20080430Testimony Filed in Utah.pdf

~~~~;oo~OUNTAIN RECEIVED
30 Ali
201 South Main, Suite 2300
Salt Lake City. Utah 84111
April 29, 2001Oil(i~tËkëof'X SlON
VI U.S. MAIL AND ELECTRONIC MAIL
Idaho Public Service Commission
472 W. Washington Street
P.O. Box 83720
Boise, Idaho 83720-0074
Attention:Jean D. Jewell
Commission Secretary
CASE NO. PAC-E-08-02
Re: CONFIDENTIAL-SUBJECT TO PROTECTIVE ORDER
In the Matter of the Application of Rocky Mountain Power for an Accounting
Order to Establish a Regulatory Asset
Dear Ms. Jewell,
Attched please find nine (9) copies (in lieu of an original and eight copies) ofthe Application,
Testimony, and Workpapers filed by Rocky Mountain Power in Uta in support of its Verified
Request for Waiver of Solicitation Process and Approval of a Signficant Energy Resource.
Please treat the documents labeled Confdential and on yellow paper as Confidential according to
the terms of the Protective Order in this Docket. The provided documents include:
1) Rocky Mountain Power Application in Utah Docket No. 08-035-35 (non-confidential)
2) Testimony of Bruce N. Wiliams (non-confidential)
3) Confdential Testimony of Gregory N. Duvall
a. Gregory N. Duvall Testimony Confdential Exhibit RMP 2.1
b. Gregory N. Duvall Confidential Workpapers
4) Confidential Testimony of Stefan A. Bird
5) Confidential Purchase and Sale Agreement between Seller and PacifiCorp
Please let me know if you have any questions.
~Y~T~'n J.~ i
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Senior Counsel
Rocky Mountain Power
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Mark C. Moench (2284)
Daniel E. Solander (11467)
Rocky Mountain Power
201 South Main Street, Suite 2300
Salt Lake City, UT 841 1 1
[phone]
[phone] (Fax)
mark.moench(ßpacificoro.com
daniel.solander(ßpacificorp.com
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Gregory B. Monson (2294)
Stoel Rives LLP
201 South Main Street, Suite 1 100
Salt Lake City, UT 841 1 1
[phone]
[phone] (fax)
gbmonson(ßstoel.com
Attorneys for Rocky Mountain Power
BEFORE THE PUBLIC SERVICE COMMISSION OF UTAH
In the Matter of the Request of ROCKY
MOUNTAIN POWER for Waiver of
Solicitation Process and for Approval of
Significant Energy Resource Decision
Docket No. 08-035-35
VERIFIED REQUEST FOR WAIVER OF
SOLICITATION PROCESS AND FOR
APPROVAL OF SIGNIFICANT ENERGY
RESOURCE DECISION
Rocky Mountain Power, a division ofPacifiCorp ("Rocky Mountain Power" or
"Company"), pursuant to Utah Code An. §§ 54-17-201(3) and 54-17-501 and Utah Admin.
Code R746-430-4, hereby requests that the Commission grant it a waiver of
the solicitation
process required by Utah Code Ann. § 54-17-201, et seq., with respect to acquisition of the
generation plant ("Plant") identified in the Confidential Testimony of Stefan A. Bird fied with
this request. The basis for this requested waiver of the solicitation process is that acquisition of
the Plant is a time-limited commercial opportity that provides value to the customers of Rocky
SaltLake-37 1469.4 0085000-01002
;0mom~oimo
Mountain Power. Moreover, the Company is just completing the request for proposals ("RFP").for the 2012 - 2014 time period approved in Docket No. 05-035-47 ("2012 RFP") and has
commenced a newall-source solicitation for the 2012 - 2016 time period in Docket No. 07-035-
, ", '94 r~2n08 All-Source RFP"). Conducting an additional solicitation related to this Plant would
not materially contribute to the public interest.
Additionally, Rocky Mountain Power, pursuant to Utah Code An. § 54-17-302 and Uta
Admin. Code R746-430-2 and R746-440-1, requests that the Commission approve the signficant
energy resource decision to acquire the Plant. The basis for ths request for approval is that the
Company has the exclusive opportity for a limited time to acquire the Plant on terms and
conditions that, over the Plant's life, will maximize benefit to the Company and its customers in
the public interest as demonstrated in the Confidential Testimony of Stefan A. Bird, the
Confidential Testimony of Gregory N. Duvall and the Testimony of Bruce N. Wiliams .("Testimony") fied with ths Request. 1
Rocky Mountain Power does not request waiver of the requirement for approval of the
acquisition of the Plant at this time. Whle this time-limited commercial opportunity does not
allow sufficient time to conduct and complete an additional solicitation process, there is
sufficient time for the Commission to review and approve the transaction using ne.arly the full
statutory timeframe of 180 days permitted by Utah Code An. § 54-17-302(5).
