20101014Parker Di.pdf

(t.C l. r: r~i
IN THE MATTER OF THE APPLICATION OF )
PACIFICORP DBA ROCKY MOUNTAIN ) CASE NO. PAC-E-10-07
POWER FOR APPROVAL OF CHANGES )
TO ITS ELECTRIC SERVICE SCHEDULES )
)
)
)
)
)
DIRECT TESTIMONY OF MARILYN PARKER
IDAHO PUBLIC UTILITIES COMMISSION
OCTOBER 14, 2010
1 Q.Please state your name and address for the
2 record.
3 A.My name is Marilyn Parker. My business address
4 is 472 West Washington Street, Boise, Idaho.
5 Q.By whom are you employed and in what capacity?
6 A.I am employed by the Idaho Public Utilities
7 Commission as a Utili ties Compliance Investigator. I
8 accepted that position with the Consumer Assistance Staff
9 in November 2002.
10 Q.What is your educational and professional
11 background?
12 A.Prior to my employment with the Idaho Public
13 Utilities Commission, I had twenty years experience
14 working in private industry for three different utility
15 companies. In 1973 and 1974, I was employed by Central
16 Alaska Utilities, a water company in Anchorage, Alaska, as
17 the Executive Secretary to the President of the company.
18 From 1982 until 1987, I was employed as a Customer Service
19 Representative for Idaho Power Company in Salmon, Idaho.
20 From February 1989 until November 2002, I was employed by
21 Intermountain Gas Company in Customer Services. During my
22 last six years at Intermountain Gas, I supervised
23 representatives at the Customer Service Center's Emergency
24 Answering Service.
25 I received a Bachelor of Arts Degree in
CASE NO. PAC-E-10-0710/14/10 PARKER, M. (Di) 1
STAFF
1 Management and Organizational Leadership from George Fox
2 University in Boise, Idaho in June of 2002.
3 In June 2003 and June 2006, I attended the
4 National Low Income Energy Consortium Annual Conference in
5 Sacramento, California and Washington, D.C., respectively.
6
8
7 Commission?
Q.Have you previously testified before the
9
A.Yes, I have.
Q.What is the purpose of your testimony in this
11
10 proceeding?
A.I will address the following topics:(1 )
12 customer comments received by the Idaho Public Utili ties
13 Commission regarding this case; (2) Rocky Mountain Power's
14 (RMP) customer relations; (3) RMP's Landlord Program; (4)
15 RMP's rebilling policy; and (5) RMP's policy of leaving
16 meters on between customers and the resulting unbilled
18
17 usage.
20
19 recommendations to the Commission.
Q.Please summarize your testimony and
A.I reviewed customers' comments regarding the
21 proposed rate increase. Customers are unhappy with the
22 prospect of another rate hike, especially in light of the
23 current economic conditions in eastern Idaho. I reviewed
24 the Company's call center telephone answering statistics
25 and found them to be commendable. Also notable is RMP's
CASE NO. PAC-E-10-0710/14/10 PARKER, M . (D i) 2
STAFF
1 relatively low number of customer complaints filed with
2 the IPUC in 2009.
3 With respect to the Company's Landlord Program,
4 I recommend that RMP review its policy of allowing
5 landlords to submit applications for service to the
6 Company on behalf of their tenants and report its findings
7 to the Commission Staff no later than 60 days following
8 issuance of the Commission's final order in this case.
9 Staff also recommends that RMP retain the Application for
10 Service form for a minimum of four years so that it will
11 be available for review in the event there is a dispute
12 later regarding responsibility for bill payment.
13 I discuss my concerns regarding RMP's procedures
14 for rebilling customers whose meters failed or whose bills
15 were prepared inaccurately. I make several
16 recommendations to improve communication with customers
17 and improve the accuracy of billing estimates. I also
18 recommend that within 60 days of the final date of the
19 Commission's order in this case, the Company meet with
20 Staff to discuss how its rebilling policy can be revised.
21 I recommend that RMP discontinue its practice of
22 routinely allowing service to remain connected between
23 customers. I recommend that the Commission direct RMP to
24 develop a policy that discourages energy waste, reduces
25 unbilled revenue, improves billing accuracy by reducing
CASE NO. PAC-E-10-0710/14/10 PARKER, M . (D i) 3
STAFF
1 the number of estimated bills, and manages the Company's
2 resources in a cost-effective manner.
