HomeMy WebLinkAbout20101014Vaughn Di.pdfBEFORE THE C '/!::J
2nHì nCT 14 PH l :41
IDAHO PUBLIC UTILITIES COMMISal9t¡
tJTlLITjE:S
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 CECILY VAUGHN
IDAHO PUBLIC UTILITIES COMMISSION
OCTOBER 14,2010
1 Q.Please state your name and business address for
2 the record.
3 A.My name is Cecily Vaughn. My business address is
4 472 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 Utili ties
7 Commission (Commission) as a senior auditor in the Utilities
8 Division.
9 Q.What is your educational and experience
10 background?
11 A.I graduated from Washington State University in
12 1974 with a Bachelors of Science degree in Veterinary
13 Science; I received my degree as a Doctor of Veterinary
14 Medicine at the same time. I practiced as a veterinarian in
15 the State of Washington until approximately 1987. From 1993
16 until 1996 I attended the College of Business and Economics
17 at the University of Arkansas in Fayetteville, Arkansas.
18 From 1996 until 1997 I studied at the College of Business at
19 Boise State University with an emphasis in accounting. I
20 passed the Uniform CPA exam in the fall of 1997; I am
21 currently a licensed CPA in the State of Idaho.
22 I was employed as a financial analyst by Hewlett
23 Packard from 1998 until 2000. In this position I provided
24 sole financial support for the HP test lab located in Boise,
25 a cost center with an annual budget in excess of $50
CASE NO. PAC-E-10-7
10/14/10
VAUGHN, C. (Di) 1
STAFF
1 million. I was solely responsible for coordinating the
2 semi-annual budgeting process, for developing and
3 implementing the allocation system used to distribute costs
4 to multiple profit centers, and for ensuring that costs
5 incurred were appropriate and met budgetary goals. During
6 this time I also served as inventory analyst for the
7 Personal LaserJet Division, a $2 billion per year profit
8 center. In this role, I was responsible for accurate
9 valuation of worldwide inventory and for removal of
10 intracorporate profit included in inventory value.
11 From 2000 until 2003 I was employed as Grants
12 Accountant (Financial Specialist) for the Center for
13 Geophysical Investigation of the Shallow Subsurface at Boise
14 State University; I was promoted to Senior Financial
15 Specialist in 2002. In this role, I was responsible for all
16 aspects of grant accounting for the Center, including
17 budgeting, submission, and ensuring that grant funds were
18 expended and accounted for in accordance with funding agency
19 regulations. I also assisted in the preparation of the BSU
20 F&A (Facilities and Administration) request used to set the
21 overhead rate applied to all federal grants awarded the
22 University.
23 I have been employed by the Commission as an
24 auditor since June 2007. I attended the annual regulatory
25 studies program sponsored by the National Association of
CASE NO. PAC-E-10-710/14/10 VAUGHN, C. (Di) 2
STAFF
1 Regulatory Utility Commissioners (NARUC) at Michigan State
2 University in August 2007.
3 SUMY
4 Q.What is the primary purpose of your testimony?
5 A.The purpose of my testimony is to summarize the
6 adjustments of all Staff members, to present the impact on
7 the Idaho revenue requirement of each individual's
8 adjustments, and to develop the final Idaho revenue
9 requirement that includes all Staff adjustments. I will
10 present in detail the specific adjustments that I propose.
11 Q.How were you able to determine the revenue
12 requirement effect of each of Staff's recommendations?
13 A.I determined what accounts in the rate case would
14 be changed by each adjustment. Using the linked Revenue
15 Adjustment Model and the Jurisdictional Allocation Model
16 (RA-JAM), I then determined the effect on revenue
17 requirement resulting from each adjustment.
18 Q.Please summarize the final Idaho revenue
19 requirement and compare that to the revenue requirement
20 proposed by the Company.
21 A.The Company requested an Idaho revenue increase of
22 $17,146,306 or $27,697,872 when grossed up for taxes; this
23 request resulted in an Idaho revenue increase of 13.66%.
24 The adjustments proposed by Staff result in an Idaho
25
CASE NO. PAC-E-10-710/14/10 VAUGHN, C. (D i) 3
STAFF
1 deficiency of $9,106,977 or $14,711,2671 when grossed up for
2 taxes; Staff's case results in an Idaho required revenue
3 increase of 7.25%. Staff's case reduces the Company
4 proposal by $8,039,329 or $12,986,605 when grossed up for
5 taxes; this represents a 47% reduction to the Idaho revenue
6 increase originally requested by the Company.
7
8
Q.Are you sponsoring any additional testimony?
A.Yes. I reviewed several specific areas of the
9 Company's filing that will be further discussed in my
10 testimony.
11 Q.Would you please summarize your recommendations in
13
12 those areas of the rate case that you personally reviewed?
A.My recommendations affecting revenue requirement
15
14 are as follows:
16
17
18
19
20
21
22
23
24
25
(1) Avian Settlement. In 2009 the Company and the
U. S. Attorney for Wyoming reached an agreement
associated with increasing protection for wildlife
habitat in and around the Company's transmission and
distribution assets. The Company requested recovery of
$500,000 in O&M expense and $1,352,283 in rate base
related to this agreement. I believe the $500,000 is a
non-recurring O&M expense and recommend the $500,000 be
removed from the current test year expenses. This
1 The difference between this revenue requirement of $14,711,267 and the
$14,802,287 shown in other Staff testimonies is due to the $1,603,785 adjustment
recommended by Staff witness Donn English.
CASE NO. PAC-E-10-710/14/10 VAUGHN, C . (D i) 4
STAFF
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
reduces the revenue requirement by $500,000 on a system
basis, thus reducing the Idaho revenue requirement by
$26,961. In addition, I believe the $1,352,283 in
transmission facility improvement should not be added
to rate base in this case since the accumulation of
minor transmission improvements falls below the
$5,000,000 threshold for pro-formed 2010 major plant
additions. This rate base reduction results in a
reduction to Idaho revenue requirement of $6,339.
(2) Bridger Coal Stripping. In Case No. PAC-E-09-08,
the Company filed for an Accounting Order authorizing
the Company to record, as a regulatory asset, the costs
associated with the removal of overburden and waste
materials at its affiliate coal mines. In January
2010, the Commission authorized the Company in Order
No. 30987 to record the removal costs as a regulatory
asset associated with its fuel account. Because this
regulatory asset was created by a change in accounting
procedures (EITF-04-6), I believe it would be
inappropriate for the asset to accrue a carrying charge
subsequent to inclusion in base rates. Therefore, I
recommend removing $1,169,114 from rate base; this
adjustment decreases Idaho revenue requirement by
$6,133.
