20130816Lobb Stipulation Testimony.pdf

BEFORE THE
IDAHO PUBLIC UTILITIES
IN THE MATTER OF THE APPLICATION OF
PACIFTCORP DBA ROCKY MOUNTAIN
POWER TO INITIATE DISCUSSIONS WITH
INTERESTED PARTIES ON ALTERNATIVE
RATE PLAN PROPOSALS.
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GASE NO. PAC-E-13-04
DIRECT TESTIMONY OF RANDY LOBB
IN SUPPORT OF THE STIPULATION
IDAHO PUBLIC UTILITIES COMMISSION
AUGUST 16,2013
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O. Please state your name and business address for
the record.
A. My name is Randy Lobb and my business address is
472 West Washington SLreet, Boise, Idaho.
A. By whom are you employed?
A. I am employed by the Idaho Public Utilities
Commission as Utilities Division Administrat.or.
O. What is your educat.ional and professional
background?
A. I received a Bachelor of Scj-ence Degree in
Agricult.ural Engineering from the University of Idaho in
1980 and worked for the fdaho Department of Water Resources
from,June of l-980 to November of 1987. I received my Idaho
Iicense as a regist,ered professional Civil Engineer in 1985
and began work aL t,he Idaho Public Utilities Commission in
December of 1,987. My duties at the Commission current,ly
include case management and oversight, of all technj-ca1 staff
assigned to Commission filings. I have conducted analysis
of ut,ility rate applicatj-ons, rate design, tariff analysis
and customer petitions. I have testified in numerous
proceedings before the Commi-ssion including cases dealing
with rate structure, cost of service, power supply, line
extensions, regulat,ory policy and facility acquisitions.
O. What is the purpose of your testimony in this
case ?
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A. The purpose of my testj-mony is to describe the
process leading to the filed Stipulation (Proposed
Set,t.lement) , to present the terms of the Stipulation and t.o
explain the rationale for Staff's support.
O. Will you please summarize your testimony?
A. The Settlement Stipulation filed in this case/ was
negotiated outside of a tradj-tional general rate case
filing, yet represents a reasonable alternat,ive to what
1ike1y would have occurred through the traditj-onal
ratemakj-ng process. Staf f recognj-zes the concern expressed
by various parti-es regarding settlement in advance of a
Company rate filing but maintains that the limit.ed j-mpact of
the set,tl-ement is as close to a non-filing as possible.
Moreover, through broad audit of Company results
of operations, revj-ew of rate cases filed in other
jurisdictions, and thorough discussion and negotiation of
Iimited settlement terms, Staff and other parties to the
case agree t,hat the Set,t,lement Stipulation is in the best
interest of cusLomers and should be approved by the
Commi-ssion.
O. Would you please describe the Lerms of the
proposed Stipulation?
A. Yes. The Stipulation has five basic provisions.
They are:
1. A 0.772 base rate revenue increase effective January A,
2Ol4 to reflect previously approved inclusion of the
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Populous to Terminal Transmission Ij-ne,
A "Stay Out Provision" whereby the Company isprohibited from filing for a base rate j-ncrease before
May 31, 201-5 and new base rates cannot become effectj-veprior to ,fanuary l, 201-6 ,
3 . A Lake Side II ECAM adder beginning ,January 1, 201-5 toreflect both costs and benefits of the new combinedcycle generat.J-ng p1ant,
4. Deferral, until the next general rate case , of changesin depreciat.ion expense to be ultimately approved bythe Commj-ssion in Case No. PAC-E-L3-02,
5. Deferral of Carbon CoaI plant depreciation expenses and
removal costs based upon Commission Order No. 32701 and
an amount to be ultj-mately decided by the Commission in
Case No. PAC-E-13-02.
O. Are there any other terms specified in the
Stipulation?
A. Yes, there are two other terms that primarily
affect Monsanto. The first. is modification of ECAM
methodology, consistent, with Commissj-on Order No. 32771-, to
assign cost responsibillty to the various customer classes
for an interim period. The second is agreement bet.ween
Monsanto and the Company regarding annual true-up of the
interruptible credit within the Electric Servj-ce Agreement.
The Stipulation is attached as Staff Exhibit. No. 101.
History
On January 1-0, 2012, Lhe Commission issued Order
No. 32432 in Case No. PAC-E-11-l-2 approving a Stipulated
Settlement for a two-year rate plan through January 1, 201-4.
The Stipulation prohibited Rocky Mountain Power from filing
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another rate case untj-l May 31, 2013, wj-th new rates not
ef f ect,ive prior to .Tanuary L, 201,4 .
fn February of 20L3, Rocky Mountain personnel made
an informal proposal to Commission Staff and other parties
to extend the multi-year agreement in lieu of another
general rate case filing. Staff saw merit in the Company's
proposal and suggest,ed that the Company file a case "to
investigat,e alternatives to a general rate case" so that all
int.erested part,ies would have an opportunity to participate.
The Company maintaj-ned that if a deal could not be struck,
it would file a tradit.ional general rat,e case application on
May 31, 20L3.
On March 31-, 2073, Rocky Mount,ain filed a Notice
of Intent to File a general- rate case and an Application
requesting the Commission provide notice to parties
interested j-n entering into rate plan settlement.
discussions.
O. What was included in the Company's Application?
A. The Applicat.ion consisted of two pages that simply
requested t.he Commission open and notj-ce a docket and set. an
intervention deadline that would formally notify interested
parties of Rocky Mountain's intent to engage in settlement
discussions. The Company stated that the intent of the
setLlement would be to reach agreemenL on Lerms that would
allow the Company t.o avoid a general rat,e case filing in
CASE NO. PAC-E-13-04
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2013 and extend the existing rate plan for an addit.ional
period of time.