3 Customer Comments Regarding the Proposed Rate Increase
4 Q.Have you reviewed the written customer comments
5 that have been received by the Commission regarding this
6 case?
7 A.Yes, as of September 29, 2010, 56 customers had
8 commented on the case. More than one-half of those
9 commenting were on the Time-of-Use (TOU) Schedule 36,
10 which is a residential rate that allows customers to
11 receive a lower rate when electric consumption is moved to
12 "off peak" time periods. These TOU customers were upset
13 because RMP is proposing to raise their rate by 15.6%,
14 almost double the percentage increase proposed for
15 residential rate Schedule 1. The perception by many of
16 the TOU customers is that RMP was, for some reason,
17 punishing them. One-half of those commenting also
18 mentioned the bad timing of the requested rate increase
19 and cited poor economic conditions as a reason that the
20 increase in rates should be denied.
21 Many customers suggested that the utility needs
22 to tighten its own belt first before asking its customers
23 to pick up the extra money it needs. Other comments were
24 from low and fixed income customers worried about another
25 increase in rates and how they would be able to pay any
CASE NO. PAC-E-10-07
10/14/10 PARKER, M. (Di) 4
STAFF
1 more money for electricity than they are already paying.
2 Q.Has the Staff considered the concerns expressed
3 by customers?
4 A.Yes, the Staff shares the concerns expressed by
5 customers regarding energy affordabili ty, rate design, and
6 the Company's efforts to control costs. Staff witnesses
7 discuss reduction of Company expenses and investments to
S control cost and make energy more affordable. Staff also
9 proposes modifications to revenue spread and rate design
10 to better assure equity among customers.
11 Cus tomer Relations
12 Q.
\What is RMP's current telephone Customer Service
13 Level?
14 A.Customer Service Level is the percent of calls a
15 utility answers within a specified length of time. RMP's
16 service level goal is to answer SO% of its calls within 30
17 seconds. This service level is one of the Customer
1S Service Performance Standards established in PAC-E- 04 - 07.
19 RMP consistently has met or exceeded its performance
20 targets over time. Since 2007, RMP has reached S5% or
21 better in one-third of the months. It has averaged more
22 than SO% in each year. In only one month in the past
23 three years did RMP drop below SO%, and in that month
24 (January 2007) RMP had a service level of 79%. Overall,
25 in the past three years, RMP has maintained commendable
CASE NO. PAC-E-10-0710/14/10 PARKER, M. (Di) 5
STAFF
2
1 service levels.
Q.What were the total number of complaints and
3 inquiries filed with the IPUC's Consumer Assistance Staff
5
4 in 2009?
A.The Consumer Assistance Staff received 43
6 complaints and S inquiries for a combined total of 51
7 contacts with RMP's customers in 2009. Of the 43
S complaints received, two-thirds involved either credit and
9 collection issues (e. g., deposits, disconnections, payment
10 arrangements) or billing issues (e. g., high bills,
11 rebilling, billing at the wrong rate, line item charges) .
12
13
Q.How does this compare to prior years?
A.The number of complaints and inquiries decreased
14 from 72 in 200S to 51 in 2009. In 2007, there were 62
15 complaints and inquiries and in 2006 there were 34. See
17
16 Staff Exhibit No. 112.
Q.In 2009, how does RMP's total number of
1S complaints and inquiries filed with the IPUC's Consumer
19 Assistance Staff compare with other major regulated energy
21
20 companies in Idaho?
A.On a per one-thousand customer basis, Rocky
22 Mountain Power had the lowest number of complaints and
23 inquiries. In three of the last four years, Rocky
24 Mountain has had fewer complaints and inquiries than the
25 other three companies. See Staff Exhibit No. 113.