(3) Medicare Subsidy. On March 23, 2010, the Patient
CASE NO. PAC-E-10-710/14/10 VAUGHN, C. (~i) 5
STAFF
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
Protection and Affordable Care Act (PPACA) was signed
into law. The Act, including a subsequent amendment to
the Act (the amendment is known as the Health Care and
Education Reconciliation Act signed into law
March 30, 2010), changes the deductibility of certain
costs incurred for post-retirement prescription drug
coverage. In Case No. PAC-E-10-04, the Company filed
for an accounting Order authorizing the Company to
create a regulatory asset and amortize the expenses
associated with the change in deductibility of retiree
drug benefits resulting from passage of the PPACA. In
this case, the Company calculated the amortization for
2011 to be $209,966. Staff believes that this amount
should be reduced by $4,999 because the Company
calculated the tax impact from January 1, 2010, rather
than from March 31, 2010 when the Act went into effect.
Because this was a situs allocation, this reduces Idaho
revenue requirement by $4,999.
Q.Are you sponsoring any Exhibits?
22
21 STAFF SUMY OF ADJUSTMNTS
A.Yes, I am sponsoring Staff Exhibit No. 108.
23
Q.Please summarize the case filed by the Company.
A.On a system basis, the Company reported
24 $4,117,757,655 in operating revenues, $3,386,414,150 in
25 operating expenses, and a rate base of $10,228,783,324.
CASE NO. PAC-E-10-710/14/10 VAUGHN, C. (D i) 6
STAFF
1 This resulted in an unadjusted return on rate base of
2 7.1499%. See Exhibit No. 108, Column (a).
3 On an Idaho basis, the Company reported
4 $261,796,035 in operating revenues, $223,164,426 in
5 operating expenses, and a rate base of $667,459,415. This
6 resulted in an unadjusted return on rate base of 5.7879%.
7 The Company requested 10.6% return on equity which resulted
8 in a request for an 8.3568% overall return on rate base.
9 Applying this return to the reported rate base, the Company
10 needed operating revenues of $55,777,915 in order to achieve
11 the requested rate of return. Since the Company reported
12 actual net operating revenues for return of $38,631,609,
13 this resulted in a revenue requirement of $17,146,306 or
14 $27,697,872 when grossed up for taxes. The Idaho revenue
15 requirement requested by the Company is a 13.66% increase
16 over current base rates. See Exhibit No. 108, Column (b).
17 Q.Please describe the Staff adjustment shown in
19
18 Exhibit No. 108, Column (c).
A.Staff witness Terri Carlock is sponsoring the
20 adjustment shown in Exhibit No. 108, Column (c). This
21 adjustment shows a decrease in the return on equity from the
22 10.6% requested by the Company to 10.0%. This results in a
23 decrease in revenue requirement of $2,167,989 (line 67) or
24 $3,502,135 when grossed up for taxes (line 69). The impact
25 of this adjustment is to decrease revenue requirement by
CASE NO. PAC-E-10-710/14/10 VAUGHN, C. (D i) 7
STAFF
1 1 . 73 % ( line 7 0) .
2 Q.Please describe the Staff adjustments shown in
3 Exhibit No. 108, Column (d).
4 A.Staff witnesses Marilyn Parker and Donn English
5 are sponsoring the adjustments shown in Exhibit No. 108,
6 Column (d). Staff witness Parker is sponsoring an imputed
7 revenue increase of $90,000 (line 2) from untimely
8 disconnect of power when properties are vacant. This
9 adjustment is discussed in detail in Staff witness Parker's
10 direct testimony.
11 Staff witness English is sponsoring several
12 adjustments. The largest adjustment reduces Operating and
13 Maintenance Expense (O&M) by removing wage, incentive,
14 benefit, and pension increases from 2009 and 2010; this
15 adjustment equals $70,954,556 on a system basis and
16 $4,079,517 when allocated to Idaho. This adjustment is
17 spread across multiple accounts and is shown in lines 9-18.
18 Other smaller adjustments to imputed revenue (line 5),
19 property tax (line 24), and the Affiliate Management Fee
20 (line 18) further reduce revenue requirement. These
21 adjustments are discussed in detail in Staff witness
22 English's direct testimony.
23 Staff witness English proposes an additional
24 adjustment to injuries and damages of $1,603,785 on a system
25 basis and $90,728 on an Idaho basis. This adjustment is
CASE NO. PAC-E-10-7
10/14/10 VAUGHN, C. (D i) 8
STAFF
1 discussed in detail by Staff witness English in his
2 testimony and is reflected in the Idaho revenue requirement
3 of $14,711,267 shown on Exhibit No. 108, Column (j),
4 line 69. However, this adjustment is not included in the
5 testimonies and exhibits of other Staff witnesses; and this
6 adjustment is not considered in the cost of service or rate
7 design recommendations.
8 The adjustments proposed by Staff witnesses Parker
9 and English increase operating revenues on an Idaho basis by
10 $97,826 (line 6) and reduce operating expenses on an Idaho
11 basis by $2,499,892 (line 31). These adjustments result in
12 a decrease in revenue requirement of $2,600,250 (line 67) or
13 $4,200,403 when grossed up for taxes (line 69). The impact
14 of these adj ustments is to decrease the Idaho revenue
15 requirement by 2.03% (line 70).
16 Q.Please describe the Staff adjustment shown in
17 Exhibit No. 108, Column (e).
18 A.Staff witness Bryan Lanspery is sponsoring the
19 adjustment shown in Exhibit No. 108, Column (e). He
20 proposes adjustments to Net Power Costs (NPC), and are
21 discussed in detail in Mr. Lanspery's direct testimony. The
22 NPC adj ustments decrease NPC on a system basis by
23 $40,903,589 and on an Idaho basis by $2,512,922 (line 20
24 minus line 4). These adjustments result in a decrease in
25 Idaho revenue requirement of $1,560,189 (line 67) or
CASE NO. PAC-E-10-710/14/10 VAUGHN, C. (D i) 9
STAFF
1 $2,520,305 when grossed up for taxes (line 69). The impact
2 of this adj ustment is to decrease the Idaho revenue
3 requirement by 1.24% (line 70) .
4 Q.Please describe the Staff adjustment shown in
5 Exhibit No. 108, Column (f).
6 A.Staff witnesses Randy Lobb and Joe Leckie are
7 sponsoring the adjustment shown in Exhibit No. 108, Column
8 (f). The majority of the adjustments reduce rate base and
9 are discussed in detail in Mr. Lobb's and Mr. Leckie's
10 testimonies. The amount of the Populus-Terminal
11 transmission line included for return on rate base is
12 reduced by 50% as proposed by Mr. Lobb. This results in a
13 rate base decrease of $400,765,483 on a system basis and
14 $23,444,781 on an Idaho basis (the majority of lines 36 and
15 37). Several other rate base items, including the Dunlap I
16 Wind Proj ect and other rate base updates, are reduced by a
17 total of $34,976,054 on a system basis and $2,046,099 on an
18 Idaho basis (included in lines 36 and 37). Also, the coal
19 stockpile inventory is reduced by $15,970,759 on a system
20 basis or $1,015,344 on an Idaho basis (line 42). In
21 addition to the rate base adjustments, Mr. Leckie proposes a
22 reduction to generation overhaul expense, reducing O&M by
23 $662,119 on a system basis and $49,154 on an Idaho basis
24 (line 12).