To the extent possible, the Company respectfully requests that the Commission issue its
order on the request for approval of the transaction by September 14, 2008, which is two weeks
prior to the expiration of the 180-day statutory timeframe. Ths is the closing date negotiated
J The request for waiver and request for approval wil be referred to collectively as the "Request."
This Request wil also serve as the notice required under Utah Admin. Code R746-401-3, to the extent .
such notice is required.
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SaltLake-371469.l I 008500-10011
with the seller, and Commission approval represents the last expected regulatory action needed
. to complete the transaction. The Company wil promptly provide information requested by the
Commission or interested paries and wil further paricipate in technical conferences and
hearings as required by the Commission or requested by interested parties to faciltate issuance
of an order prior to September 14, 2008.
COMMUNICATIONS AND DISCOVERY
1. Communcations, including pleadings and other filings, regarding this Request
should be addressed to:
David L. Taylor
Uta Regulatory Affairs Manager
Rocky Mountain Power
201 South Main Street, Suite 2300
Salt Lake City, Utah 841 I 1
dave. taylor(ßpacificorp.com
Mark C. Moench
Daniel E. Solander
Rocky Mountain Power
201 South Main Street, Suite 2300
Salt Lake City, UT 84 i I i
mark.moench(ßpacificorp.com
daniel.solander($pacificorp.com.Gregory B. Monson
Stoel Rives LLP
201 South Main Street, Suite 1 100
Salt Lake City, UT 84111
gbmonson(ßstoel.com
2. Rocky Mountain Power requests that any data requests regarding this Request
be addressed to:
By email (preferred)datareguest(ßpacificorp.com
By regular mail Data Request Response Center
PacifiCorp
825 NE Multnomah, Suite 2000
Portland, OR 97232
By facsimile [phone]
.
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SaltLake-371469.1 J 0085000-10011
Informal inquires may be directed to Daniel E. Solander at [phone] or David L. Taylor at
[phone].
BACKGROUN
3. Rocky Mountain Power is a division of PacifiCorp, an Oregon corporation. The
Company is authorized to do business in the state of Utah and is an electncal corporation
holding a certificate of convenience and necessity issued by the Commission authonzing it to
provide electric service in many pars of the state of Uta. Rocky Mountain Power curently
provides electrc service to approximately 760,000 customers in the state of Utah and is an
affected electrical utilty as defined in the Energy Resource Procurement Act, codified as
Chapter 17 of Title 54 of the Uta Code ("Act"). Rocky Mountan Power also provides electrc
service to customers in Idaho and Wyoming. Pacific Power, another division ofPacifiCorp,
provides electric service to customers in California, Oregon and Washington. Rocky Mountain
Power and Pacific Power share generation and transmission resources for the Company's east
and west control areas ("System") under the PacifiCorp Inter-Jursdictional Cost Allocation
Protocol effective June 1, 2004 ("Revised Protocol").
4. The Company's need to acquire new System-wide resources to serve its growing
customer base and increasing demand for electricity has been well established in its integrated
resource plans ("IRP"), RFP approval applications and other proceedings before the
Commission. Customer growt and increasing loads, coupled with environmental requirements
and improved reliabilty expectations from customers, are drivers for new utilty plant
investments.
5. In 2005, the Utah Legislature enacted the Act. The Act was based on the
acknowledged need of the Company to acquire substantial new System energy resources. It
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Sale-371469.I i 008500-1001 i
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established standards and procedures for submission of action plans in conjunction with IRs,
. solicitations, including use of an independent evaluator, and approval of significant energy
resource decisions.