O. How did the case proceed?
A. The Commission opened t,he case and set an
intervention deadline. Six part.ies inLervened including the
Idaho Conservation League (ICL), t.he Snake River Alliance
(SRA), Lhe Consumer Action Partnership Association of Idaho
(Caeatl, the Idaho Irrigation Pumpers Association (IIPA),
Monsanto and PaciflCorp's Idaho Industrial Customers (PIIC) .
Settlement workshops were held on April a9, 201-3
and May 2, 2013, where all parties participated. Rocky
Mountain Power (RMP) made its initial proposal and
negotiations ensued. Apart from t.he issues specifically
identified in the Settl-ement Stipulation, other issues
discussed included the ratemaking process, the perceived
lack of information or evj-dence that justified provisions of
the Sett.lement, rate design, cost of service and Monsanto
contract provisions.
After review of the general Staff audit and
lengthy discussion of alternatives, all parties except CAPAI
agreed to settlement Lerms and signed the Stipulat.ion.
Rocky Mountain submitt.ed the document for Commission
approval on June 3, 2013.
Staff Evaluation
O. How did St.aff evaluate the Stipulation t.o
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det,ermine that the terms were reasonable?
A. Staff began its evaluation by reviewj-ng the terms
proposed in the Stipulation. Wit.h few exceptions, the
expenses proposed for recovery in rates were eit.her already
approved by the Commj-ssion for future rate recovery or were
dependent upon Commission determinat.ion in an existing case.
For example, the proposed base rate increase of
approximately $2 million (0.77*) represents the revenue
requirement for the 272 of the Populus t,o Terminal
transmission line approved for rate recovery by the
Commj-ssion in Order No. 32432. The St.ipulation also
specifies that Rocky Mountain wil-I be aLlowed to defer as a
regulatory asset t,he difference between current depreciat.ion
expenses and new depreciation expenses approved by the
Commission in Case No. PAC-E-13-02. The deferred balance,
reflect.ing either an increase or decrease in expenses will
be amortized in the next, general rate case.
Fina11y, the Stipulation specifies accounting and
ratemaking treatment for the Carbon coal plant removal cosLs
based prj-marj-Iy on prevj-ous or expected Commission Orders.
The Commj-ssion already approved Carbon removal cost deferral
in Order No. 32701- and will specify the appropriate
projected removal cost and associated depreciation expense
in Case No. PAC-E-13-02.
These are all issues that have been or will be
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decided by the Commission with respect to rate recovery in
the next general rate case regardless of the outcome in t.his
case.
a. What issues have not and will not be addressed by
the Commission prior to the conclusion of this case?
A. Treatment of costs associ-ated with the Lake Side
II Combined Cycle gas plant currently under construction has
not been addressed by the Commissj-on. It is unlikely cost,
recovery of the ptant would be fu1Iy addressed by the
Commissj-on before its scheduled online date of June 1, 20]-4.
However, the Stipulatj-on specifies that costs and
benefits of the plant will be tracked through t.he ECAM
starting ,January 1, 201,5. Alt.hough the Stipulation
specifies that project, costs would be included in the ECAM
out.side of a general rate case, costs would not be included
for t.he first six months of project operation while t.he
benefits would automatically fl-ow through t.he ECAM on the
first day of project operation.
O. What is t.he impact. on customers of including Lake
Side II in the ECAM?
A. The actual benefits derived from Lake Side If are
difficult to quantify because they will depend upon t.he
price of nat.ural gas as compared to the operating cost of
ot.her generation resources. The more Lake Side II operates
economj-cally, the more benefits will aut.omatically flow
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through the ECAM in the form of lower operating costs.
CusLomers will receive these benefits without j-ncurring any
project capital costs for six months.
Starting 'January 1, 2015, annual capital revenue
requirement not to exceed $5.43 million will be added to the
ECAM for recovery from Idaho cusLomers. This will allow an
equitable tracking of project benefits and costs until- Lake
Side fI is permanently placed in base rates. ECAM rates
reflect,ing Lake Side II capital costs will not be effective
until April L, 201-6.
O. Will the Commission have an opportunity to review
actual- project costs for prudency?
A. Yes. A fuII review of project costs and
justification for the generating plant will be conducted as
part of the Company's next general rate case. Up to a year
of act,ual plant operation wiLl also be available to assess
the value of the plant to Idaho customers. Any subsequent
adjustment. in cost recovery can be included as an offset to
costs previously tracked through the ECAM.
O. What is the effect. of changes to ECAM cost
allocation methodology?
A. The changes result in a slight shift. of ECAM cost
responsi-bility from Monsanto and Agrium to other customer
classes. The modification results in an approximate $90,000
shift in the last six months of 20L3 but becomes a non issue
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when the ECAM deferral is calculated on a total Idaho basis
on December 7-, 20L3. The parties agreed that the temporary
cost shift was equitable given reduced line losses
experienced by these transmission service 1eve1 customers.
O. Why did the Staff support changes to the
Monsanto/nocky Mountain Power Electric Service Agreement?
A. This St.ipulation term resolves a long-st.anding
dispute between the Company and Monsanto regarding the
annual true-up of t.he interruptible credit and does not
impact any other customer class. Consequently, all parties
support resolution of this issue.
O. What other cost recovery issues are specified by
the Stipulation?
A. The only other issues specified in the Stipulation
include the stay-out provisions that prohibit the Company
from filing a general rate case prior to May 31-, 201-5 or
increasing base rates prior to ,January 1, 2016, and how the
0.77e" increase will be applied to existing customer rates.