25 The adjustments proposed by Staff witnesses Lobb
CASE NO. PAC-E-10-710/14/10 VAUGHN, C. (Di) 10
STAFF
1 and Leckie reduce O&M expenses on an Idaho basis by $49,154
2 (line 20) and reduce Idaho rate base by $25,028,230 (line
3 61). These adjustments result in a decrease in revenue
4 requirement of $1,801,208 (line 67) or $2,909,643 when
5 grossed up for taxes (line 69). The impact of this
6 adjustment is to decrease the Idaho revenue requirement by
8
7 1 . 43% ( line 70).
Q.Please describe the Staff adjustment shown in
9 Exhibit No. 108, Column (g).
10 A.I am sponsoring the adjustments shown in Exhibit
11 No. 108, Column (g), and I will discuss these adjustments in
12 detail in my direct testimony to follow. In summary, my
13 adjustments result in a decrease in Idaho revenue
14 requirement of $30,974 (line 67) or $50,035 when grossed up
15 for taxes (line 69). The impact of these adjustments is to
17
16 decrease revenue requirement by 0.02% (line 70).
Q.Please describe the Staff adjustment shown in
18 Exhibit No. 108, Column (h).
19 A.Staff witness Terri Carlock is sponsoring the
20 adjustments shown in Exhibit No. 108, Column (h). These
21 adjustments result from treating the Idaho Irrigation Load
22 Control costs as power supply expense and reversing the
23 irrigator load decrement from normalized to actual loads.
24 This changes the system generation (SG) allocator for Idaho
25 from 5.5085% to 5.9056%. As shown in Column (h), this
CASE NO. PAC-E-10-710/14/10 VAUGHN, C. (Di) 11
STAFF
1 affects the adjustment amount of nearly every account.
2 These adjustments are discussed in detail in Staff witness
3 Carlock's direct testimony.
4 On an Idaho basis, this adj ustment increases
5 operating revenues by $4,191,848 (line 6), increases total
6 operating expenses by $1,095,478 (line 31), and increases
7 rate base by $40,095,425 (line 61). This results in an
8 increase in revenue requirement of $65,116 (line 67) or
9 $105,188 when grossed up for taxes (line 69). The impact of
10 this adjustment is to increase revenue requirement by 0.05%
11 (line 70).
12 Q.Please summarize the final Idaho revenue
13 requirement and compare that to the revenue requirement
14 proposed by the Company.
15 A.As shown in Exhibit No. 108, Column (b), the
16 Company requested an Idaho revenue increase of $17,146,306
17 (line 67) or $27,697,872 (line 69) when grossed up for
18 taxes i this request resulted in an Idaho revenue increase of
19 13.66% (line 70). As shown in Exhibit No. 108, Column (j),
20 the adjustments proposed by Staff result in an Idaho revenue
21 requirement of $9,106,977 (line 67) or $14,711,267 (line 69)
22 when grossed up for taxes ¡Staff's case results in an Idaho
23 required revenue increase of 7.25% (line 70). Staff's case
24 reduces the Company proposal by $8,039,329 or $12,986,605
25 when grossed up for taxes; this is a 47% reduction in Idaho
CASE NO. PAC-E-10-710/14/10 VAUGHN, C. (Di) 12
STAFF
1 revenue requirement increase originally requested by the
2 Company.
3 Q.Please describe the adjustments you recommend in
4 Exhibit No. 108, Column (g).
5 A.These adj ustments are discussed below.
6 AVIAN SETTLEMNT
7 Q.Please describe the nature of the Avian
8 Settlement.
9 A.In 2009 the Company and the U. S. Attorney for
10 Wyoming agreed to settle Case No. 09CR1 74 -B that was filed
11 wi th the United States District Court for the District of
12 Wyoming. Under the terms of the agreement, PacifiCorp
13 agreed to increase protection for wildlife habitat in and
14 around the Company's transmission and distribution assets.
15 In addition, the Company agreed to provide funds to various
16 wildlife agencies in Wyoming as well as Idaho, Utah and
17 Montana to support improvements to design and the
18 construction of avian-safe power lines.
19 Q.What were the Company adjustments associated with
20 the Avian Settlement?
21 A.The Company requested recovery of $500,000 for
22 injuries and damages related to Case No. 09CR174-B. I
23 believe this is a non-recurring expense that should be
24 removed from expenses for rate setting purposes. This
25 reduces the revenue requirement by $500,000 on a system
CASE NO. PAC-E-10-710/14/10
VAUGHN, C. (Di) 13
STAFF
1 basis, thus reducing the Idaho revenue requirement by
2 $26,961.
3 Q.Were there any other adjustments associated with
4 the Avian Settlement?
5 A.Yes. The Company requested an adjustment to rate
6 base of $1,352,283 for capital improvements of existing
7 power lines. The Company argues that these improvements
8 will benefit customers by protecting wild life habitat and
9 reducing avian related outages. See Company witness
10 McDougal, Di., pg. 25, lines 22-23, and pg. 26, line 1.
11 Q.Do you agree with the Company's request?
12 A.No. Although the improvements will provide some
13 benefit to customers, they should not be included in this
14 general rate case. The improvements described by the
15 Company consist of a number of small independent proj ects
16 rather than a single large project; the need for each
17 individual project is based on the findings of field studies
18 that survey "avian incidents," including bird fatalities
19 caused by power lines and damage to power facilities caused
20 by bird activity. Although I believe avian-related
21 improvements are reasonable, I believe this addition to rate
22 base is premature and should not be included for the
23 following reasons. First, because of the diverse nature of
24 the many projects contributing to this adjustment, the exact
25 cost of the project and date the project will be placed in
CASE NO. PAC-E-10-710/14/10 VAUGHN, C. (Di) 14
STAFF
1 service is neither known nor measurable. In addition, the
2 amount requested is pro-formed for 2010 and falls far below
3 the $5,000,000 threshold used to include major plant
4 additions expected to be placed in service during 2010.
5 Therefore, I believe the $1,352,283 should be removed from
6 rate base for this case, and this type of capital
7 improvement be included in the next general rate case. My
8 adjustment results in a rate base decrease for Idaho in the
9 amount of $79,860 and a reduction in depreciation expense of
10 $1,605 i the revenue requirement for Idaho decreases by
11 $8,194.
12 EITF-04-6: BRIDGER COAL STRIPPING AMORTIZATION
13 Q.Please describe the Bridger Coal Stripping
14 Amortization.
15 A.In Case No. PAC-E-09-08, the Company filed for an
16 Accounting Order authorizing the Company to record, as a
17 regulatory asset, the costs associated with the removal of
18 overburden and waste materials at its affiliate coal mines.
19 In January 2010, the Commission authorized the Company in
20 Order No. 30987 to record the removal costs as a regulatory
21 asset associated with its fuel account. The costs
22 associated with coal stripping were to be expensed through
23 Account 501, Fuel Expense, as the coal was extracted from
24 the mine and placed in inventory.