6. Pursuant to the Act, the Company submitted action plans and requested approval
of solicitation processes for new System resources as contemplated by its action plans.
a. The Company filed an application in June 2005 in Docket No. 05-035-
47, seeking approval of the action plan filed with its 2004 IR. Among other thngs, the
application sought approval of a 2009 RFP. In September 2005, the Company sought to
suspend the schedule based on the pendency of an IRP update fied in November 2005
in Docket No. 05-2035-0 I. Further suspension of the schedule was sought pending the
acquisition of the Company by MidAerican Energy Holdings Company.
b. In July 2006, the Company fied a modified proposal, seeking approval.of the proposed 2012 RFP. In April 2007, the Commission approved the 2012 RFP
with some modifications, including increasing the resource need from 840 megawatts
("MW") up to 1,700 MW of generation. However, as recently disclosed on a
confdential basis to the Commission and paries to Docket No. 05-035-47 entitled to
receive confidential information, the 2012 RFP will, at most, result in new System
resources with total capacity substantially less than the amount solicited.
c. In May 2007, the Company fied its 2007 IRP in Docket No. 07-2035-
OL. The Commission issued its Report and Order in the docket on Februar 6, 2008,
refusing to acknowledge the 2007 IRP. The System resource needs assessment
conducted for the 2007 IRP showed a PacifiCorp incremental peak capacity need of
over 21,400 MW by 2012.".
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SaltLake-37 1 469. 1 1 0085000-10011
d.In Februar 2008, the Company fied its 2008 All-Resource RFP in .Docket No. 07-035-94. The 2008 All-Resource RFP is currently pending before the
Commission.
7. In 2007, the Act was amended to allow a waiver of the solicitation process and
approval of the acquisition of a significant energy resource under certain circumstances.
8. The Commission has adopted rules pursuant to the Act providing, among other
things, standards and procedures for obtaining a waiver of the solicitation process and for
obtaining approval of a signficant energy resource acquisition.
9. The Testimony explains the process by which the Company became aware of the
Plant and its actions in response to that information. The paries have negotiated all of th
essential terms of a Purchase and Sale Agreement ("PSA") that gives PacifiCorp the exclusive
right to acquire the Plant while it seeks necessar state and federal regulatory approvals with a .time-limited period. The PSA is substantially final, awaiting completion of accompanying
disclosure schedules.
10. Given the commercially sensitive natue of the information regarding the
Company's opportity to acquire the Plant,i but cognzat of the Commission's desire for
public disclosure of non-confdential information, Rocky Mountan Power will provide general,
non-confidential information regarding the Plant and the proposed terms and conditions of the
agreement for acquisition of the Plant in this Request and the Testimony of Mr. Willams.
More detailed, confidential information will be provided in the Confidential Testimony of
2 PacifiCorp was required to enter into a Confidentiality Agreement with the owner of the Plant
under which it agreed not to disclose information regarding the Plant or terms and conditions for it
acquisition and related agreements. This agreement has now been incorporated into the PSA. The PSA
allows PacifiCorp to disclose information in connection with regulatory fiings and documents in .
suffcient detail to gain approval ofthe acquisition, but PacifiCorp must disclose the information under
terms and conditions that wiJ preserve its confidentiality to the greatest extent possible.
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SaltLake-37 J 469. II 00500-10011
.Messrs. Bird and Duvall fied with this Request. The confidential Testimony wil be made
available to interested parties under the terms of the Generic Protective Order issued by the
Commission in Docket No. 07-999-03 pursuant to the Act with respect to the request for waiver
of the solicitation process. With respect to the request for approval of the Company's
significant energy resource decision to acquire the Plant, the Company wil request issuance of
a protective order in this docket hereafter.
WAIVER OF SOLICITATION
1 1. Rocky Mountain Power requests that the Commission grant it a waiver of the
solicitation process contemplated by the Act and the Commission's rules based on the time-
limited commercial opportity to acquire the Plant.
12. Based on its experience since passage of the Act, Rocky Mountain Power
anticipates that conducting the solicitation process otherwse required by the Act in connection
. with acquisition of the Plant would take from ten to twelve months. If that period is added to
the approval process, which may take as much as 180 days or six months, Uta Code An.
§ 54-17-302(5), the Company canot complete the acquisition withn the time allowed by the
owner of the Plant and could lose the opportity to acquire the Plant on the terms and
conditions curently available under the PSA. In addition, Rocky Mountain Power. is just
completing the 2012 RFP and recently fied its 2008 All-Resource RFP for capacity and energy
resource needs for 2012 - 2016. Conducting yet another RFP for this transaction is not likely
to result in the identification of any added resources nor would it materially contribute to the
public interest.
.
13. As described below, the acquisition of the Plant is in the public interest and
provides a reasonably-priced resource that wil assist Rocky Mountain Power in meeting the
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SaltLake-37 1 469. 1 1 0085000-10011
needs of its customers. Therefore, granting a waiver of the solicitation process is in the public
interest..