Staff maintains that the stay-out provision
prohibit.ing further base rate increases is clearly in the
best interest of customers and that a smal1 uniform increase
in revenue requirement limits t,he impact on all Company
customers.
O. Has the Company made 201,3 rate filings in other
state jurisdictions?
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A. Yes, the Company has pending rate cases in Oregon
and Washington requesting increases of 4.62 and 14.1?
respectively.
O. Did Staff conduct. an audit of Company results of
operations to determj-ne if settlement was a reasonable
alternative to a general rate case in Idaho?
A. Yes. Staff spent two days at Company headquarters
and multiple days in Boise reviewing results of operations
for the twelve months ended December 20L2. Potential-
proforma adjustments were afso eval-uated. Staff audited
t,he results of operations and records to determine
reasonableness, identify potential issues and eval-uate the
magnitude of potential adjustments. The results of
operations indicat,e the Company was preparing t.he General
Rate Case with an Idaho revenue requj-rement increase that
could be greater than $15 Mill-ion. General- rate case j-ssues
and potential adjustments identified by Staff include the
following: plant in service changes, depreciation and
amortization expenses, property taxes, net power supply
costs, labor increases, pension costs, outsJ-de services,
injuries and damages, operation and mainLenance expenses,
income t.axes with the impact from bonus depreciat.ion,
memberships, subscriptions, donations, SO2 emj-ssion
all-owance sa1es, allocation of renewable energy credits
(REC) and the sale of RECs.
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Based on its audit, Staff determined that even with
typical rate case adjustments similar to the Staff position
in the last few cases, the result,ing Idaho revenue
requirement would be greater t.han the approximate i2 Million
(0.772) increase proposed in the settlement discussions to
be effective January 1, 201"4. Staff also verified the
revenue requirement associated with the inclusion of the
remainj-ng 27t of the Populus to Terminal transmission line
investment and evaluated the ECAM adder associated with Lake
Side II.
General Concerns
O. Do you have any concerns about accept,ing a
stipulated base raLe increase without a general rate case
filing from the Company?
A. The lack of a Company filing that proposes and
justifies an increase in rates is certainly a considerat.ion
in deciding whether to accept the Stipulated Settlement. A
formal rate case filing can be more transparent and provide
more time to address a broader range of issues. Staff
ultimat.ely determined t.hat while a more formal filing could
have provided more informat.ion upfront for parties to
evaluate, it like1y would have included a proposal and
justification for a much larger increase. The tradeoff in
this case is to forgo t,he traditional rate filing as a
condition for obtaining a limited increase with rate
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stability over time.
The fact that a t,raditional filing has not been
made has not prevented the St.aff from auditing and
evaluating justification for t.he increase. As previously
indicated, t.he impact of the Settlement is quite limited
with straight forward justification. Staff believes that
other settlement, terms are similarly straight forward, have
l-imited or no impact through the rate plan period and woul-d
1ike1y be justified through the t.radit.ional- rate filing
process anyway.
Fina11y, Staff sees value for both the Company and
its rat,epayers in avoiding costly rate proceedings if
reasonable alternatj-ves are available. Ultimately, Staff
believes that the process and the associated settlement
results is a better deal for all customers in this case.
O. Do you have any concerns that important. j-ssues
such as class cosL of service and rat,e design are not,
addressed in this case?
A. I have some concern that. cost all-ocation among the
classes can become less accurate over time. Lj-kewj-se,
conditions can change that justify a fresh l-ook at, rate
structure. However, these issues were considered and
addressed in the last general raLe case, Case No.
PAC-E-L1--L2. In that case, the Company-proposed class cost
of service study was used as the basis for making a 50? move
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toward cost of service over the two-year raLe period (20L2-
2013) . Rate sLrucLure was also modified to move demand
charges closer to cost of service while uniformly increasing
energy charges and maintaining customer charges at current
Levels.
Staff does not believe that conditions have
changed enough since Lhe last. rate case to require
modif ication in t.his case in t.hese areas. This is
particularly Lrue when addressing these issues could mean
rejecting a favorable rate set.t,Iement, or causing significant
rate impacts for a select group of customers when 1itt1e
impact occurs as a result of the Settlement. Consequent1Y,
Staff supports a uniform revenue requirement increase for
all cusLomer classes and a uniform increase in only the
energy component of rates.
Summary
O. Could you please summarize Staff 's view of t.he
rate case process and resulting Settlement?
A. Yes. Given the relatively sma1l size of the rate
increase and limited nature of Settlement terms, Staff
maintains t.hat the process used 1n this case is a reasonable
alt.ernative to a traditional rate case filing. The terms of
the Settlement, have limit.ed rat.e impact and primarily
address cost recovery for items previously approved or will
be decided by t.he Commission j-n separate proceedings. The
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agreement provides rate stabllity through January of 201-5
and was signed by all parti-es to the case except CAPAI.
Staff believes the Settlement Stipulation is in the public
j-nterest and should be approved by the Commission.