25 Q.Has the Company proposed an adjustment associated
CASE NO. PAC-E-10-710/14/10 VAUGHN, C. (Di) 15
STAFF
1 with the Bridger Coal Stripping Amortization?
2 A.Yes. The Company has added $1,169,114 to system
3 rate base for the costs related to coal stripping i $74,327
4 of this amount is allocated to Idaho.
5 Q.Do you agree with the Company's adjustment?
6 A.No. In its original filing, the Company did not
7 request a carrying charge on the regulatory asset associated
8 with mine stripping costs. I believe a carrying charge is
9 not justified or required. Because this regulatory asset is
10 created by a change in accounting procedures, I believe
11 recovery of the costs through a regulatory asset is adequate
12 and it is inappropriate for the asset to be included in rate
13 base or accrue a carrying charge. Therefore I recommend
14 that $1,169,114 be removed from rate base at the system
15 level, resulting in a reduction of rate base allocated to
16 Idaho of $74,327. This adjustment reduces the Idaho revenue
17 requirement by $6,133.
18 MEDICA SUBSIDY
19 Q.Please describe the Medicare Subsidy Amortization.
20 A.In the Medicare Modernization Act (MM) of 2003,
21 the federal government provided a 28 percent subsidy to
22 companies that provided a retiree drug discount. Subsequent
23 to negotiations related to the MMA, companies were allowed
24 to deduct 100 percent of the cost of the drug benefit
25 provided to their retirees even though the companies were
CASE NO. PAC-E-10-710/14/10 VAUGHN, C. (Di) 16
STAFF
1 paying only 72 percent of the benefits.
2 On March 23, 2010, the Patient Protection and
3 Affordable Care Act (PPACA) was signed into law. Due to
4 provisions included in the PPACA, including a subsequent
5 amendment (the amendment is known as the Health Care and
6 Education Reconciliation Act signed into law March 30,
7 2010), the portion of the expense offset by the 28 percent
8 subsidy is no longer deductible for tax purposes. Companies
9 may deduct only the net amount of the drug costs.
10 Therefore, companies must reduce the post-retirement benefit
11 obligation on the balance sheet by the amount of the
12 actuarially-determined subsidy to be received.
13 In Case No. PAC-E-10-04, the Company filed for an
14 Accounting Order authorizing the Company to record, as a
15 regulatory asset, the tax expense associated with enactment
16 of the PPACAi in addition, the Company requested that they
17 be allowed to amortize the expense over a four-year period
18 beginning January 1, 2011. In July 2010, the Commission
19 authorized the Company in Order No. 32028 to record costs
20 associated with the PPACA as a regulatory asset and to
21 amortize the expense over a four-year period beginning
23
22 January 1, 2011.
Q.Has the Company proposed an adjustment associated
25
24 with the Medicare Subsidy (PPACA) amortization?
A.Yes. The Company has proposed to expense $209,996
CASE NO. PAC-E-10-710/14/10 VAUGHN, C. (Di) 17
STAFF
2
1 in 2011 as the first of four expense amortizations.
Q.Does you propose an adjustment to the Company
4
3 adjustment?
A.Yes. The amount of the adjustment was calculated
5 as of January 1, 2010. However, the PPACA and the
6 subsequent amendment did not go into effect until March 31,
7 2010. In response to an audit request from Staff, the
8 Company calculated the amount of the adjustment effective
9 March 31, 2010 as $819,988 to be amortized over four years,
10 or $204,997 per year. Because this amount was calculated on
11 an Idaho basis, this results in a Staff adjustment of $4,999
12 to Idaho expense ($209,996 - $204,997 = $4,999) and an
14
13 equivalent reduction to Idaho revenue requirement.
Q.Does this conclude your direct testimony in this
16
15 proceeding?
17
18
19
20
21
22
23
24
25
A.Yes, it does.
CASE NO. PAC-E-10-7
10/14/10
VAUGHN, C. (D i) 18
STAFF
--
L~
(b
)
(e
)
(d
)
(e
)
(f
)
(g
)
(h
)
(i
)
+-
(j
)
i 1
Te
r
r
i
C
a
r
l
o
c
k
Te
r
r
i
C
a
r
l
o
c
k
ì
I
1
A
d
j
u
s
t
m
e
n
t
Ad
j
u
s
t
m
e
n
t
-
-
Pa
c
i
f
i
C
o
r
p
i
Re
t
u
r
n
o
n
Ma
r
i
l
y
n
P
a
r
k
e
r
Ne
t
i I
I
Po
w
e
r
Ca
s
e
Pa
c
i
f
i
C
o
r
p
Eq
u
i
t
y
&
Do
n
n
Br
y
a
n
Ad
j
u
s
t
m
e
n
t
!
as
F
i
l
e
d
-
Po
w
e
r
C
a
s
e
a
s
Re
d
u
c
e
d
t
o
En
g
l
i
s
h
La
n
s
p
e
r
y
Jo
e
L
e
c
k
i
e
Ce
c
i
l
y
V
a
u
g
h
n
Ir
r
i
g
a
t
o
r
To
t
a
l
l
d
a
h
o
I
I
P
U
C
S
t
a
f
f
To
t
a
l
S
v
s
t
e
m
Fi
l
e
d
-
-
I
d
a
h
o
10
.
0
%
Ad
j
u
s
t
m
e
n
t
s
Ad
i
u
s
t
m
e
n
t
s
Ad
j
u
s
t
m
e
n
t
s
Ad
j
u
s
t
m
e
n
t
s
Lo
a
d
C
o
n
t
r
o
l
Ad
j
u
s
t
m
e
n
t
s
i
C
a
s
e
--
-
-
-
-
-
-
i
De
s
c
r
i
p
t
i
o
n
o
f
A
c
c
o
u
n
t
S
u
m
m
a
i
y
:
--
l
-
-
,
i
!
-.
Op
e
r
a
t
i
n
g
R
e
v
e
n
u
e
s
1
t-
~
-
--
-
-
-
-
__
-
l
_
_
_
(2
)
l§
e
n
e
r
a
l
B
u
s
i
n
e
s
s
R
e
v
e
n
u
e
s
i
3,
2
9
7
,
6
5
4
,
1
7
6
20
2
,
7
3
3
,
1
6
2
0
9t
~
0
0
0
0
90
,
0
0
0
i
20
2
,
8
2
3
,
1
6
2
i
I
n
t
e
r
d
e
p
a
r
t
m
e
n
t
a
l
--
--
-
_
.
