20060403Intercompany Administrative Services Agreement.pdf

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900 sow. Fifth Avenue. Suite 2600
Portland, Oregon 97204
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ATTORNEYS AT LAW . i i
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March 31 2006
JAMESM. VANNOSTRAND
Direct [phone]
jrnvann ostrand~stoe I. com
VIA OVERNIGHT MAIL
Ms. Jean D. Jewell
Commission Secretary
Idaho Public Utilities Commission
472 W. Washington
Boise, ill 83702-0074
Re:Case No. PAC-O5-
Joint Application of MidAmerican Energy Holdings Company and PacifiCorp d/b/a
Utah Power & Light Company for an Order Authorizing Proposed Transaction
Dear Ms. Jewell:
Enclosed for filing in the above proceeding is a copy of the Intercompany Administrative
Services Agreement ("IASA") between MidAmerican Energy Holdings Company ("MEHC"
and its subsidiaries. Under the terms of Commitment 13 in the Idaho commitments attached to
and incorporated in the Commission s Order No. 29998 issued on March 14, 2006 in the above
proceeding, MEHC and PacifiCorp committed to file the IASA with the Commission.
Commitment 13 provides that:
The Inter-company Administrative Services Agreement (IASA) will include the
corporate and affiliate cost allocation methodologies. The IASA will be filed
with the Commission as soon as practicable after the closing of the transaction.
Approval of the IASA will be requested if required by law or rule, but approval
for ratemaking purposes will not be requested in such filing. Refer to
Commitment 14 (t). Amendments to the IASA will also be filed with the
Commission.
Consistent with Commitments 13 and 14( t), 1 approval for ratemaking purposes is not requested
in this filing. It is PacifiCorp s understanding that the reasonableness of payments under the
1 Commitment 14(f) provides that "(aJny corporate cost allocation methodology used for rate
setting, and subsequent changes thereto, will be submitted to the Commission for approval if required by
law or rule.Oregon
Washington
California
Utah
Portlnd3-1546187.10051851-00005 Idaho
Ms. Jean D. Jewell
March 31 , 2006
Page 2
IASA by PacifiCorp to MEHC and its subsidiaries will be considered in subsequent general rate
proceedings in Idaho.
The proposed effective date of the IASA is March 31 , 2006. The IASA governs the provision of
administrative services between and among MEHC and its subsidiaries, and includes
administrative services that are provided by: MEHC to its subsidiaries, the subsidiaries to
MEHC , and MEHC subsidiaries to other MEHC subsidiaries.Article of the IASA. Under the
IASA, charges for administrative services are calculated on the basis of direct charges, service
charges, or pursuant to an allocation methodology (in the case of costs incurred for the general
benefit of the entire corporate group). Article of the IASA. The IASA identifies the principles
that will be followed in any cost allocation methodology used for assigning corporate and
affiliate costs. Article of the IASA. These principles are consistent with the principles to which
MEHC and PacifiCorp committed in Commitment 14.3 The IASA also includes requirements
2 For affiliate charges or costs not covered by the provisions ofthe IASA, Commitment I 39
requires MEHC and PacifiCorp to use asymmetrical pricing, if a readily identifiable market for the goods
services or assets exists, and if the transaction involves a cost of more than $500 000.
3 Commitment 14 provides that "(aJny proposed cost allocation methodology for the allocation of
corporate and affiliate investments, expenses, and overheads, required by law or rule to be submitted to
the Commission for approval, will comply with the following principles:
a) For services rendered to PacifiCorp or each cost category subject to allocation to PacifiCorp
by MEHC or any of its affiliates, MEHC must be able to demonstrate that such service or
cost category is necessary to PacifiCorp for the performance of its regulated operations, is not
duplicative of services already being performed within PacifiCorp, and is reasonable and
prudent.