CASE NO. PAC-E-10-07
10/14/10 PARKER, M. (Di) 6
STAFF
1
2 Landlord Program
3 Q.Please briefly describe RMP's Landlord Program.
4 A.RMP calls its program the "Landlord Interim
5 Billing Agreement". When a landlord signs up for this
6 program, the landlord can choose to have electric service
7 at his or her rental properties transfer automatically
8 into the landlord's name when a tenant discontinues
9 service. In those situations, if the landlord has the
10 Landlord Interim Billing Agreement in place, the
11 electrici ty is not physically disconnected when the tenant
12 moves out. At that point, the tenant's account is closed
13 and a final bill is prepared for the tenant. The
14 financial responsibility then transfers to the landlord on
15 the date the tenant requested to be disconnected. From
16 that point forward, the landlord is the responsible party
17 for service until a new tenant moves in and assumes
18 financial responsibility. There is no charge to the
19 landlord for transferring service into or out of the
20 landlord's name.
21 Q.What are the benefits of a Landlord Program?
22 A.For the landlord, the major benefit is that it
23 protects the landlord's property from freezing if a tenant
24 moves out and requests disconnection of service during the
25 winter. Another benefit is that it allows electricity to
CASE NO. PAC-E-10-0710/14/10 PARKER, M. (Di) 7
STAFF
1 stay on between tenants, allowing landlords to clean and
2 perform maintenance on the premises after a tenant has
3 moved out and show the property to prospective tenants.
4 Q.Does Staff have any concerns regarding RMP's
5 Landlord Program?
6 A.Yes. RMP allows landlords to obtain a tenant' s
7 Application for Service from the tenant and submit it by
S fax to RMP. Staff is concerned that RMP may not have
9 proof in some situations that the tenant has granted
10 permission to the landlord to submit billing and signup
11 information on the tenant's behalf or that the information
12 provided is accurate. Staff believes the best practice is
13 one where the utility communicates directly with the
14 person who will be financially responsible for the
15 billing. Accepting Applications for Service from third
16 parties is a questionable business practice. Staff is
17 also concerned that RMP may not have adequate checks and
1S balances in place to meet the requirements of the Federal
19 Trade Commission's (FTC) "Red Flag Rule".
20 Q.What is the FTC's Red Flag Rule?
21 A.The FTC issued regulations (the Red Flag Rule)
22 requiring financial institutions and creditors to develop
23 and implement written identity theft prevention programs
24 as part of the Fair and Accurate Credit Transactions Act
25 of 2003. A program must provide for the identification,
CASE NO. PAC-E-10-0710/14/10 PARKER, M . (D i) S
STAFF
1 detection, and response to patterns, practices or specific
2 activities known as "red flags" that could indicate
3 identity theft. The Red Flag Rule applies to creditors
4 that defer payments for goods or services. Because
5 utilities bill customers after services are provided, they
6 are cons idered credi tors.
7 Q.Does Staff have any recommendations regarding
8 the Company's policy of accepting Applications for Service
9 from landlords on behalf of tenants?
10 A.Yes. Staff recommends that the Company review
11 its policy to make sure that the information it obtains
12 from landlords is accurate and is provided with the full
13 knowledge and permission of tenants as well as to insure
14 compliance with the Red Flag Rule. The Company's findings
15 should be reported to the Commission Staff no later than
16 60 days following issuance of the Commission's final order
17 in this case. Staff also recommends that RMP retain the
18 Application for Service form for a minimum of four years
19 so that it will be available for review in the event there
20 is a dispute later regarding responsibility for bill
21 payment.
22 Rebilling in Accordance with the Idaho Pulic utili ties
23 Commission's Utility Customer Relations Rule 204 (UCRR)
24 Q.What concerns did Staff identify in its
25 investigation of RMP's procedure to rebill its customers
CASE NO. PAC-E-10-0710/14/10 PARKER, M. (Di) 9
STAFF
1 when a customer's bill is prepared inaccurately due to
2 reasons such as a meter malfunction or metering equipment
3 that was incorrectly installed or programmed?
4 A.RMP does not follow an obj ecti ve or
5 independently verifiable methodology when preparing
6 estimated bills. Its process entails using electric
7 consumption at the premises from prior years to establish
8 electric usage trends in its rebilling calculation. RMP
9 does not apply a weather normalization factor based on
10 Heating or Cooling Degree Days obtained from the National
11 Weather Service. To come up with its estimate of the
12 amount of electricity the customer used, RMP compares
13 electric usage trends of other residents in the
14 neighborhood during the same time period.