--
-
-
-
-
r
-
-
-
(3
)
0
0
0
-~
-
~
0
0
0
0
0'
0
--
-
--
+-
-
~
-
(4
)
Sp
e
c
i
a
l
S
a
l
e
s
60
8
,
3
3
4
,
8
5
8
45
,
2
8
9
,
3
8
2
'
0
0
53
5
,
7
6
1
0
0
3,3
0
3
,
2
4
6
3,
8
3
9
,
0
0
7
L
-
49
,
1
2
8
,
3
8
9
(5
)
Ot
h
e
r
O
p
e
r
a
t
i
n
g
R
e
v
e
n
u
e
s
21
1
,
7
6
8
,
6
2
1
13
,
7
7
3
,
4
9
2
0
7,
8
2
6
0
0'
0
88
,
6
0
1
89
6
,
2
7
1
14
,
6
6
9
,
9
1
9
(6
)
!
T
o
t
a
l
O
p
e
r
a
t
i
n
g
R
e
v
e
n
u
e
s
i
4,
1
1
7
,
7
5
7
,
6
5
5
26
1
,
7
9
6
,
0
3
5
0
97
,
8
2
6
53
5
,
7
6
1
0
0
4,
1
9
1
,
8
4
4,8
2
5
,
4
3
4
1
26
6
,
6
2
1
,
4
7
0
~
.
~_
.
_
-
-r
(7
)
iL
,
-_
.
_
.
_
.
.
_
-
"
"
-
-
"
.
(8
)
Op
e
r
a
t
i
n
g
E
x
p
e
n
s
e
s
:
.-
-
-
-
,
-
_
.
.
r
-
(9
)
'S
t
e
a
m
P
r
o
d
u
c
t
i
o
n
84
3
,
7
2
1
,
0
0
6
60
,
4
0
,
0
7
0
0
(1
,
4
!
l
~
!
9
0
10
5
,
2
5
8
0
0
97
5
,
8
9
2
(4
1
1
,
6
4
)
59
,
9
9
,
4
3
0
--
-
(1
0
)
Nu
c
l
e
a
r
P
r
o
d
u
c
t
i
o
n
0
0
0
0
0
0
0
0
0
0
--
-
-
-
-
~
-
~
~y
d
r
o
P
r
o
d
u
c
t
i
o
n
35
,
8
3
5
,
2
0
2
2,
1
3
3
,
9
3
0
0
(1
4
9
,
8
2
3
)
0
0
0
14
3
,
0
2
2
(6
,
8
0
1
)
2,
1
2
7
,
1
2
9
--
(1
2
)
Ot
h
e
r
P
o
w
e
r
S
u
p
p
l
y
95
6
,
8
4
,
4
9
3
79
,
7
0
5
,
5
6
1
(1
9
0
)
(1
1
,
4
5
1
)
(2
,
1
5
1
,
6
5
3
)
(4
9
,
1
5
4
)
0
(3
,
8
9
3
,
9
0
4
)
(6
,
1
0
6
,
3
5
1
73
,
5
9
9
,
2
1
0
(1
3
)
Tr
a
n
s
m
i
s
s
i
o
n
16
3
,
3
4
2
,
0
3
0
10
,
5
8
8
,
4
6
0
0
69
,
2
3
4
0
0
76
2
,
8
3
2
83
2
,
0
6
11
,
4
2
0
,
5
4
9
--
(1
4
)
Di
s
t
r
i
b
u
t
i
o
n
20
4
,
3
2
0
,
4
0
1
11
,
4
3
4
,
5
6
0
(1
,
2
5
1
,
6
8
1
0
0
0
0
(1
,
2
5
1
,
6
8
1
10
,
1
8
~
~
--
-
_
.
(1
5
)
Cu
s
t
o
m
e
r
A
c
c
o
u
n
t
i
n
g
89
,
2
7
9
,
5
0
4,
6
4
3
,
8
3
6
0
(2
3
7
,
1
5
2
-~
0
0
0
(2
3
7
,
1
5
2
)
4,
4
0
,
6
8
4
f-
-
-
01
i
-+
(1
6
)
Cu
s
t
o
m
e
r
S
e
r
v
i
c
e
&
I
n
f
o
!
64
,
6
2
6
,
1
0
9
1,
8
4
7
,
4
5
--
~
0
0
'4
0
0'
1
,
8
4
7
,
4
5
8
--
-
-
-
-
_
.
_
~
i
-
1
01
-
-
-
-
-
0
(1
7
)
Sa
l
e
s
0
0
0
--
-
~
--
0
0
o
i
0
--
-
-
-
-
-
_
.
-
.
-
.
._
_
.
-
(4
6
8
,
4
4
7
f
(1
8
)
Ad
m
i
n
i
s
t
r
a
t
i
v
e
&
G
e
n
e
r
a
l
i
15
3
,
1
4
6
,
2
5
0
11
,
4
9
4
,
2
9
7
0
(9
3
0
,
4
1
6
)
0
0
(3
1
,
9
6
0
)
1
49
3
,
9
3
0
11
,
0
2
5
,
8
4
9
--
,
.
(1
9
)
I
(2
0
)
To
t
a
l
0
&
M
E
x
p
e
n
s
e
s
2,
5
1
1
,
1
1
3
,
9
9
6
18
2
,
2
5
4
,
1
9
9
(1
9
0
)
(4
,
0
7
3
,
3
1
2
)
(1
,
9
7
7
,
1
6
1
(4
9
,
1
5
4
)
(3
1
,
9
6
0
)
(1
,
5
1
8
,
2
2
8
)
(7
,
6
5
0
,
0
0
5
)
17
4
,
6
0
4
,
1
9
2
(2
1
)
(2
2
)
De
p
r
e
c
i
a
t
i
o
n
43
9
,
6
5
5
,
4
5
7
27
,
4
7
7
,
4
7
8
0
0
0
(4
5
,
2
1
9
)
(1
,
4
9
7
)
1,4
2
7
,
5
3
7
1,
3
8
0
,
8
2
1
28
,
8
5
8
,
2
9
9
(2
3
)
Am
o
r
t
i
z
a
t
i
o
n
E
x
p
e
n
s
e
41
,
4
4
7
,
1
2
4
2,
1
0
0
,
4
8
0
0
0
0
0
0
11
6
,
0
1
5
11
6
,
0
1
5
2,2
1
6
,
4
9
5
(2
4
)
Ta
x
e
s
O
t
h
e
r
T
h
a
n
I
n
c
o
m
e
11
8
,
5
5
6
,
1
4
9
5,
7
3
5
,
3
3
0
0
(1
5
,
5
3
6
)
0
0
0
27
8
,
7
2
0
26
3
,
1
8
3
5,
9
9
8
,
5
1
3
(2
5
)
In
c
o
m
e
T
a
x
e
s
-
F
e
d
e
r
a
l
(1
5
5
,
0
6
7
,
7
6
8
(1
7
,
4
7
7
,
5
9
6
44
,
0
0
1,
3
9
9
,
4
4
3
83
9
,
7
2
7
26
5
,
5
5
2
13
,
2
9
4
81
6
,
9
0
6
3,
3
7
8
,
9
2
8
(1
4
,
0
9
8
,
6
6
7
(2
6
)
In
c
o
m
e
T
a
x
e
s
-
S
t
a
t
e
(2
0
,
7
2
7
,
3
7
9
(1
,
9
5
2
,
7
3
9
1,
5
3
6
18
9
,
5
1
3
11
4
,
0
7
5
36
,
1
6
4
1,8
0
6
11
5
,
8
0
5
45
8
,
8
9
9
(1
,
4
9
3
,
8
4
2
(2
7
)
In
c
o
m
e
T
a
x
e
s
-
D
e
f
N
e
t
45
8
,
7
8
8
,
2
4
6
25
,
5
0
8
,
2
1
3
0
0
0
0
(8
4
5
)
(1
2
3
,
5
8
3
)
(1
2
4
,
4
2
8
)
25
,
3
8
3
,
7
8
5
(2
8
)
In
v
e
s
t
m
e
n
t
T
a
x
C
r
e
d
i
t
A
d
j
.