b) Cost allocations to PacifiCorp and its subsidiaries will be based on generally accepted
accounting standards; that is, in general, direct costs will be charged to specific subsidiaries
whenever possible and shared or indirect costs will be allocated based upon the primary cost-
driving factors.
c) MEHC and its subsidiaries will have in place positive time reporting systems adequate to
support the allocation and assignment of costs of executives and other relevant personnel to
PacifiCorp.
d) An audit trail will be maintained such that all costs subject to allocation can be specifically
identified, particularly with respect to their origin. In addition, the audit trail must be
adequately supported. Failure to adequately support any allocated cost may result in denial of
its recovery in rates.
e) Costs which would have been denied recovery in rates had they been incurred by PacifiCorp
regulated operations will likewise be denied recovery whether they are allocated directly or
indirectly through subsidiaries in the MEHC group.
f) Any corporate cost allocation methodology used for rate setting, and subsequent changes
thereto, will be submitted to the Commission for approval if required by law or rule.
Port1nd3-1546187.l 0051851-00005
Ms. Jean D. Jewell
March 31 , 2006
Page 3
regarding payment arrangements (Article 4(b)), the maintenance of books and records necessary
to support the charges for administrative services (Article 7), and the treatment of confidential
information (Articles 15 and 16).
Please contact me if the Commission or its Staff has any questions regarding this filing. Thank
you for your assistance.
JMV:jlf
Enclosures
cc:Mark C. Moench
Port1nd3-1546187.10051851-00005
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
Intercompany Administrative Services Agreement
INTERCOMPANY ADMINISTRATIVE SERVICES AGREEMENT
BETWEEN
MIDAMERICAN ENERGY HOLDINGS COMPANY
AND
ITS SUBSIDIARIES
This Intercompany Administrative Services Agreement ("Agreemenf) is entered into as of March 31 J 2006
by and between MidAmerican Energy Holdings Company (hereinafter the "Company ) and its direct and
indirect subsidiaries (hereinafter the .Subsidiaries ) (each a "Party" and together the "Parties
WHEREAS, the Company provides senior management, executive oversight and other administrative
services that provide value to and benefit the Subsidiaries as entities in the consolidated group;
WHEREAS, the Subsidiaries have access to professional, technical and other specialized resources that
the Company may wish to utilize from time to time in the provision of such administrative services; and
WHEREAS, the Company and Subsidiaries may desire to utilize the professional, technical and other
specialized resources of certain Subsidiaries;
NOW, THEREFORE, in consideration of the premises and mutual agreements set forth herein, the
Company and Subsidiaries agree as follows:
ARTICLE 1. PROVISION OF ADMINISTRATIVE SERVICES
Upon and subject to the terms of this Agreement, services will be provided between and among the
Company and its Subsidiaries that are not directly applicable to the production, distribution or sale of a
product or service available to customers of the Company or its subsidiaries ("Administrative Services
For purposes of this Agreement, Administrative Services shall include, but not be limited to the following:
a) services by executive, management, professional, technical and clerical employees;
b) financial services, payroll processing services, employee benefits participation, supply chain and
purchase order processing services, tax and accounting services, contract negotiation and
administration services, risk management services, environmental services and engineering and
technical services;
c) the use of office facilities, including but not limited to office space, conference rooms, furniture,
equipment, machinery, supplies, computers and computer software, insurance policies and other
personal property;
d) the use of automobiles, airplanes, other vehicles and equipment;
To obtain specialized expertise or to achieve efficiencies, the following s~uations may arise under this
Agreement whereby Administrative Services may be provided between and among the Company and its
Subsidiaries:
a) The Company may directly assign or allocate common costs to the Subsidiaries,
b) The Company may procure Administrative Services from the Subsidiaries for its own benefrt,
c) The Company may procure Administrative Services from the Subsidiaries for subsequent
allocation to some or all Subsidiaries commonly benefiting, or
d) The Subsidiaries may procure Administrative Services from each other.