APPROVAL OF ACQUISITION
14. Acquisition of the Plant is consistent with the 2012 RFP because the resources
that are available under the 2012 RFP will fall substantially short of the 1,700 MW
contemplated by the 2012 RFP. Furhermore, based on the resource needs assessment
conducted for the 2007 IRP, PacifiCorp's incremental peak capacity need is over 2,400 MW by
2012. Acquisition of the Plant will assist the Company in meeting ths need.
15. Acquisition of the Plant will add valuable incrementa generation to backstop
the intermittent profile of the Company's growing renewable wind portolio and offset the loss
of flexible System hydro legacy contracts that are due to expire between 2009 and 2012.
16. As explained in the confidential Testimony, the Plant is available to the
Company on reasonable terms and conditions. The Plant reduces risk because as an existing
resource, the Plant is not subject to permitting and constction cost, schedule and the
escalating cost of steel, materials and labor risks to which the Company would be exposed in a
new constrction resource alternative.
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17. The PSA is fair and reasonable. The substantially-final PSA is provided as an
exhbit to the confdential Testimony.
18. The information, data, models and analyses used by the Company to evaluate
the acquisition of the Plant demonstrate that acquisition of the Plant is in the public interest and
wil be beneficial to the Company's customers. This information is provided in the confidential
Testimony.
.
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19. An analysis of the estimated effect of the Plant on the Company's revenue
. requirement demonstrates that acquisition of the Plant is in the public interest and will be
beneficial to the Company's customers. The analysis is provided in the confdential
Testimony.
20. The Company has the ability to acquire the Plant without impairing its credit or
financial viabilty. Financial information demonstrating this is provided in the Testimony of
Mr. Wiliams.
21 . Rocky Mountain Power has complied with all requirements of the Act and the
Commission's rules issued under the Act in connection with this Request. Rocky Mountain
Power fied and served on the service list maintained by the Commission a prefiing notice and
public notice of ths Request in accordance with Utah Admin. Code R746-440-1(2)(a) and (b)
and paragraph 8 of the Generic Protective Order issued April i 7,2007 in Docket No. 07-999-
. 03 at least five calendar days and four business days prior to filing ths Request. In addition,
Rocky Mountain Power provided media notice of the pending filing.3
REQUEST FOR RELIEF
WHEREFORE, Rocky Mountai Power requests relief as follows:
1 . That the Commission, by the next business day following. the date ~s Request
is fied (April 2, 2008), notice a techncal conference on the request for waiver of the
solicitation process durng the period from three business days to seven calendar days
following the date of this Request in accordance with Uta Code An. § 54-17-501(4). Rocky
Mountain Power suggests that the technical conference be scheduled on April 8, 2008, the last
day permitted under the statute, if that day is available on the Commission's calendar.
3 See "Rocky Mountain seeking OK to buy a generating plant," Deseret Morning News (March
. 27,2008).
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SaltLake-371469.I 10085000.10011
2. That the Commission proceed to require the filing of comments on the waiver
request during the period from three business days to seven calendar days following the
technical conference held pursuant to the foregoing paragraph in accordance with Utah Code
Ann. § 54-17-501(6). If the techncal conference is held on April 8, 2008, the Commission
may require comments on any day from April 1 1-15, 2008. Rócky Mountain Power suggests
that comments be due on April 15, 2008.
3. That the Commission issue its wrtten decision on the waiver request within
seven calendar days following the date comments on the waiver request are due pursuant to the
foregoing paragraph in accordance with Utah Code An. § 54-17-501(7). If Rocky Mountain
Power's suggested dates are adopted for the techncal conference and filing comments, the
Commission's decision would be due on April 22, 2008.
4.That the Commssion grant the waiver of the solicitation process sought in this
Request.
5. That the Commission notice a scheduling conference to set a schedule for
interested persons to fie comments and reply comments on the request for approval of the
significant energy resource decision to acquire the Plant, for any techncal conferences deemed
useful to the Commission or interested paries, for a hearing on the approval Request and for
other processes and procedures deemed reasonable or necessar by the Commission in
determining to approve Rocky Mountain Power's acquisition of the Plant.
6. That the Commission approve Rocky Mountain Power's acquisition of the Plant,
to the extent possible, before the negotiated closing date of September 14,2008, which is only
two weeks short of the 1 80-day period permtted by Uta Code An. § 54-17-302(5).
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RESPECTFULL Y SUBMITTED:
SaltLake-371469.11 00850010011
April i, 2008.
~6.YY~~o~
Danel E. Solander
Rocky Mountain Power
Gregory B. Monson
Stoel Rives LLP
Attorneys for Rocky Mountain Power
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VERIFICATION .