(1
,
6
7
2
,
7
1
0
(2
0
1
,
4
9
4
)
0
0
0
0
0
(1
3
,
6
6
1
)
(1
3
,
6
6
1
)
(2
1
5
,
1
5
5
(2
9
)
Mi
s
e
R
e
v
e
n
u
e
&
E
x
p
e
n
s
e
(5
,
6
7
8
,
9
6
5
)
(2
7
9
,
4
4
5
)
0
0
0
0
0
(4
,
0
3
4
)
(4
,
0
3
)
(2
8
3
,
4
7
8
(3
0
)
(3
1
)
To
t
a
l
O
p
e
r
a
t
i
n
g
E
x
p
e
n
s
e
s
3,
3
8
6
,
4
1
4
,
1
5
0
22
3
,
1
6
4
,
4
2
6
45
,
3
5
2
(2
,
4
9
9
,
8
9
2
(1
,
0
2
3
,
3
6
0
20
7
,
3
4
3
(1
9
,
2
0
2
)
1,
0
9
5
,
4
7
8
(2
,
1
9
4
,
2
8
2
)
22
0
,
9
7
0
,
1
4
1
(3
2
)
(3
3
)
Op
e
r
a
t
i
n
g
R
e
v
e
n
u
e
f
o
r
R
e
t
u
r
n
73
1
,
3
4
3
,
5
0
5
38
,
6
3
1
,
6
0
9
(4
5
,
3
5
2
)
2,5
9
7
,
7
1
8
1,
5
5
9
,
1
2
0
(2
0
7
,
3
4
)
19
,
2
0
2
3,0
9
6
,
3
7
0
7,
0
1
9
,
7
1
6
45
,
6
5
1
,
3
2
9
(3
4
)
Pa
c
i
f
i
C
o
r
p
Id
a
h
o
R
e
v
e
n
u
e
R
e
q
u
i
r
e
m
e
n
t
an
d
Su
m
m
a
r
y
o
f
A
d
j
u
s
t
m
e
n
t
s
PA
C
-
E
-
1
0
-
7
Ex
h
i
b
i
t
N
o
.
1
0
8
Ca
s
e
N
o
.
P
A
C
-
E
-
1
0
-
7
Va
u
g
h
n
,
C
.
,
S
t
a
f
f
10
/
1
4
/
1
0
P
a
g
e
1
o
f
2
I
Pa
c
i
f
i
C
o
r
p
Id
a
h
o
R
e
v
e
n
u
e
R
e
q
u
i
r
e
m
e
n
t
an
d
Su
m
m
a
r
y
o
f
A
d
j
u
s
t
m
e
n
t
s
PA
C
-
E
-
1
0
-
7
(a
)
I
(
b
)
t
-
(
c
)
(
d
)
-
+
~
~
l
~
i
(
g
)
1
(
h
)
1
(
i
)
I
O
J
I
1
I
I
i
T
e
r
r
i
C
a
r
l
o
c
k
¡
T
e
r
r
C
a
r
l
o
c
k
i
A
d
j
u
s
t
m
e
n
t
;
A
d
j
u
s
t
m
e
n
t
-
Pa
c
i
f
i
C
o
r
p
R
e
t
u
r
n
o
n
M
a
r
i
l
y
n
P
a
r
k
e
r
I
N
e
t
Po
w
e
r
C
a
s
e
P
a
c
i
f
i
C
o
r
p
E
q
u
i
t
y
&
D
o
n
n
B
r
y
a
n
I
A
d
j
u
s
t
m
e
n
t
as
F
i
l
e
d
-
-
P
o
w
e
r
C
a
s
e
a
s
R
e
d
u
c
e
d
t
o
E
n
g
l
i
s
h
L
a
n
s
p
e
r
y
'
J
o
e
L
e
c
k
i
e
C
e
c
i
l
y
V
a
u
g
h
n
I
r
r
i
g
a
t
o
r
I
T
o
t
a
l
l
d
a
h
o
I
I
P
U
C
S
t
a
f
f
To
t
a
l
S
y
s
t
e
m
F
i
l
e
d
-
-
I
d
a
h
o
1
0
.
0
%
A
d
i
u
s
t
m
e
n
t
s
A
d
i
u
s
t
m
e
n
t
s
I
A
d
j
u
s
t
m
e
n
t
s
A
d
j
u
s
t
m
e
n
t
s
L
o
a
d
C
o
n
t
r
o
l
A
d
j
u
s
t
m
e
n
t
s
C
a
s
e
i
i
~
~
i
'
-
~
-
t
~
~
~
~
~
-
~
-
-
-
-
-
-
18
,
5
0
1
,
5
3
3
'
4
0
~
f
-
~
'
1
6
8
,
7
8
2
,
7
2
8
I
_
0
0
0
(
1
,
9
3
9
,
9
0
3
(
7
4
,
4
9
0
)
'
5
8
,
9
1
6
,
4
3
9
5
6
,
9
0
2
,
0
4
1
,
2
2
5
,
6
8
4
,
7
7
4
13
,
1
0
4
,
5
1
6
(
0
)
.
0
0
0
(
2
2
,
0
7
6
,
1
5
8
O
!
(
1
,
5
9
1
,
3
3
1
)
(
2
3
,
6
6
7
,
4
9
0
(
2
3
,
6
6
7
,
4
9
0
--
-
~
~
-
"
"
,
.
.
-
-
-
-
.
_
-
-
"
13
6
,
4
9
6
,
7
7
1
4
,
1
7
~
~
&
_
.
_
_
_
_
0
0
0
0
(
7
4
,
3
2
7
)
1
2
6
2
,
8
7
2
1
8
8
,
5
4
4
,
3
6
2
,
6
6
0
57
,
5
1
4
,
0
5
5
3
,
3
5
2
,
8
5
2
0
0
0
0
0
i
2
4
1
,
6
8
2
4
1
,
6
8
6
3
,
5
9
4
,
5
3
8
--
-
_
.
.
-
-
_
.
o
0
0
0
0
0
0
0
0
0
--
-
-
-
_
.
_
.
_
.
-
_
.