ARTICLE 2. DEFINITIONS
For purposes of this Agreement these terms shall be defined as follows:
(a) "Laws" shall mean any law, statute, rule, regulation or ordinance.
(b) "State Commissions" shall mean any state public utility commission or state public service
commission w~h jurisdiction over a rate-regulated Party.
(c) "Subsidiaries" shall mean current and Mure direct and indirect majority-owned subsidiaries of the
Company.
ARTICLE 3. EFFECTIVE DATE
This Agreement shall be effective as of the date set forth above; provided, however, that in those jurisdictions
which regulatory approval is required before the Agreement becomes effective, the effective date shall be as of
the date of such approval.
ARTICLE 4. CHARGES AND PAYMENT
(a) CHARGES.
Parties shall charge for Administrative Services on the following basis:
(i) Direct Charges: The Party receiving the benefit of Administrative Services ("Recipient Party") will
be charged for the operating costs incurred by the Party providing the Administrative Services
Providing Party"), including, but not limited to, allocable salary and wages, incentives, paid
absences, payroll taxes, payroll add~ives (insurance premiums, hea~h care and retirement
benefrts and the like), direct non-labor costs, if any, and similar expenses, and reimbursement of
out-of-pocket third party costs and expenses.
(ii) Service Charges: Costs that are impractical to charge directly but for which a cost/benefit
relationship can be reasonably identified. A practical allocation method will be established by
Providing Party that allocates the cost of this service equ~ably and consistently to the Recipient
Party. Any changes in the methodology will be communicated in writing to rate-regulated
subsidiaries at least 180 days before the implementation of the change.
(iii) Allocations: Costs incurred for the general benefit of the entire corporate group for which direct
charging and service charges are not practical. An allocation methodology will be established
and used consistently from year to year. Any changes to the methodology will be communicated
Page 2
in wrning to rate-regulated subsidiaries at least 180 days before the implementation of the
change.
The charges constitute full compensation to the Providing Party for all charges, costs and expenses
incurred by the Providing Party on behalf of the Recipient Party in providing the Administrative Services,
unless otherwise specifically agreed to in wrning between the Parties.
If events or circumstances arise which, in the opinion of the Parties, render the costs of providing any
Administrative Services materially different from those charged under a specific rate or formula then
effect, the specific rate or formulas shall be equitably adjusted to take into account such events or changed
circu mstances.
Providing Parties will bill each and all Recipient Parties, as appropriate, for Administrative Services
rendered under this Agreement in as specific a manner as practicable. To the extent that direct charging
for services rendered is not practicable, the Providing Party may utilize allocation methodologies to assign
charges for services rendered to the Recipient Party, reflective of the drivers of such costs. Such
allocation methodologies may utilize allocation bases that include, but are not limned to: employee labor,
employee counts, assets, and mu~i-factor allocation formulae.
Any cost allocation methodology for the assignment of corporate and affiliate costs will comply with the
following principles:
i) For Administrative Services rendered to a rate-regulated subsidiary of the Company or each
cost category subject to allocation to rate-regulated subsidiaries by the Company, the
Company must be able to demonstrate that such service or cost category is reasonable for the
rate-regulated subsidiary for the performance of ns regulated operations, is not duplicative of
Administrative Services already being performed within the rate-regulated subsidiary, and is
reasonable and prudent.
ii) The Company and Providing Parties will have in place positive time reporting systems
adequate to support the allocation and assignment of costs of executives and other relevant
personnel to Recipient Parties.
iii) Parties must maintain records sufficient to specifically identify costs subject to allocation,
particularly wnh respect to their origin. In addftion, the records must be adequately supported
in a manner sufficient to justify recovery of the costs in rates of rate-regulated subsidiaries.
iv) It is the responsibility of rate-regulated Recipient Parties to this Agreement to ensure that costs
which would have been denied recovery in rates had such costs been directly incurred by the
regulated operation are appropriately identified and segregated in the books of the regulated
operation.