STATE OF OREGON )
: ss.
COUNTY OF MDL TNOMAH )
Stefan A. Bird, being first duly sworn upon his oath, testifies that:
i. He is the Senior Vice President, Commercial and Trading, for PacifiCorp
Energy.
2. He has read the foregoing Verified Request for Waiver of Solicitation Process
and Approval of Significant Energy Resource Decision ("Request").
3. The statements in the Request aTe true and correct to the best of his knwledge,
information and belief.
c¡tStefan;".
Subscribed and sworn to before me on April i, 2008.
OFFICIAl SEA
TERICA M REYES
NOTARY PUBUC - OREGON
COMMISSION NO. 419127
MY COMMISSION EXPIRES AUGUST 26, 2011
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SallLakc-37 1469. 1 I 008500-10011
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CERTIFICATE OF SERVICE
I hereby certify that I caused a true and correct copy of the foregoing VERIFIED
REQUEST FOR WAIVER OF SOLICITATION PROCESS AND FOR APPROVAL OF
SIGNIFICANT ENERGY RESOURCE DECISION to be served upon the following by
electronic mail and hand delivery to the addresses shown below on April 1,2008:
Michael Ginsberg
Patricia E. Schmid
Assistant Attorney Generals
500 Heber M. Wells Building
160 East 300 South
Salt Lake City, UT 841 1 1
mginsberg(ßutah. gov
pschmidtêutah.gov
Wiliam A. Powell
Division of Public Utilties
400 Heber M. Wells Building
160 East 300 South
Salt Lake City, UT 8411 I
wpowell(ßutah.gov
Gar A. Dodge
Hatch, James & Dodge
lOWest Broadway, Suite 400
Salt Lake City, UT 84101
gdodge(ßhjdlaw.com
SaItLake-371469.11 008500-10011
Paul H. Proctor
Assistant Attorney General
500 Heber M. Wells Building
160 East 300 South
Salt Lake City, UT 841 I 1
pproctor(ßutah. gov
Michele Beck
Cheryl Muray
Committee of Consumer Services
200 Heber M. Wells Building
160 East 300 South
Salt Lake City, UT 84111
mbecktfutah.gov
cmurayrmutah.gov
F. Robert Reeder
Wiliam J. Evans
Michael J. Malmquist
Vicki M. Baldwin
Parsons Behle & Latimer
201 South Main Street, Suite 1800
Salt Lake City, UT 84145-0898
frreeder(ßparsonsbehle.com
bevans(ßparsonsbehle.com
mmalmguist(ßparsonsbehle.com
vbaldwinrmparsonsbehle.com
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RECEIVED
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BKFORE THE PUBLIC SERVICE COMMSSION OF UTAH
In the Matter of the Request of ROCKY
MOUNTAIN POWER for Waiver of
Solicitation Process and for Approval of
Significant Energy Resource Decision
Docket No. 08-035-_
TESTIMONY OF
BRUCE N. WILLIAM
FOR
ROCKY MOUNTAIN POWER
EXIDBITRMP3
APRIL 1, 2008
Jl
I Q.PJease state your name, business address and job tite..2 A.My name is Bruce N. Wiliams. My business address is 825 NE Multnomah,
3 Suite 1900, PonJand, Oregon 97232. I am Vice President and Treasurer of
4 PacifiCorp. Rocky Mountain Power is a division of PacifiCorp ("Company").
5 Q.What are your responsibilties in your current position?
6 A.I am responsible for the Company's treasury, credit risk management, pension
7 and other investment management activities.
8 Q.Please describe your business and educational background.
9 A.I have been employed by the Company for 22 years. My business experience has
10 included financing of the Company's electric operations and non-utility activities,
11 investment management, and investor relations. I received a Bachelor of Science .12 degree iIi Business Administration with a concentration in Finance from Oregon
13 State University in June 1980. i also received the Chartered Financial Analyst
14 designation upon passing the examination in September 1986.
15 Q.What is the purpose of your testimony?
16 A.My testimony supports Rocky Mountain Power's Verified Request for Waiver of
17 Solicitation Process and for Approval of Significant Energy Resource Decision
18 ("Request") with respect to the Company's proposal to acquire the generating
19 plant ("Plant") identified in the Confidential Testimony of Stefan A. Bird. The
20 Request is filed under the Utah Energy Resource Procurement Act ("Act"),
21 specifically Utah Code Ann. §§ 54-17-201(3),54-17-302 and 54-17-5ul. It is
22 also filed in accordance with Commission rules adopted under the Act, Utah .