~
43
,
5
8
0
,
1
1
8
2
,
5
7
0
,
3
3
5
0
0
0
0
0
1
0
4
,
1
3
6
,
1
0
4
,
1
3
6
2
,
6
7
4
,
4
7
1
-_
.
.
_
_
.
~
-
-
15
7
,
1
6
5
,
6
5
9
1
2
,
1
4
6
,
1
3
6
0
0
0
(
1
,
0
1
5
,
3
4
)
0
0
(
1
,
0
1
5
,
3
4
1
1
,
1
3
0
,
7
9
1
._
-
-
-
-
-
-
-
16
7
,
9
1
8
,
1
1
6
9
,
9
5
5
,
9
0
0
0
0
0
0
3
3
5
,
1
7
6
3
3
5
,
1
7
6
1
0
,
2
9
1
,
0
8
2
~-
'
!
l
~
3
,
0
9
5
,
9
6
1
5
8
9
(
3
2
,
2
8
9
)
(
1
3
,
2
9
5
)
1
3
,
4
2
9
(
2
1
8
)
7
4
,
1
7
2
3
2
,
3
8
8
3
,
1
2
8
,
3
5
7
33
,
8
5
4
,
5
4
7
3
,
5
0
3
,
6
4
,
0
0
0
i
0
0
(
1
2
)
(
1
2
)
3
,
5
0
3
,
6
2
8
,.
"
"
.
.
,
,
~
m
!
'
,
,
t
,
*
-
,
.
"
.
'
.
'
"
"
'
.
"
"
19
,
1
6
5
,
7
4
2
,
4
9
7
1
1
,
2
0
7
,
7
0
4
,
9
5
g
t
-
5
8
9
(
3
2
,
2
8
9
)
(
1
3
'
2
-
~
~
t
_
~
~
~
-
-
(
2
5
,
0
2
7
,
9
7
6
(
1
4
9
'
0
=
t
~
_
~
'
~
~
:
I
3
3
,
1
2
8
,
3
4
0
1
'
2
4
0
,
8
3
3
'
2
:
~
--
-
-
-
~
-
-
-
-
-
-
-
-
-
(6
,
2
5
7
,
4
4
0
,
3
7
5
(
3
7
1
,
6
8
1
,
9
9
3
0
0
0
!
0
1
,
4
9
7
(
1
6
,
9
9
6
,
7
1
9
(
1
6
,
9
9
5
,
2
2
2
(
3
8
8
,
6
7
7
,
2
1
5
(4
0
5
,
5
6
,
1
4
2
_
_
_
.
£
1
~
0
~
~
_
~
~
_
.
-
0
0
0
1
-
-
-
(
3
1
3
)
_
~
(
9
1
9
,
7
2
5
)
(
9
2
0
,
0
3
8
)
(
2
2
,
5
2
5
.
9
8
~
(2
,
1
9
1
,
7
7
1
,
7
6
5
(
1
4
0
,
5
8
8
-
'
8
3
.
_
_
_
.
_
_
0
0
_
_
0
0
_
8
4
5
_
_
.
(
1
2
9
,
1
3
3
)
(
1
2
8
,
2
8
8
)
(
1
4
O
,
7
1
7
,
_
~
~
?
(7
,
2
5
0
,
0
5
4
)
(
2
2
8
~
_
_
_
(
3
2
4
)
1
2
(
2
3
)
6
0
~
_
_
_
_
_
(
1
5
,
4
7
6
)
(
1
5
,
7
5
1
)
(
2
4
4
,
O
l
~
(2
0
,
2
5
8
,
O
~
_
_
_
~
~
~
~
_
_
_
_
_
_
0
0
0
0
o
!
(
4
6
,
9
7
6
)
(
4
6
,
9
7
6
)
(
9
9
,
6
7
3
o
0
0
0
0
0
0
0
0
0
(5
4
,
6
7
8
,
8
3
5
(
5
,
1
9
2
,
7
6
0
0
0
0
0
0
(
1
4
4
,
8
9
3
)
(
1
4
4
,
8
9
3
)
(
5
,
3
3
7
,
6
5
3
j
(8
,
9
3
6
,
9
5
9
,
1
7
3
(
5
4
'
2
4
5
,
5
4
t
=
-
(
3
2
4
)
1
2
(
2
3
)
(
2
5
3
)
2
,
3
4
2
(
1
8
,
2
5
4
,
9
2
1
(
1
8
,
2
5
3
,
1
6
8
(
5
5
8
,
4
9
8
,
7
1
2
-l
1
-
10
,
2
2
8
,
7
8
3
,
3
2
4
i
6
6
7
,
4
5
9
4
_
_
_
2
6
4
(
3
2
,
2
7
7
)
(
1
3
,
3
~
(
2
5
,
0
2
8
,
2
3
0
1
(
1
4
6
,
6
9
3
)
1
4
0
,
0
9
5
,
4
2
5
1
1
4
,
8
7
5
,
1
7
2
1
6
8
2
,
3
3
4
,
5
8
7
7.
1
4
9
9
%
1
5
.
7
8
7
9
%
-
0
.
0
0
%
0
.
3
8
9
5
%
0
.
2
3
3
7
%
!
0
.
2
1
6
9
%
0
.
0
0
4
5
%
0
.
0
6
9
%
0
.
8
9
4
3
%
6
.
6
9
0
5
%
!
10
.
6
0
0
0
%
-
0
.
6
0
0
0
%
0
.
0
0
0
0
%
0
.
0
0
0
%
0
.
~
~
%
0
.
~
~
%
0
.
0
0
0
0
%
-
0
.
6
0
%
1
0
.
0
0
0
0
%
8.
3
5
%
-
0
.
3
3
1
6
%
0
.
0
0
0
0
%
0
.
0
0
0
%
0
.
~
~
%
0
.
0
0
0
0
%
0
.
0
0
0
0
%
-
0
.
3
3
1
6
%
8
.
0
2
5
1
%
1
55
,
7
7
7
,
9
1
5
(
2
,
2
1
3
,
3
4
1
(
2
,
6
1
1
)
(
1
,
0
6
9
)
(
2
,
0
0
8
,
5
5
0
(
1
1
,
7
7
2
)
3
,
2
1
7
,
6
5
6
(
1
,
0
1
9
,
6
0
9
5
4
,
7
5
8
,
3
0
6
17
,
1
4
6
,
3
0
6
(
2
,
1
6
7
,
9
8
9
(
2
,
6
0
,
2
5
0
(
1
,
5
6
0
,
1
8
9
)
(
1
,
8
0
1
,
2
0
8
(
3
0
,
9
7
4
)
6
5
,
1
1
6
(
8
,
0
3
9
,
3
2
9
9
,
1
0
6
,
9
7
7
1.
6
1
5
4
0
.
0
0
0
0
0
.
~
~
0
.
0
0
0
0
.
0
0
0
0
.
0
0
0
0
0
.
~
~
0
.
~
~
1
.