(b) PAYMENT.
(i) Each Providing Party shall bill the Recipient Party monthly for all charges pursuant to
this Agreement via billings to the Company. The Company, in ns capacity as a clearinghouse for
Page 3
intercompany charges wnhin the Company shall aggregate all charges and bill all Recipient Parties in a
single bill. Full payment to or by the Company for all Administrative Services shall be made by the end of
the calendar month following the intercompany charge. Charges shall be supported by reasonable
documentation, which may be maintained in electronic form.
(ii) The Parties shall make adjustments to charges as required to reflect the discovery of
errors or omissions or changes in the charges. The Parties shall conduct a true-up process at least
quarterly and more frequently if necessary to adjust charges based on reconciliation of amounts charged
and costs incurred. It is the intent of the Parties that such true-up process will be conducted using
substantially the same process, procedures and methods of review as have been in effect prior to
execution of this Agreement by the Parties.
ARTICLE 5. GENERAL OBLIGATIONS: STANDARD OF CARE
Rate-regulated Parties will comply wnh all applicable State and Federal Laws regarding affiliated interest
transactions, including timely filing of applications and reports. The Parties agree not to cross-subsidize
between the rate-regulated and non-rate-regulated businesses or between any rate-regulated businesses,
and shall comply with any applicable State Commission Laws and orders. Subject to the terms of this
Agreement, the Parties shall perform their obligations hereunder in a commercially reasonable manner.
ARTICLE 6. TAXES
Each Party shall bear all taxes, duties and other similar charges except taxes based upon ns gross income
(and any related interest and penalties), iltlJosed as a result of ns receipt of Administrative Services under
this Agreement, including without limitation sales, use, and value-added taxes.
ARTICLE 7. ACCOUNTING AND AUDITING
Providing Parties and the Company shall maintain such books and records as are necessary to support the
charges for Administrative Services, in sufficient detail as may be necessary to enable the Parties to satisfy
applicable regulatory requirements ("Records ). All Parties:
(a) shall provide access to the Records at all reasonable times;
(b) shall maintain the Records in accordance wnh good record management practices and with at
least the same degree of completeness, accuracy and care as n maintains for ns own records; and
(c) shall maintain ns own accounting records, separate from the other Party's accounting records.
Subject to the provisions of this Agreement, Records supporting intercoltlJany billings shall be available for
inspection and copying by any qualified representative or agent of enher Party or ns affiliates, at the
expense of the inquiring Party. In addnion, State Commission staff or agents may audn the accounting
records of Providing Parties that form the basis for charges to rate-regulated subsidiaries, to determine the
reasonableness of allocation factors used by the Providing Party to assign costs to the Recipient Party and
amounts subject to allocation or direct charges. All Parties agree to cooperate fully wnh such audns.
Page 4
ARTICLE 8. BUDGETING
In advance of each budget year, Providing Parties shall prepare and deliver to the Recipient Parties, for
their review and approval, a proposed budget for Administrative Services to be performed during that year.
The approved schedule of budgeted Administrative Services shall evidence the base level of
Administrative Services. The schedule shall be updated at least annually. Each Party shall promptly notify
the other Party in writing of any requested material change to the budget costs for any service being
provided.