Page 1 - Confidential Testimony of Bruce N. Willams
23.24
25 Q.
26 A.
27
28
29
30
31
32 Q.
33 A..34
35
36
37
38
39
40
41
42
43
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Admin. Code R746-430-2, R746-430-4 and R746-440-L. My testimony describes
generally how the Company wil finance the acquisition the Plant.
What do you expect the source of funds to be for the acquisition of the Plant?
The Company expects to use a reasonable mix of capital designed to provide a
competitive cost of capitaL. predictable capital market access and to allow the
Company to remain financially stable. The Company anticipates utilizing funds
from sources similar to those used in the past, including operating cash flows and
the issuance of new long-term and short debt and, if necessary, new equity capital
to fund the acquisition of the Plant.
Is the Company capable of financing the acquisition of the Plant?
Yes. In addition to the internally generated funds. the Company currently has
access to the capital markets and expects to be able to borrow funds necessary to
help finance the acquisition of the Plant. This access was evidenced most recently
by the Company's October 2007 issuance of $600 milion of first mortgage
bonds. PacifiCorp senior secured debt is currently rated "A3" and "A-" by
Moody's Investors Service and Standard and Poor's, respectively, both of which
are investment grade ratings. In addition, the Company has received cash equity
contributions from its parent company in the past and, if necessary, may again in
the future. The Company's access to the capital markets in the future wil be
influenced by outcomes of regulatory matters, industry developments and
regulatory authority to issue securities.
Page 2 - Confidential Testimony of Bruce N. Wiliams
J:
44 Q.Does the Company have regulatoi'y authority suffcient to aHow it to .45 finance the acquisition of the Plant?
46 A.Yes. The Company has authority to issue sufficient amounts of short-term and
47 long-term debt and common equity for acquisilion of the Plant. Our regulatory
48 authority allows securities to be issued for ceitain purposes including (1) the
49 acquisition of property, (2) the construction. completion. extension or
50 improvement of utility facilities, (3) the improvement of service, (4) the discharge
51 or lawful refunding of obligations which were incurred for utility purposes or
52 (5) the reimbursement of the Company's treasury for funds used for the foregoing
53 purposes.
54 Q.Does the Company have a debt~to-equity ratio which provides the
55 Company with financial stabilty?.
56 A.Yes, the Company's capital structure is appropriate for providing financial
57 stability in this matter. The Company expects its capital strcture may change
58 over time, due in part to capital spending, nonetheless it expects to remain
59 financially stable.
60 Q.What is your conclusion?
61 A.The Company has the financial capability to acquire the Plant.
62 Q.Does this conclude your testimony?
63 A.Yes.
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Page 3 - Confidential Testimony of Brue N. Wiliams
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CERTIFICATE OF SERVICE
I hereby certify that I caused a true and correct copy of the foregoing TESTIMONY OF
BRUCE N. WILLIAMS FOR ROCKY MOUNTAIN POWER to be sered upon the
following by electronic mail and hand deliver to the addresses shown below on April 1,2008:
Michael Ginsberg
Patricia E. Schmid
Assistant Attorney Generals
500 Heber M. Wells Building
160 East 300 South
Salt Lake City, UT 841 1 1
mginsbergØ2utah.gov
pschmidCiutah.gov
Wiliam A. Powell
Division of Public Utilties
400 Heber M. Wells Building
i 60 East 300 South
Salt Lake City, UT 84 i I 1
wpowellCiutah.gov
Gar A. Dodge
Hatch, James & Dodge
i 0 West Broadway, Suite 400
Salt Lake City, UT 84101
gdodgeCihjdlaw.com
SaltLake-371469.4 008500-01002
Paul H. Proctor
Assistant Attorney General
500 Heber M. Wells Building
160 East 300 South
Salt Lake City, UT 841 1 1
pproctorcautah.gov
Michele Beck
Cheryl Muray
Committee of Consumer Services
200 Heber M. Wells Building
160 East 300 South
Salt Lake City, UT 841 1 1
mbeckCiutah.gov
cmurrayCiutah.gov
F. Robert Reeder
Wiliam J. Evans
Michael J. Malmquist
Vicki M. Baldwin
Parsons Behle & Latimer
201 South Main Street, Suite 1800
Salt Lake City, UT 84 1 45-08~8
freedercaparsonsbehle.com
bevansCiparsonsbehle.com
mmalmquistcaparsonsbehle.com
vbaldwincaparsonsbehle.com