15 Q.Why does Staff believe the current method of
16 rebilling employed by RMP is problematic?
17 A.Staff believes there are more accurate ways to
18 prepare corrected billings. Both Avista Utilities and
19 Intermountain Gas Company have implemented rebilling
20 mechanisms that have been accepted by Commission Staff.
21 Both Avista Utilities and Intermountain Gas employ in
22 their methodologies, among other factors, the National
23 Weather Service's Heating and Cooling Degree Days tailored
24 to specific regions of their service territories. Unlike
25 usage data gathered from a customer's neighbors, this
CASE NO. PAC-E-10-0710/14/10 PARKER, M. (Di) 10
STAFF
1 weather data is both objective and verifiable.
2 Q.Does RMP adequately communicate with customers
3 whose meters malfunctioned and who will be rebilled?
4 A.No. RMP told Staff it informs those customers
5 who will be rebilled by means of the customers' billing
6 statements. However, it is Staff's opinion that the
7 brief, non-descript message on the statement is not an
8 acceptable explanation. The billing statement is usually
9 the first notification the customer receives indicating
10 that some of the previous months' bills have been wrong.
11 RMP' s current procedure is to print a brief message on the
12 customer's bill stating that the customer should call RMP
13 for an explanation of the added charges if the customer
14 desires additional information. Staff Exhibit No. 114 is a
15 redacted copy of a customer's bill.
16 Q.What suggestions does Staff have for improving
17 RMP's rebilling policy?
18 A.At a minimum, Staff recommends that each
19 affected customer be sent a letter of explanation along
20 with a spreadsheet comparing usage and dollars previously
21 billed with the estimated usage and rebilled dollar
22 amount. This information should be mailed out prior to
23 the actual rebilling by the Company. This provides the
24 customer an opportunity to contact the Company if there
25 are any questions or disagreement with the usage estimate.
CASE NO. PAC-E-10-0710/14/10 PARKER, M. (Di) 11
STAFF
1 It also allows the Company to revise its estimate if
2 necessary before the customer is actually billed, thereby
3 avoiding the additional step of having to prepare a
4 revised rebilling statement. Staff also recommends that
5 the Company attempt to contact the customer by phone if
6 the rebilling covers more than a three-month period or is
7 for a significant dollar amount. This would allow the
8 customer to discuss with the Company any unusual
9 circumstances that might affect the rebilling. Currently,
10 RMP calls the customer if the rebilled amount is more than
11 $10,000; Staff believes the threshold should be much
12 lower.
13 Staff recommends that the letter of explanation
14 make it clear to the customer that in accordance with UCRR
15 204, payment arrangements are available for a period of
16 time that may extend to the length of time that the
17 underbilled amount accrued or the customer was not billed.
18 Staff recommends RMP meet with Staff within 60
19 days from the date of the final order in this case to
20 discuss development of acceptable policies with respect to
21 estimating usage and rebilling.
22 Unbilled Usage Due to Leaving Service Connected
23 Q.What is RMP' s policy regarding allowing service
24 to remain connected between customers?
25 A.RMP does not routinely physically disconnect
CASE NO. PAC-E-10-0710/14/10 PARKER, M. (Di) 12
STAFF
1 service when a customer closes an account. As a result,
2 energy continues to be used even though there is no
3 customer to bill for that usage.
4 Q.What is RMP's justification for this policy?
5 A.RMP maintains that most premises are only vacant
6 for a few days between customers. According to the
7 Company, by not disconnecting service after a customer
8 discontinues service, RMP saves the time of service
9 technicians and vehicle mileage associated with having to
10 disconnect and subsequently reconnect service within a
11 relatively short period of time. From the Company's point
12 of view, the dollar savings in employee time and vehicle
13 mileage outweigh the lost revenue associated with the
14 unbilled energy.
15 Q.What did Staff find in its investigation of this
16 policy?
