022.At the Commission,Mr.English has audited a number
of utilities including electric,water,and natural gas
companies,and provided comments and testimony in numerous cases
dealing with general rates,tax issues,pension issues,
depreciation and other accounting issues,and other regulatory
policy decisions.Mr.English participates in the Energy
Efficiency Advisory Groups and External Stakeholder Advisory
Committees for Idaho Power,Avista Utilities,Rocky Mountain
Power,and Intermountain Gas Company.He is a member of several
of the National Association of Regulatory Utility Commissioners
(NKRUC)working groups including the NARUC State Working Group
on Performance-Based Regulation,the NARUC State Working Group
on Electric Vehicles,and the NARUC State Working Group on Grid-
Interactive Efficient Buildings in collaboration with the
National Association of State Energy Officials (NASEO).Mr.
English is the Chair of the NARUC Staff Subcommittee on
Education and Research and the Vice Chair of the NARUC Staff
Subcommittee of Accounting and Finance.Mr.English is also a
faculty member of NARUC Rate School.
Exhibit No.101
Case Nos.IPC-E-23-11
D.English,Staff
11/15/23 Page 2 of 2
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 15th DAY OF NOVEMBER 2023,SERVED THE FOREGOING DIRECT TESTIMONY OF DONN ENGLISH IN SUPPORTOFTHESTIPULATIONANDSETTLEMENT,IN CASE NO.IPC-E-23-11,BY E-MAILING A COPY THEREOF,TO THE FOLLOWING:
LISA D NORDSTROM TIMOTHY TATUM
DONOVAN E WALKER CONNIE ASCHENBRENNERMEGANGOICOECHEAALLENMATTLARKIN
IDAHO POWER COMPANY IDAHO POWER COMPANY
PO BOX 70 PO BOX 70
BOISE ID 83707-0070 BOISE ID 83707-0070
E-MAIL:E-MAIL:[e-mail]
[e-mail] [e-mail]
[e-mail] [e-mail]
[e-mail]
[e-mail]
KELSEY JAE MICHAEL HECKLER
LAW FOR CONSCIOUS LEADERSHIP COURTNEY WHITE
920 N CLOVER DR CLEAN ENERGY OPPORTUNITIES
BOISE ID 83703 3778 PLANTATION RIVER DR
E-MAIL:[e-mail] STE 102
BOISE ID 83703
E-MAIL:
[e-mail]
[e-mail]
ERIC L OLSEN LANCE KAUFMAN PhD
ECHO HAWK &OLSEN PLLC 2623 NW BLUEBELL PLACE
PO BOX 6119 CORVALLIS OR 97330
POCATELLO ID 83205 E-MAIL:lance aegisinsight.com
E-MAIL:elo echohawk.com
PETER J RICHARDSON DR DON READING
RICHARDSON ADAMS PLLC 280 SILVERWOOD WAY
515 N 27THST EAGLE ID 83616
BOISE ID 83702 E-MAIL:[e-mail]
E-MAIL:peter richardsonadams.com
CERTIFICATE OF SERVICE
JIM SWIER AUSTIN RUESCHHOFF
MICRON TECHNOLOGY INC THORVALD A NELSON
8000 S FEDERAL WAY AUSTIN W JENSEN
BOISE ID 83707 HOLLAND &HART LLP
E-MAIL:[e-mail] 555 17TH ST STE 3200
DENVER CO 80202
E-MAIL:[e-mail]
[e-mail]
[e-mail]
[e-mail]
clmoser hollandhart.com
TOM ARKOOSH
ARKOOSH LAW OFFICES
PO BOX 2900
BOISE ID 83701
[e-mail]
erin.cecil arkoosh.com
ED JEWELL WIL GEHL
DARRELL EARLY ENERGY PROGRAM MANAGER
DEPUTY CITY ATTORNEY BOISE CITY DEPT OF PUBLIC WORKS
BOISE CITY ATTORNEY'S OFFICE PO BOX 500
PO BOX 500 BOISE ID 82701-0500
BOISE ID 83701-0500 E-MAIL:weehl cityofboise.org
E-MAIL:[e-mail]
ejewell citvofboise.org
dearly citvofboise.org
MATTHEW NYKIEL BRAD HEUSINKVELD
ID CONSERVATION LEAGUE ID CONSERVATION LEAGUE
710 N 6TH ST 710 N 6TH ST
BOISE ID 83702 BOISE ID 83702
E-MAIL:mathew.nykiel amail.com E-MAIL:
[e-mail]
PETER MEIER DWIGHT ETHERIDGE
US DEPT OF ENERGY EXETER ASSOCIATES
1000 INDEPENDENCE AVE SW 5565 STERRETT PLACE
WASHINGTON DC 20585 STE 310
E-MAIL:[e-mail] COLUMBIA MD 21044
E-MAIL:detheridge exeterassociates.com
CERTIFICATE OF SERVICE
F.DIEGO RIVAS BENJAMIN J OTTO
NW ENERGY COALITION 1407 W COTTONWOOD CT
1101 8TH AVE BOISE ID 83702
HELENA MT 59601 E-MAIL:[e-mail]
E-MAIL:diego nwenergy.org
NORMAN M SEMANKO JUSTINA A CAVIGLIA
PARSONS BEHLE &LATIMER PARSONS BEHLE &LATIMER
800 W MAIN ST STE 1300 50 W LIBERTY ST STE 750
BOISE ID 83702 RENO NV 89502
E-MAIL:[e-mail] E-MAIL:[e-mail]
STEVE W CHRISS
DIR ENERGY SERVICES
WALMART INC
2608 SOUTHEAST J ST
BENTONVILLE AR 72716
E-MAIL:[e-mail]
SECRETARY
CERTIFICATE OF SERVICE