O. Does that conclude your testimony?
A. Yes it does.
cAsE NO. PAC-E-L3-04
8/t6/L3
LOBB, R. (STrP) 1-4
STAFF
Mark C. Moench (ISB# 8942)
Daniel E. Solander (ISB# 8931)
201 South Main Street, Suite 2300
salt Lake city, Utah 841 l l
Telephone: [phone] I 4
Facsimile: [phone]
Daniel. sol ander@Dacifi cor!.com
Mark.moench@pacifi corp.com
Attorneys for Roclcy Mountain Power
IN TIIE MATTER OF TIIE APPLICATION
OF PACIFICORP DBA ROCKY
MOUNTAIN POWER TO INITIATE
DISCUSSIONS WTTH INTERESTED
PARTIES ON ALTERNATryE RATE
PROPOSALS
STIPULATION (PAC-E-13-04) - Page I
BEFORE TIIE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. PAC.E-l3-O{
STIPULATION
This Stipulation ("Stipulation') is entered into by and among Rocky Mountain Power, a
division of PacifiCorp ("Rocky Mountain Power" or the "Company''); Stafffor the Idaho Public
Utilities Commission ("Staff'); Monsanto Company ("Monsanto"); PacifiCorp Idaho lndustrial
Customers ("P[C"); the Snake River Alliance ("SRA"); Idaho lrrigation Pumper Association
("IIPA'); and ldaho Conservation League. Tho Community Action Partrership Association of
Idaho ("CAPAI") is an optional signatory. The parties above, including CAPAI if a signatory,
are collectively the "Parties".
I. INTRODUCTION
l. The terms and conditions of this Stipulation are set forth herein. The Parties
agree that this Stipulation represents a fair, just and reasonable compromise of the issues raised
in this proceeding and that this Stipulation is in the public interest. The Parties recommend that
Exhibit No. 101
Case No. PAC-E-13-4
R. Lobb, Staff
8116113 Page 1 of 21
the Idalro Public Utilities Commission ("Commission') approve the Stipulation and all of its
terms and conditions. See IDAPA 3 I .0 I .0 1 .27 l, 27 2, and 27 4.
II. BACKGROUNI)
2. The following Stipulation represents an agreement between the Parties on a new
two year rate plan.
3. On March l, 2013, Rocky Mountain Power filed a Notice of Intent to file a
general rate case, and an Application requesting the Commission provide notice to parties
interested in entering into rate plan settlernent discussions.
4. With a view toward resolving the iszues raised in Rocky Mountain Power's
Application in this proceeding representatives of the Parties met on April 19, 2013, andMay 2,
2013, pnrsuant to IDAPA 31.01.01.271 and272, to engage in settlernent discussions.
5. Based upon the settlernent discussions between the Parties, as I compromise of
the positions in this proceeding and for other consideration as set forth below, the Parties
stipulate and agree as follows, subject to the approval by the Commission of the terms and
conditions of this Stipulation as described below.
III. TERMS OF TIIE STIPULATION
BASE RATES
6. The Parties agree that the Stipulation is submitted to the Comrnission in lieu of a
gareral rate case and, upon approval by the Commission, the Parties agree Rocky Mountain
Power will not file any request with the Commission to increase its base rates in ldaho before
May 3 1 , 2A15, with new rates not effective prior to January I , 2016, with the difference in timing
Exhibit No. 101
Case No. PAC-E-13-4
R. Lobb, Staff
8116113 Page2 of 2l
STIPULATION (PAC-E-l 3-04) - Page 2
taking into consideration the Commission's normal notice and suspension periods for a general
rate case.
7. The Parties agree that base revenue requirernent for all schedules will be
increased by the uniform p€rcentage amount of 0.77o/o. The Parties further agree that within
each schedule the insrease will be recovered by increasing only energy rates by a uniform
percantage amount. These calculations will use 2012 normalized billing determinants and the
rates will be effective January 1,2014. The rates are shown on Attachment I .
8. These rates allow recovery of the 27% of the Populus to Terminel tansmission
line investrnent that was deemed plant held for future use in Order No. 32196. Commission
Order No.32432 determined that this investnent is now used and useful and shall be included in
rates on or after January 1,2014. The base rate increase is designed to collect approximately
$2.0 million annually from ldaho customers and is calculated as set forttr in the table below.
Revenue Reouirement Comnonents 2013
Plant in Service
Plant in Service $
218,512,895
13,225,475
Average Accum Depr Reserve
N* Plant in Service
Pre-Tax Rehrrn
Revenue Requireme,nt on Plant
De,preciation Expense
1,443,113
268,477
303,551
2,015,140
Amortization of Deferred Depreciation
Revenue Requirement S
Uniform Percentage lncrease
Deferred Depreciation Expense
ECAM
Exhibit No. 101
Case No. PAC-E-13-4
R. Lobb, Staff
8116113 Page 3 of 21
STIPULATION (PAC-E-I3-M) - Page 3
9. The Parties agree to the inclusion of and paylng for a resource adder for the Lake
Side II generation facility that will be recovered through the ECAM at 100%, for the period that
the investment in the facility is not reflected in rates as a component of rate base, beginning
January 1,2015, subject to the Lake Side II generation facility having achieved commercial
operation as of that date. The ECAM defenal will be determined by multiplying the actual
megawatt-hours of generation from the Lake Side II generation facility by $1.99 per megawatt-
hour ldatro Resource Adder as more fully set forth in the table below:
The recovery of the Lake Side II resource adder will be capped after the first 2,729,500
megawatt-hours of generation, or recovery of approximately $5.43 million from Idaho customers
through the ECAM,
Pursuant to Commission Order No.32771the Parties have agreed to modiff the ECAM
calculation by rernoving the wholesale sales line loss adjustnent from Monsanto and Agrium's
actual load used to calculate all deferral balances except for the Load Change Adjustnent
Exhibit No. 101
Case No. PAC-E-13-4
R. Lobb, Staff
8116113 Page 4 of 21
Rocky Mountain Pourcr
Lake Side II Resource Adder
In Service: June 2014
ic Plant In-Servicc 661,7?5,143
Deprcciation Expense 21,373,722 21,373,722
o&M 3,934,000 3,934,000
Propcny Taxcs 6,000,000 6,000,000
AccumDapreciation {21,373,n2)
DIT Balance (115J66,R2)
Net Plant In-Service 5U,98/.,689 58A71267
I"ake Sidc ll 8g,nl,gf!g 6.0525% $ 5,433,873
. 2,729540 . 2,729
$ 32.89 6,0525% $ 1.99
STIPULATION (PAC-E-I3-04) - Page 4
Revenue (LCAR) portion of the ECAM deferral. This change will be effective for the ECAM
deferral period starting June 1,2013 and ending on Novernber 30, 2013. t
Effective December 1,2013, the ECAM deferral will be calculated on a total Idaho basis;
Monsanto and Agrium's share will not be calculated and deferred separately. The rates will be
designed based on energy sales data. Specifically, as in past ECAMs, the proposed rates will be
calculated by effectively dividing the total target amount for Idaho customers by the energy sales
data at their appropriate delivery voltage levels.