17 A.The presumed net benefit of RMP's policy of not
18 disconnecting service may be more myth than fact. Staff
19 found that in many instances, not much time and mileage,
20 if any, was saved. The Company continues to send a
21 technician to the premises monthly to read the meter.
22 When unbilled usage at a premise exceeds 1,000 kWh, a
23 technician is dispatched to disconnect the meter. In
24 those instances where the threshold is reached, the
25 Company does not save any time and mileage costs because a
CASE NO. PAC-E-10-0710/14/10 PARKER, M . (D i) 13
STAFF
1 technician eventually had to be dispatched to turn off the
2 meter anyway, and a technician eventually would have been
3 required to turn the meter back on when a new customer
4 established service. Not only does RMP not save the time
5 and mileage costs in those instances, it loses a
6 considerable amount of revenue for electricity that went
7 unbilled.
8 Q.Has RMP's threshold always been 1,000 kilowatt
9 hours?
10 A.No. Until a few years ago, the threshold was
11 400 kWh. This means that during a time period of
12 increasing upward pressure on rates, the Company more than
13 doubled the amount of energy and associated revenue it was
14 willing to lose before taking action.
15 Q.How much energy goes unbilled due to RMP's
16 policy?
17 A.In 2009, there were 835 instances where usage
18 exceeded 1,000 kWh, meaning at least 835,000 kWh was
19 unbilled. The majority of affected accounts were
20 residential. At RMP's current average residential rate,
21 that is a minimum retail loss in revenue of $75,818. The
22 Company did not identify how much additional energy was
23 used in excess of the 1, 000 kWh threshold before it
24 actually disconnected service, nor did it provide the
25 total amount of unbilled usage attributable to situations
CASE NO. PAC-E- 10 - 0710/14/10 PARKER, M. (Di) 14
STAFF
1 where the 1, 000 kWh threshold was not exceeded before a
2 new customer signed up for service. Staff estimates that
3 in excess of 1,000,000 kWh goes unbilled annually due to
4 this policy. Based on the current average residential
5 rate, more than $90,000 in revenue was foregone by the
6 Company in 2009.
7 Q.What other concerns were found regarding RMP's
8 meter reading and billing policies as they pertain to
9 leaving meters connected between customers?
10 A.Staff questioned RMP regarding the meter reading
11 it uses for billing purposes when an account is opened and
12 closed if a technician is not sent to the premises to
13 obtain a meter reading. RMP stated that it uses the
14 actual monthly cyclical meter reading obtained on the
15 regular meter reading day to estimate a beginning or
16 ending read when a customer requests connection or
17 disconnection wi thin five days of the regular monthly
18 meter reading date. Affected customers are billed based
19 on estimated rather than actual usage.
20 If a customer requests connection or
21 disconnection outside of this ten day window (five days
22 before or after a regular meter reading), RMP sends a
23 technician out to obtain a reading. In other words, in 20
24 out of 30 days in a billing cycle, there are no savings in
25 employee time and vehicle mileage because an out-of-cycle
CASE NO. PAC-E- 10 - 0710/14/10 PARKER, M. (Di) 15
STAFF
1 meter reading had to be obtained.
2 Q.Why is Staff concerned about this policy at this
3 time?
4 A.When this policy was implemented, energy rates
5 were lower than they are today and RMP was not capaci ty-
6 constrained. Now, customers are constantly reminded about
7 the importance of using energy wisely. RMP has a number
S of programs in place to encourage energy efficiency and
9 conservation. RMP sends mixed messages to customers when
10 it encourages conservation on one hand and on the other
11 hand, leaves service connected when there is no customer
12 paying for or beneficially using the energy being
13 delivered to the premises. Staff recommends that the
14 Commission direct RMP to develop a policy that discourages
15 energy waste, reduces unbilled usage, improves billing
16 accuracy by reducing the number of estimated bills, and
17 manages the Company's workforce and equipment in a cost-
1S effective manner. Staff is willing to work with the
19 Company to devise an acceptable policy.
20 Q.Is Staff recommending that the Company
21 immediately dispatch an employee to read a meter or
22 disconnect service when a customer establishes or
23 discontinues service?