6
1
5
4
27
,
6
9
7
,
8
7
2
(
3
,
5
0
2
,
1
3
5
(
4
,
2
0
0
,
4
0
3
(
2
,
5
2
0
,
3
0
5
(
2
,
9
0
9
,
6
4
(
5
0
,
0
3
5
)
1
0
5
,
1
8
8
(
1
2
,
9
8
,
6
0
5
1
4
,
7
1
1
,
2
6
7
13
.
6
6
%
-
1
.
3
%
-
2
.
0
3
%
-
1
.
2
4
%
-
1
,
4
3
%
-
0
.
0
2
%
0
.
0
5
%
-
6
,
4
1
%
7
.
2
5
%
!
1-
.
(3
5
)
~~
i-
3
7
)
i
(3
8
)
,
(3
9
)
(4
0
)
(4
1
1
(~
~
(4
3
)
(4
4
)
,
'-
-
(4
5
)
!
~~
(4
7
)
(4
8
l
(4
9
)
(5
0
)
(5
1
)
(5
2
)
1-
-
-
-
(5
3
)~(5
5
)
(5
6
)
(5
7
)
(5
8
)
(5
9
)
(6
0
)
~T
o
t
a
i
R
a
t
e
B
a
s
e
(6
2
)
1
(6
3
)
(6
4
)
(6
5
)
(6
6
)~~(6
9
)
'7
0
'
De
s
c
r
i
p
t
i
o
n
o
f
A
c
c
o
u
n
t
S
u
m
m
a
r
y
:
Ra
t
e
B
a
s
e
:
1 E
l
e
c
t
r
i
c
P
l
a
n
t
i
n
S
e
r
v
i
c
e
Pl
a
n
t
H
e
l
d
f
o
r
F
u
t
u
r
e
U
s
e
--
-
-
-
-
-
~
Mi
s
c
D
e
f
e
r
r
e
d
D
e
b
i
t
s
Ele
c
P
l
a
n
t
A
c
t
l
A
d
j
Nu
c
l
e
a
r
F
u
e
l
Pr
e
p
a
y
m
e
n
t
s
Fu
e
l
S
t
o
c
k
Ma
t
e
r
i
a
l
&
S
u
p
p
l
i
e
s
Wo
r
k
i
n
g
C
a
p
i
t
a
l
We
a
t
h
e
r
i
z
a
t
i
o
n
L
o
a
n
s
Mi
s
c
e
l
l
a
n
e
o
u
s
R
a
t
e
B
a
s
e
To
t
a
l
E
l
e
c
t
r
i
c
P
l
a
n
t
Ra
t
e
B
a
s
e
D
e
d
u
c
t
i
o
n
s
:
Ac
c
u
m
P
r
o
v
F
o
r
D
e
p
r
_
.
.
_
_
~
_
Ac
c
u
m
P
r
o
v
F
o
r
A
m
o
r
t
--
-
-
-
-
-
-
-
-
-
-
-
-
Ac
c
u
m
D
e
f
I
n
c
o
m
e
T
a
x
e
s
Un
a
m
o
r
t
i
z
e
d
I
T
C
--
Cu
s
t
o
m
e
r
A
d
v
f
o
r
C
o
n
s
t
Cu
s
t
o
m
e
r
S
e
r
v
i
c
e
D
e
p
o
s
i
t
s
Mi
s
c
e
l
l
a
n
e
o
u
s
R
a
t
e
B
a
s
e
D
e
d
u
c
t
i
o
n
s
To
t
a
l
R
a
t
e
B
a
s
e
D
e
d
u
c
t
i
o
n
s
Un
a
d
j
u
s
t
e
d
R
e
t
u
r
n
o
n
R
a
t
e
B
a
s
e
(
R
O
R
B
)
Re
q
u
e
s
t
e
d
o
n
E
q
u
i
t
y
Re
q
u
e
s
t
e
d
R
e
t
u
r
n
o
n
R
a
t
e
B
a
s
e
Re
v
e
n
u
e
R
e
q
u
i
r
e
t
o
M
e
e
R
e
q
u
e
s
t
e
d
R
O
R
B
Re
v
e
n
u
e
R
e
q
u
i
r
e
m
e
n
t
B
e
f
o
r
e
I
n
c
o
m
e
T
a
x
e
s
Ta
x
I
m
p
a
c
t
Re
v
e
n
u
e
R
e
q
u
i
r
e
m
e
n
t
G
r
o
s
s
e
d
-
U
p
f
o
r
T
a
x
e
s
Pe
r
c
e
n
t
R
e
v
e
n
u
e
R
e
o
u
i
r
e
m
e
n
t
Ex
h
i
b
i
t
N
o
.
1
0
8
I
Ca
s
e
N
o
.
P
A
C
-
E
-
1
O
-
7
Va
u
g
h
n
,
C
.
,
S
t
a
f
f
10
/
1
4
/
1
0
P
a
g
e
2
o
f
2
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 14TH DAY OF OCTOBER 2010,
SERVED THE FOREGOING DIRECT TESTIMONY OF CECIL Y VAUGHN, IN
CASE NO. PAC-E-1O-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.westona!pacificorp.com
E-MAIL: ONLY
MARK C MOENCH
DANIEL E SOLANDER
ROCKY MOUNTAIN POWER
E-MAIL: mark.moencha!pacificorp.com
daniel. solandera!pacificorp.com
RANDALL C BUDGE
RACINE OLSON NYE ET AL
PO BOX 1391
POCATELLO ID 83204-1391
(FED EX)
E-MAIL: rcb(fracinelaw.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(fyanel.net
PAUL J HICKEY
HICKEY & EVANS LLP
1800 CAREY AVE., SUITE 700
PO BOX 467
CHEYENNE WY 82003
(FED EX)
E-MAIL: phickeya!hickeyevans.com
E-MAIL: ONLY
KATIE IVERSON
BRUBAKER & ASSOCIATES
E-MAIL: kiverson(fconsultbai.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: tbuller(ßagrium.com
jaharris(ßagrium.com
BENJAMIN J OTTO
IDAHO CONSERVATION LEAGUE
710 N 6TH STREET
POBOX 844
BOISE ID 83702
(HAND CARRIED)
E-MAIL: botto(ßidahoconservation.org
E-MAIL: ONLY
DR. DON READING
E-MAIL: dreading(ßmindspring.com
MELINDA J DAVISON
DAVISON VAN CLEVE, P.C.
333 SW TAYLOR, SUITE 400
PORTLAND, OR 97204
(FED EX)
E-MAIL: mjd(ßdvclaw.com
RONALD L WILLIAMS
WILLIAMS BRADBURY, P.C.
1015 W HAYS STREET
BOISE ID 83702
(HAND CARRIED)
E-MAIL: ron(ßwiliamsbradbury.com
BRAD M PURDY
ATTORNEY AT LAW
2019 N 17TH STREET
BOISE ID 83702
(HAND CARRIED)
E-MAIL: bmpurdy(ßhotmail.com
3J ": .l~
SECRETARY
CERTIFICATE OF SERVICE