ARTICLE 9. COOPERATION WITH OTHERS
The Parties will use good tanh efforts to cooperate with each other in all matters relating to the provision
and receipt of Administrative Services. Such good tanh cooperation will include providing electronic access
in the same manner as provided other vendors and contractors to systems used in connection with
Administrative Services and using commercially reasonable efforts to obtain all consents, licenses,
sublicenses or approvals necessary to permR each Party to perform its obligations. Each Party shall make
available to the other Party any information required or reasonably requested by the other Party regarding
the performance of any Administrative Service and shall be responsible for timely providing that information
and for the accuracy and completeness of that information; provided, however, that a Party shall not be
liable for not providing any information that is subject to a confidentiality obligation owed by it to a person or
regulatory body other than an affiliate of it or the other Party. Either Party shall not be liable for any
impairment of any Administrative Service caused by it not receiving information , either timely or at all , or by
it receiving inaccurate or incomplete information from the other Party that is required or reasonably
requested regarding that Administrative Service. The Parties will cooperate with each other in making such
information available as needed in the event of any and all internal or external audits, utility regulatory
proceedings, legal actions or dispute resolution. Each Party shall fully cooperate and coordinate with each
other's employees and contractors who may be awarded other work. The Parties shall not commit or permit
any act, which will interfere wRh the performance of or receipt of Administrative Services by either Party'
employees or contractors.
ARTICLE 10. COMPLIANCE WITH ALL LAWS
Each Party shall be responsible for (i) its compliance with all laws and governmental regulations affecting
its business, including but not limited to, laws and governmental regulations governing federal and state
affiliate transactions, workers' compensation, heaRh, safety and security, and (ii) any use R may make of
the Administrative Services to assist it in complying with such laws and governmental regulations.
ARTICLE 11. LIMITATION OF LIABILITY
NotwRhstanding any other provision of this Agreement and except for (a) rights provided under Article 12 in
connection with Third-Party Claims, (b) direct or actual damages as a resuR of a breach ofthis Agreement,
and (c) liability caused by a Party's negligence or willful misconduct, no Party nor their respective directors,
officers, employees and agents, will have any liability to any other Party, or their respective directors,
officers, employees and agents, whether based on contract, warranty, tort, strict liability, or any other
theory, for any indirect, incidental, consequential, special damages, and no Party, as a resuR of providing a
Service pursuant to this Agreement, shall be liable to any other Party for more than the cost of the
Administrative Service(s) related to the claim or damages.
Page 5
ARTICLE 12. INDEMNIFICATION
Each of the Parties will indemnify, defend, and hold harmless each other Party, members of Rs Board of
Directors, officers, employees and agents against and from any third-party claims resulting from any
negligence or willful misconduct of a Party's employees, agents, representatives or subcontractors of any
tier, their employees, agents or representatives in the performance or nonperformance of its obligations
under this Agreement or in any way related to this Agreement. If a Third-Party claim arising out of or in
connection wRh this Agreement results from negligence of muhiple Parties (including their employees,
agents, suppliers and subcontractors), each Party will bear liability wRh respect to the Third-Party Claim in
proportion to Rs own negligence.
ARTICLE 13. DISPUTE RESOLUTION
The Parties shall promptly resolve any conflicts arising under this Agreement and such resolution shall be
final. If applicable, adjustments to the charges will be made as required to reflect the discovery of errors or
omissions in the charges. If the Parties are unable to resolve any service, performance or budget issues or if
there is a material breach of this Agreement that has not been corrected within ninety (90) days, representatives
of the affected Parties will meet promptly to review and resolve those issues in good faith.
ARTICLE 14. TERMINATION FOR CONVENIENCE
A Party may terminate as participation in this Agreement eaher wRh respect to all, or wah respect to any
one or more, of the Administrative Services provided hereunder at any time and from time to time, for any
reason or no reason, by giving notice of termination at least sixty (60) days in advance of the effective date
of the termination to enable the other Party to adjust its available staffing and facilities. In the event of any
termination with respect to one or more, but less than all, Administrative Services, this Agreement shall
continue in full force and effect wRh respect to any Administrative Services not terminated hereby. If this
Agreement is terminated in whole or in part, the Parties will cooperate in good faith with each other in all
reasonable respects in order to effect an efficient transition and to minimize the disruption to the business
of all Parties, including the assignment or transfer of the rights and obligations under any contracts.
Transitional assistance service shall include organizing and delivering records and documents necessary
to allow continuation of the Administrative Services, including delivering such materials in electronic forms
and versions as reasonably requested by the Party.