DEPRECIATION STUDY AND CARBON PLAI\IT
10. The Parties request Commission approval of the proposed accounting treatnent
for the Company to establish a regulatory asset that would allow the Company to defer, on a
monthly basis, ary aryegate net increase or decrease in Idaho allocated depreciation expense for
the period beginning on the latter of January 1,2014, or the effective date in the Commission
Order approving new depreciation rates, until the date that new depreciation rates are reflected in
customer rates.
I 1. The Parties aglee that the Company will be allowed to recover or be required to
refund the deferred depreciation expense beginning on the effective date of the next general rate
case. The balance shall be amortized over a period not to exceed 10 years from the effective date
of the next rate case. The Parties agree that depreciation of the Carbon Plant should not be
included in this deferral.
12. Commission Order No. 32701 authorized the Company to create a regulatory
asset to transfer the remaining Carbon Plant balances upon retirernent fiom electric plant in
I Accordingly, the deferral period for the ECAJT,I application to be filed Febnrary l,2}l4,will reflect two
different allocation methodologies. The crursnl allocation methodology will b€ used for the December 1,2A12,
throughMay3l,20l3period. Theproposedallocationwillbeusedfor&cJunel,20l3,throughNovember30,
2013 period.
Exhibit No. 101
Case No. PAC-E-13-4
R. Lobb, Staff
8116113 Page 5 of 2l
STIPULATION (PAC-E-I3-04) - Page 5
service and accumulated depreciation to be amortized from the date of hansfer to the regulatory
assets through December 31,202A. The regulatory asset as of the date of transfer will include
the un-depreciated book balance assuming that existing depreciation rates were used prior to the
plant retirement date. The difference between the depreciation rate effective in 2014 and the
current depreciation rate based on the prior decommissioning date of 2A20 will be included in the
Remaining Carbon Balances regulatory asset until Carbon depreciation rates are updated in the
next general rate case.
13. The Parties agree to the creation of a regulatory asset for futr"rre recovery from
Idaho ratepayers of Idaho's allocated share of the prudently incuned Carbon Removal
Costs. The projectd removal costs were identified in the calculation of the new depreciation
expense as part of Case PAC-E-13-02, which is subject to Commission review and approval.
14. The Parties agree that the Company shall be allowed to recover from customers
ldaho's share of the prudently incurred Carbon Removal Costs over a reasonable period
determined by the Commission in a futtre proceeding. The amortization of the Carbon removal
costs will begrn when the amortization expense is included in rates in the next general rate case.
MONSANTO CONTRACT
15. The Parties agree Monsanto's existing Electric Seryice Agreement (the
'*Contract") which currently expires December 31,2013, shall be amended as follows:
1. A new Section 4.4 shall be added and read as follows:
4,4 Interruptible Credit Annual True-up: Beginning January 1,2014, in the
event Measured Demand in any billing period in any Calendar Year is less than
162 megawatts, the fbllowing calculation shall occur and shall be reflected on the
Billing Period immediately following the Calendar Year in question:
4.4.1 If the average of the 12 months of Measured Dernands for the Calendar
Year in question is equal to or greater than 171 megawatts (the sum of 9
megawatts and 162 megawatts), a credit will be provided to Monsanto to
Exhibit No. 101
Case No. PAC-E-13-4
R. Lobb, Staff
8116113 Page 6 of 2l
STIPULATION (PAC-E-I3-04) - Page 6
reflect the difference between a total Intemrptible Credit amount based on 162
megawatts of Measured Demand for each Billing Period in the Calendar Year
in question and the actual total Intemrptible Credit amount paid in the
Calendar Year in question. A $50,000 credit shall be added to the true-up in
2014 andZAl5.
4.4.2 If the average of the 12 months of Measured Demands for the Calendar
Year in question is less than 171 megawatts (the sum of 9 megawatts and 162
megawatts), then no adjustmart shall be made, except for the credit of
$50,000 referenced in 4.4.1.
4.4.3 This section 4.4 is intended to reflect a compromise of positions by
Monsanto and Rocky Mountain Power and will not be deemed to set any
precedent or interpretation that is counter to the Commission Order Nos.
32424 and 32432.
2. Monsanto waives any rights to claim any true-up of Interruptible Credit for any
billing periods prior to January l, 2074, for months in which the Measured
Dernand was below 162 megawatts.
3. The Company and Monsanto shall enter into a new Electric Service Agreement
effective January 1,2014, with an initial term through December 31, 2015. The
new Electric Service Agreernent shall be executed contemporaneously with
Monsanto and Rocky Mountain Power's execution of this Stipulation.