24 A.No. The Company needs a reasonable length of
25 time to respond to a customer's request. For residential
CASE NO. PAC-E-10-07
10/14/10 PARKER, M. (Di) 16
STAFF
1 and small commercial customers, a work completion interval
2 of up to three calendar days is reasonable in the maj ori ty
3 of circumstances. An interval of up to five calendar days
4 is reasonable for those situations where weather, the
5 customer's remote location, or some other out-of-the-
6 ordinary issue may delay work. For other types of
7 customers, e. g., irrigation customers, a work completion
8 interval of up to ten calendar days would be reasonable.
9 Staff believes these intervals are realistic based on
10 Idaho Power's reported success in using these same
11 intervals to manage its performance.
12 Q.Does RMP employ any of the newer advanced meter
13 reading technologies?
14 A.No. RMP has limited technical capability at
15 this time. Currently, RMP has approximately 16,000
16 residential and commercial meters that can be read by its
17 meter readers wi th handheld devices. However, obtaining
18 those meter readings still requires a meter reader to be
19 near the meter to operate the electronic device.
20 Approximately 57,000 meters in Idaho are still read by a
21 meter reader standing in front of the meter.
22 Q.Would newer metering technologies solve some of
23 the metering and billing issues raised by Staff?
24 A.Yes, many of the issues mentioned would be less
25 problematic and in some cases eliminated with advanced
CASE NO. PAC-E-10-0710/14/10 PARKER, M. (Di) 17
STAFF
1 meter reading technologies. To Staff's knowledge,
2 however, RMP has no immediate plans to upgrade its meters
3 to allow for remote meter reading or remote disconnection
4 and reconnection of service.
5 Q.If RMP is required to disconnect service within
6 a reasonable interval after a customer discontinues
7 service, won' t this increase workload and expense to the
8 Company?
9 A.As Staff pointed out earlier, the Company may
10 not be saving as much time and money as it believes bý
11 leaving meters on between customers. To the extent that
12 RMP' s costs do increase, there are ways in which the
13 Company can recover at least a portion of its costs
14 directly from customers who are causing those costs.
15 Both Idaho Power and Intermountain Gas assess an
16 account initiation fee when a new account is opened to
17 help cover the costs associated with connecting and
18 disconnecting meters. Currently, RMP customers are not
19 charged an account initiation fee if an account is opened
20 during regular working hours. Based on the total number
21 of RMP accounts opened in 2009, which includes accounts
22 that required an actual connection of the meter as well as
23 those accounts that did not require an actual meter
24 connection but required a reading or estimated reading to
25 complete the transfer of service, the Company would have
CASE NO. PAC-E-10-0710/14/10 PARKER, M. (D i) 18
STAFF
1 received approximately $288,000 in additional revenue if
2 it had in place a $20 account initiation fee.
3 Q.What do the other regulated gas and electric
4 companies in Idaho charge residential customers to open an
6
5 account?
A.Idaho Power's fee is $20 for accounts initiated
7 during working hours and Intermountain's fee is $14 for
8 accounts opened during regular office hours. Avista
9 Utilities is currently considering implementation of such
11
10 a charge.
Q.Does this conclude your direct testimony in this
13
12 proceeding?
14
15
16
17
18
19
20
21
22
23
24
25
A.Yes, it does.
CASE NO. PAC-E-10-0710/14/10 PARKER, M. (Di) 19
STAFF
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Case No. PAC-E-IO-07
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Case No. PAC-E-IO-07
M. Parker, Staff
10/14/10
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Preious Account Balance 40.81 0An:DESCRIPTION AAOUIl
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Date OUl:Die 15,200
AMOUNT DUE $199.02
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cali I.Hlre 1.88Z21.7UfJ
~~~MOUAIN PA6E20F2
BIllNG DATE: Nov 30, 2009 ACCONtNUM8ER'
Questions aboui your bin: Gall toll tr1.888-221-7070 ww-rocmtnpwer.net
OA ri DUE: Dec 15, 2009 AMOUNT DUE: $199. D2
AlEJ. ¡. COINUED UNITS COST PER UNITS ClGë
0219 Meter Information Corrected 011281. 026/9
03109 Meter Information Corred 0216109 - 037109
049 Me1er Information Corrd 03f710 - 041210
05 Meter Inormatin Corrected 04710. 057109
06 Meter Information Correct 051710 - 065109
07109 Meter Informati on Corrcted 0615109 . 0712819
089 Meter Information Corrcted 071281 - 086/9
099 Meter Information Corrected 0616109 - 095J9
101 Meter Information Corr 09109 - 1016/9
121 Meter Informtion Corrctd 12~ . 01~09
Total Adjustments
-12.91
.5.93
6.57
27.77
35.39
61.95
40.27
23.10
22.78
2.09
175.55
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Pleas print your new infonnation below and check the box on
1le re-r/S side Of ths PaymentStib. Thnk you.