ARTICLE 15. CONFIDENTIAL INFORMA TIO~ONDISCLOSURE
To the fullest extent allowed by law, the provision of any Administrative Service or reimbursement for any
Administrative Service provided pursuant to this Agreement shall not operate to impair or waive any
privilege available to either Party in connection with the Administrative Service, its provision or
reimbursement for the Administrative Service.
All Parties will maintain in confidence Confidential Information provided to each other in connection with this
Agreement and will use the Confidential Information solely for the purpose of carrying out Rs obligations
under this Agreement. The term Confidential Information means any oral or written information, (including
without limitation, computer programs, code, macros or instructions) which is made available to the Company I its
Page 6
Subsidiaries or one of its representatives, regardless of the rmnner in which such information is furnished.
Confidenfiallnformation also includes the following:
a. All Information regarding the Administrative Services, including, but not limited to, price, costs,
methods of operation and software, shall be maintained in confidence.
b. Systems used to perform the Administrative Services provided hereunder are confidential and
proprietary to the Company, Rs Subsidiaries or third parties. Both Parties shall treat these systems and all
related procedures and documentation as confidential and proprietary to the Company, its Subsidiaries or
its third party vendors.
c. All systems, procedures and related materials provided to either Party are for Rs internal use
only and only as related to the Administrative Services or any of the underlying systems used to provide
the Administrative Services.
Notwithstanding anything in this Article 15 to the contrary, the term "Confidentiallnformation" does not include
any information which (i) at the time of disclosure is generally available to and known by the public (other than as
a resun of an unpermitted disclosure made directly or indirectly by a Party), (i~ was available to a Party on a non-
confidential basis from another source (provided that such source is not or was not bound by a confidentiality
agreement with a Party or had any other duty of confidentiality to a Party), or (ii~ has been independently
acquired or developed without violating any of the obligations under this Agreement.
The Parties shall use good faith efforts at the termination or expiration of this Agreement to ensure that all user
access and passwords are cancelled.
All Confidential Information supplied or developed by a Party shall be and remain the sole and exclusive
property of the Party who supplied or developed it.
ARTICLE 16. PERMmED DISCLOSURE
NotwRhstanding provisions of this Agreement to the contrary, each Party may disclose Confidential
Information (i) to the extent required by a State Commission, a court of co!1l)etent jurisdiction or other
governmental authority or otherwise as required by law, including without limitation disclosure obligations
imposed under the federal securRies laws, provided that such Party has given the other Party prior notice
of such requirement when legally permissible to permit the other Party to take such legal action to prevent
the disclosure as it deems reasonable, appropriate or necessary, or (ii) on a "need-to-know" basis under
an obligation of confidentiality to its consultants, legal counsel, affiliates, accountants, banks and other
financing sources and their advisors.
ARTICLE 17. SUBCONTRACTORS
To the extent provided herein, the Parties shall be fully responsible for the acts or omissions of any
subcontractors of any tier and of all persons employed by such subcontractors and shall maintain complete
Page 7
control over all such subcontractors. It being understood and agreed that not anything contained herein
shall be deemed to create any contractual relation between the subcontractor of any tier and the Parties.
ARTICLE 18. NONWAIVER
The failure of a Party to insist upon or enforce strict performance of any of the terms of this Agreement or to
exercise any rights herein shall not be construed as a waiver or relinquishment to any extent of ITS right to
enforce such terms or rights on any future occasion.
ARTICLE 19. SEVERABILITY
Any provision of this Agreement prohibITed or rendered unenforceable by operation of law shall be
ineffective only to the extent of such prohibITion or unenforceability without invalidating the remaining
provisions of this Agreement.
ARTICLE 20. ENTIRE AGR~MENTS INCORPORATED BY REFERENCE
All understandings, representations, warranties, agreements and any referenced attachments, if any,
existing between the Parties regarding the subject matter hereof are merged into this Agreement, which
fully and completely express the agreement of the Parties WITh respect to the subject matter hereof.