4. Section 4.1 of the contract will be amended to reflect the increase shown in
Attachment 1 related to Populus to Terminal Transmission line described in
Paragraph 7 above.
16. Monsanto and the Company agree to prepare and execute an Electric Service
Agreement that reflects these changes to the conhact and provide it to the Commission for
approval.
17. Monsanto and the Company will continue to work collaboratively and in good
faith to address the terms and conditions and to optimize the value of Monsanto's curtailment
Exhibit No. 101
Case No. PAC-E-13-4
R. Lobb, Staff
8l16l13 PageT of 2l
STIPULATION (PAC-E- I 3-04) - Pase 7
products to Monsanto and the Company, including a discussion of cost of ssvice methodologies
as applied to the Monsanto load and how said methodologies could be utilized in the next general
rate case. Monsanto and the Cornpany will report to the Staffand Commission as appropriate on
the progress made.
RATE DESIGN
18. If CAPAI is a signatory to the Stipulation, the Parties agree to the following: the
Parties agreo to conduct a rate design collaborative process to evaluate potential ehanges to rate
design for the Company's residential servicg Schedule l, and general service, Schedule 6 and
23. The Parties fuither agree to met within one month after the Stipulation is filed to begin the
collaborative discussions. If CAPAI is not a signatory to the Stipulatiorl the Parties agree that
this Paragraph 18 is ofno cffect and does not apply.
19.
W. GENERAL PROVISIONS
The Parties agree drat this Stipulation represents a compromise of the positions
of the Parties on all issues in this proceeding. Other than the above referenced positions and any
testimony or comments filed in support of the approval of this Stipulation, and except to the
extert necessary for a Party to explain before &e Cornmission its own statornents and positions
with respect to the Stipulation, all negotiations relating to this Stipulation shall not be admissible
as evidence in this or Bny other proceeding regarding this subject matter.
The Parties submit this Stipulation to the Commission and recommend approval
in its entirety pursuant to IDAPA 31.A1.01.274. The Parties request that the Commission notice
the filing of the Stipulation and establish a procedural schedule, including public and technical
hearings as necessary, for the review and consideration of the Stipulation by the Commission.
The Parties shall support this Stipulation before the Commi$sion, and no Party shall appeal any
Exhibit No. i01
Case No. PAC-E-13-4
R. Lobb, Staff
8116/13 Page 8 of 21
2A.
STIPULATION (PAC-E-13-04) - Page 8
portion of this Stipulation or Order approving the same. If this Stipulation is challenged by any
person not a party to the Stipulation, the Parties to this Stipulation reserve the right to cross-
examine witnesses and put on such case as they deem appropriate to respond fully to the issues
presented, including the right to raise issues that are incorporated in the settlement ernbodied in
this Stipulation. Notwithstanding this reservation of rights, the Parties to this Stipulation agree
that they will continue to zupport the Commission's adoption of the terms of this Stipulation.
21. In the event the Commission rejects or modifies any part or all of this
Stipulation, or imposes any additional material conditions on approval of this Stipulation, each
Party reserves the right, upon written notice to the Commission and the other Parties to this
proceeding, within l5 days of the date of such action by the Commission, to withdraw from this
Stipulation. In such case, no Party shall be bound or prejudiced by the terms of this Stipulation,
and each Party shall be entitled to seek reconsideration of the Commission's order, file testimony
as it chooses, cross-examine witnesses, and do all other things nocessary to put on such case as it
deerns appropriate.
22. The Parties agree that this Stipulation is in the public interest and that all of is
terms and conditions are fair, just and reasonable.
23, No Party shall be bound, benefited or prejudiced by any position asserted in the
negotiation of this Stipulation, except to the extent expressly stated herein, nor shall this
Stipulation be constnred as a waiver of the rights of any Party unless such rights are expressly
waived herein. Execution of this Stipulation shall not be deemed to constitute an
acknowledgment by any Party of the validity or invalidity of any particular method, theory or
principle of regulation or cost recovery. No Party shall be deelned to have agreed that any
method, theory or principle of regulation or cost recovery onployed in arriving at this Stipulation
Exhibit No. 101
Case No. PAC-E-13-4
R. Lobb, Staff
8116113 Page 9 of 2l
STIPULATION (PAC-E-I3-04) - Page 9
is appropriate for resolving any issues in any other proceeding in the future. No findings of fact
or conclusions of law other than those stated herein shall be deerned to be implicit in this
Stipulation.
24. The obligations of the Parties under this Stipulation are subject to the
Commission's approval of this Stipulation in accordance with its terms and conditions and, if
judicial review is sought, upon such approval being upheld on appeal by a court ofcompetent
jurisdiction.
Id
Br
Pacifi Corp ldaho Indusfidal Customers
By ,,?il-/ruw
Exhibit No. 101
Case No. PAC-E-13-4
R. Lobb, Staff
8116113 Page l0 of 21
Respecttully submitted trris ZSay ot 4,2013,
Rocky Mountain Power Monsanto Company
ldaho Public Utilities Commission Staff Snake River Alliance
By By
aho Conservation League Idaho Irrigation Pumper Association
By
Community
Association
Action Partnership
ofldaho
STIPULATION (PAC-E-I3-04) - Page 10
is apopiato br rccolving my ismco in my othor procooding in tho fitra No findiagp of fact
or ooaclusions of lew othcr tbm trosc shtd hmh Sall bc d@cd b bo implicit iu this
Stipulatioo.