ACCOUNT NUMBER: 60913700.0012
LA FIRST M.J.
NEW STEE ADDRE
ST zip
EXhibliNo.lî4
Case No, PAC-E-IO-07
M. Parker, Staff
10/14/1 0 Page 2 of 2
CI1'
TEPHONE NUMBER
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 14TH DAY OF OCTOBER 2010,
SERVED THE FOREGOING DIRECT TESTIMONY OF MARILYN PARKER, IN
CASE NO. PAC-E-IO-07, BY MAILING A COpy THEREOF, POSTAGE PREPAID, TO
THE FOLLOWING:
TED WESTON
ID REGULATORY AFFAIRS MANAGER
ROCKY MOUNTAIN POWER
201 S MAIN ST STE 2300
SALT LAKE CITY UT 84111
(FED EX)
E-MAIL: ted.weston(ipacificorp.com
E-MAIL: ONLY
MARK C MOENCH
DANIEL E SOLANDER
ROCKY MOUNTAIN POWER
E-MAIL: markmoench(ipacificorp.com
daniel.solander(ipacificorp.com
RANDALL C BUDGE
RACINE OLSON NYE ET AL
PO BOX 1391
POCATELLO ID 83204-1391
(FED EX)
E-MAIL: rcb(iracinelaw.net
E-MAIL: ONLY
JAMES R SMITH
MONSANTO COMPANY
E-MAIL: jim.r.smith(fmonsanto.com
ANTHONY Y ANKEL
29814 LAKE ROAD
BAY VILLAGE OH 44140
(FED EX)
E-MAIL: tony(iyankel.net
PAUL J HICKEY
HICKEY & EV ANS LLP
1800 CAREY AVE., SUITE 700
PO BOX 467
CHEYENNE WY 82003
(FED EX)
E-MAIL: phickey(ihickeyevans.com
E-MAIL: ONLY
KATIE IVERSON
BRUBAKER & ASSOCIATES
E-MAIL: kiverson(iconsultbai.com
ERICLOLSEN
RACINE OLSON NYE ET AL
PO BOX 1391
POCATELLO ID 83204-1391
(FED EX)
E-MAIL: elo(fracinelaw.net
CERTIFICATE OF SERVICE
TIM BULLER
JASON HARRS
AGRIUMINC
3010 CONDA RD
SODA SPRINGS ID 83276
(FED EX)
E-MAIL: tbullerliagrium.com
j aharisliagri ur.com
BENJAMIN J OTTO
IDAHO CONSERVATION LEAGUE
710 N 6TH STREET
POBOX 844
BOISE ID 83702
(HAND CARRIED)
E-MAIL: bottoliidahoconservation.org
E-MAIL: ONLY
DR. DON READING
E-MAIL: dreadinglimindspring.com
MELINDA J DAVISON
DAVISON VAN CLEVE, P.C.
333 SW TAYLOR, SUITE 400
PORTLAND, OR 97204
(FED EX)
E-MAIL: mjdlidvclaw.com
RONALD L WILLIAMS
WILLIAMS BRADBURY, P.C.
1015 W HAYS STREET
BOISE ID 83702
(HAND CARRIED)
E-MAIL: ronliwiliamsbradbury.com
BRAD M PURDY
ATTORNEY AT LAW
2019 N 17TH STREET
BOISE ID 83702
(HAND CARRIED)
E-MAIL: bmpurdylihotmail.com
l~'-bl¡-
SECRETARY
CERTIFICATE OF SERVICE