ARTICLE 21. OTHER AGREEMENTS
This Agreement does not address or govern the Parties' relationship involving: (a) the tax allocation
agreement nor (b) any other relationships not specifically identified herein. All such relationships not
addressed or governed by this Agreement will be governed and controlled by a separate agreement or
tariff specifically addressing and governing those relationships or by applicable Laws or orders.
Page 8
This Agreement has been duly executed on behalf of the Parties as follows:
MlDAMERICAN ENERGY HOLDINGS COMPANY
By.
Patrick J. Goodman
T~e: Sr. Vice President &
Chief Financial Officer
----
PPW HOLDINGS
~ ~
By.
Brian K. Hankel
T~e: Vice President & Treasurer
CE ELECTRIC UK FUNDING COMPANY
By: p:J(~
Patrick J. Goodman
Tille: Director
HOME SERVICES OF AMERICA, INC.
By. /2!
()
Paul J. IGIi
T~e: 4ss-~N LlC
By:
Thomas B. pecketer
T~e: Vice President & Controll
Brian K. Hankel
T~: Vice President & Treasure
KR HOLDING, LLC
By.
Patrick J. Goodman
T~e: Vice President & Treasurer
INC.
Brian K. Hankel
Tille: Vice President & Treasurer
CE CASECNAN WATER AND ENERGY COMPANY,8/P---
Brian K. Hankel
Tde: Vice President & Treasurer
Page 9
CERTIFICATE OF SERVICE
I hereby certify that I served a copy of the foregoing document upon the parties of record
in this proceeding by first-class mail, addressed to said parties/attorneys ' addresses as shown
below:
Andrea L. Kelly
Managing Director, Strategy
PacifiCorp
825 NE Multnomah
Portland, OR 97232
James R. Smith
Monsanto Company
Highway 34 North
PO Box 816
Soda Springs, ill 83276
Douglas L. Anderson
Senior Vice President
and General Counsel
MidAmerican Energy
Holdings Company
302 S 36th Street, Suite 400
Omaha, NE 68131
Katie Iverson
Brubaker & Associates
17244 W Cordova Court
Surprise 85387
Mark C. Moench
Senior Vice President, Law
MidAmerican Energy
Holdings Company
201 S Main Street, Suite 2300
Salt Lake City, UT 84111
Eric L. Olsen
Racine, Olson, Nye, Budge & Bailey
201 E Center
Pocatello, ill 83204-1391
Anthony Yankel
29814 Lake Road
Bay Village, OH 44140
Donald L. Howell
Deputy Attorney General
Idaho Public Utilities Commission
472 West Washington
Boise, ill 83702
Barton Kline
Monica B. Moen
Idaho Power Company
PO Box 70
Boise, ill 83707
Terri Carlock
Accounting Supervisor
Idaho Public Utilities Commission
472 West Washington
Boise, ill 83702
John R. Gale
Vice President, Regulatory Affairs
Idaho Power Company
PO Box 70
Boise, ill 83707
Randall C. Budge
Racine, Olson, Nye, Budge & Bailey,
Chartered
201 E Center
Pocatello, ill 83204-1391
Brad M. Purdy
Attorney at Law
2019 N 1 ih Street
Boise, ill 83702
Page 1 - CERTIFICATE OF SERVICE (PAC-05-
Portlnd3-1527178.10051851-00005
Arthur F. Sandack
8 E Broadway, Suite 510
Salt Lake City, UT 84111
Alan Herzfeld
Herzfeld & Piotrowski LLP
713 W Franklin
Boise, ill 83701
DATED: March 31 , 2006.
Joint Counsel for MidAmerican Energy Holdings
Company and PacifiCorp dba Utah Power &
Light Company
Page 2 - CERTIFICATE OF SERVICE (pAC-05-
Portlnd3-1527178.10051851-00005