24. Tbo obligrtianr of &e Partioe undec t&is Stipul*ion a€ subjcct to thc
Cotrmission's a1ryrcval of this Stipulatioo in acoorduoc with ib tcros aod coaditionc d, if
judicial rwiw is sougbt, upon ruch approval bt*ng uphcld on appal by a court of compctcot
jruidiction"
Rcspcctfuuy srrbmitod tbi, gC6y orfi;- zott.
ByBy
Idr[o hhllc Ufflldq Qemrnk;flea $61fr SnrkeRfuer Alltance
Idaho Cmrcrrndon Lorguc Idaho Irlgrdon Pumpcr Arocir0on
By By.
Community Action Prrtncrrhlp
Arocldoo of ldrho
PrffiCorp tdrho ltr&rHd Curtomorr
Bv Bv
Exhibit No. 101
Case No. PAC-E-13-4
R. Lobb, Staff
8116113 Page I I of 21
STIPULATION (PAC-E-I 3-04) - Pago 10
is appropriatc for rcoolviag aayissucc in any otherprocooding in &t fttm. No findiqgs of frtt
6 coDclusionr of law othcr than thosG statod hcrcitr sball bc dcald to bc implicit in tlis
Sdpulatioo.
U. Ttc ob[g$iou of the Parties rmder ftis Stiprldion ue subjd to thc
Commission'e appmrnal of Stis Stipuladion in aaoordmco wi& i6 hrmo rd oonditioos ed, if
judidal rwiew ir rougfo! upon such ryprowl bohg ryhcld oo appoal by a oourt of oompetcnrt
juri*lictioo.
Rccpcdfirnya*mittodeis
-dayof
. 2013.
RoclryMounlrh Poffcr MourrntoCorpmy
Snekc RlvcrAlttrnca
Idrho Conrennffon Lcrgue Idaho lrrtgafiol Pumper Arroclaffou
By.By.
Idilo hbllc Ufflldcr Covrmllrlol Strfi
By
Communtty Acdon Prrlnemlo$
Anodrdon of Idrho
PaclfrCorp ldrho Indurtrld C'ustomcrr
By By.
Exhibit No. 101
Case No. PAC-E-13-4
R. Lobb, Staff
8116113 Page 12 of 27
STIPUI-ATION (PAGel 3.(}{) - Pagle 10
io rygropdrte for rwlving my irmco in aay other pooorliug in &o fukrq No Mingt of fact
sr oonclwioaa of law o(ha th*n tbooo gtaod hffiin afirll $s demod to bo inptioit io thir
Stipldion.
24. lbo oblig$ions of &e Prtic rder this Stiprlmion are eubjcct to 6o
kigsioo's qlprcval of &ic Sdpulatioo in acoordanco with i8 kms ond omditiong d, if
judidd rwiow ir mrrght rpn mch approrml b6ing uphdd or ryoal by a eourt of cupctcnt
jurididim. r
ncepeanruy arbritcd *fu u* * flqfizon.
Rocl{f Momtain Powsr MouraabCompeny
By By
Idrto PubltcUdltder Comnirfou Sffi $ueloRiwr Alllance
Idrho Cmondo Loegrc fdrho Irrigrflm Punpcr Ardfun
PeclfiCorp ldaho In&sdd Curtomcn
By.By.
"rff * By
Connunlty
Arrod&n
Acdon krtranhip
ofldrho
Exhibit No. 101
Case No. PAC-E-13-4
R. Lobb, Staff
8116113 Page 13 of 2l
STIPULATION (PAC-E-l 3-04) - Pagt 10
is appropriate for resolving sny issuos in any othor proceeding in the ftture. No finding of fact
or conclusions of law othcr than thoss stated herein shall be deemed to bc implicit in this
Stipulation.
24, The obligations of thc Partios undar this Stipulation are subjcot to the
Commiesion's approvat of this Stipulation in accordanco with its terms and conditions and, if
judicial roview is sought, upon such appmval being upheld on appeal by a court of compotmt
jurisdiaion.
'2'l)r, oth.rorr.Rcspcctfully zubmittod thisi_da1 _17.
RockyMountaln Power Monrauto Company
Idaho Publtc Uttlltler Commlsrion Staff Snske Rlyer Allisnce
Idaho Concervadon Lergue Idrho Irrlgrdon Pumper Arsoclatlon
By,By.
Communlty Acdon Partnerehlp
Asroclatlon of Idrho
PaclflCorp ldrho Industrlal Customers
By By
Exhibit No. 101
Case No. PAC-E-13-4
R. Lobb, Staff
8116113 Page 14 of 21
STIPULATION (PAC-E-! 3-04) - Page l0
is appropriate for resolving any issuee in any other procdiug in &e future. No finilirrgs of fa*
or ooaolusione of law other than those stated hrnein shall be deemrsd to be implicit in this
Stipulation.
24.The obligations of the Parties under this Stipulation are zubject to the
Camnrission's approval of this Stiptlation in accordanco \vittl its tqms qnd conditioms ard, if
judicial review is sought, upon such approval bcirrg upbold on appei by a murt of compotslt
jurisdiction.
Respcctftlly submittcd this _ day of .2013.
RockyMountain Power MormantoCompeny
Idaho Publlc Udllder Comulegi,on Sfrff Snrkr Rlver Allhnce
By.
PaclffCorp ldaho Industrlrt Curtomerc
Idcko Concervaffm Lcrgue
By
Commnnlty
Arloclrtion
Acfion Prrhershlp
ofldeho
ByBy
Exhibit No. 101
Case No. PAC-E-13-4
R. Lobb, Staff
8116113 Page 15 of 2l
STIPULATION (PAC-E-l3+l) -Page 10
Attachment I
Settlement Rate Spread
& Rate Design
Exhibit No. 101
Case No. PAC-E-13-4
R. Lobb, Staff
8116113 Page 16 of 2l
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Exhibit No. 101
Case No. PAC-E-13-4
R. Lobb, Staff
8116113 Page 17 of 2l
a!
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Attachment I - Settlement Rates
ROCKY I'OUNTAIN POWER . STATE OF IDAHO
cAsE NO. PAC-E-I3-04
Present
Price
Settlement
Price
utDot4
SCHEDULE NO. I - Residential Service
Customer Charge
All kwh (May - Oct)
<= 700 kWh
> 700 kwh
All kV/h (Nov - Apr)
<= 1,000 kWh
> I,000 kwh
Seasonal Service Charge
SCHEDULE NO.36 - ResidentialService Optional TOD
Customer Charge
On-Peak kWh (May - Oct)
Off-Peak kWh (May - Oct)
On-Peak kWh (Nov - Apr)
Off-Peak kWh (Nov - Apr)
Seasonal Service Charge
SCHEDULE NO.6/6A - General Service - Large Power
Customer Charge (Secondary Voltage)
Customer Charge (Primarl' Voltage)
All kW (May - Oct)
All kW (Nov - Apr)
Allkwh
Seasonal Service Charge (Secondary)
Seasonal Service Charge (Primary)
Voltage Discount
SCHEDULE NO. 7 - Customer Owned Light
Residential
Charges Per Lamp
I6,000 Lumens, HPSV
SCHEDULE NO. 7/7A - Security Area Lighting
Charges Per Lamp
7000 Lumens, MV
20,000 Lumens, MV
5,600 Lumens, HPSV, Co Owned Pole
5,600 Lumens, HPSV, No Co Owned Pole
9,500 Lumens, HPSV, Co Owned Pole
9,500 l.umens, HPSV, No Co Owned Pole
16,000 Lumens, HPSV, Co Owned Pole
16,000 Lumens, HPSV, No Co Owned Pole
27,5A0 Lumens, HPSV, Co Owned Pole
$s.00
10.7874
14.5630
8.2571
|.1472
s60.00
s r 4.00
14.4027 A
4.9t48 t,
12.3029 (
4.4e82 g
s 168.00
$37.00
$111.00
s14.36
$il.8 r
3.6696 A
$444.00
$ I,332,00
($0.6s)
$5.00
10.8759
t4.6825
8.3249
r 1.2386
$60.00
(
(
$14.00
14.s265 (
4.957t (
12.4087 i
4.5369 (
s r 68.00
$37.00
sr I1.00
$ 14.36
sil.81
3.7293 i,
s444.00
s I,332.00
($0.6s)
s r 5.03
o
(
(
(
(
(
$ r 4.91
$26.83
$47.86
$r 7.04
$ r3.56
$r9.sr
$ r6.02
$25.70
s22.88
s36.97
Exhibit No. 101
Case No. PAC-E-I3-4
R. Lobb, Staff
8116113 Page 18 of 21
$27.04
$48.23
$17.r7
$ r3.67
$ 19.66
sr6.r5
$25.90
$23.06
s37.26
Page 2 of 5
Attachment I - Settlement Rates
ROCKY MOUNTAIN POWER . STATE OF IDAHO
cAsE NO. PAC-E-13-04
Present
Price
Settlement
Price
Uu20t4
27,500 Lumens, HPSV. No Co Owned Pole
50,000 Lumens, HPSV, Co Owned Pole
50,000 Lumens, HPSV, No Co Owned Pole
16,000 Lumens, HPS Flood, Co Owned Pole
16,000 Lumens, HPS Flood, No Co Owned Pole
27,500 Lumens, HPS Flood, Co Owned Pole
27,500 Lumens, HPS Flood, No Co Owned Pole
50,000 Lumens, HPS Flood, Co Owned Pole
50,000 Lumens, HPS Flood, No Co Owned Pole
8,000 Lumens, LPSV, Energy Only
13.500 Lumens, LPSV. Energy Only
22,500 Lumens, LPSV, Energy Only
33,000 Lumens, LPSV, Energy Only
SCHEDULE NO.9 - GeneralService - High Voltage
Customer Charge
AllkW (May - Oct)
AllkW Qllov - Apr)
Minimum kW Summer
Minimum kW Winter
Allkwh
SCHEDULE NO. l0 - Irrigation
Small Customer Charge (Season)
Large Customer Charge (Season)
Post-Season Customer Charge
All kW (June I - Sept l5)
First 25.000 kWh (June I - Sept l5)
Next 225,000 kWh (June I - Sept l5)
Atl Add'l kWh (June I - Sept l5)
AII kwh (Sept l6 - May 3l)
SCHEDULE NO. I I - Company-Owned Street Lighting Service
Charges per Lamp
5.800 Lumens, High Intensiry Discharge
9,500 Lumens, High lntensiry Discharge
16,000 Lumens, High lntensity Discharge
27,500 Lumens, High Intensity Discharge
50,000 Lumens, High lntensity Discharge
9,500 Lumens, High lntensity Discharge - Series l
16,000 Lumens, High Intensity Discharge - Series I
9,500 Lumens, High Intensity Discharge - Series 2
16,000 [-umens, High Intensity Discharge - Series 2
12,000 Metal Halide
sls.r4 $15.26sr8,89 s19.04$2s.7s $2s.95s3s.96 $36.24$52.79 $53.20
$3 r.2s $3 I .49$34.29 534.56
$25.7 t $25.91$28.68 $28.90$27.88 $28.10
Exhibit No. 101
Case No. PAC-E-13-4
R, Lobb, Staff
8116113 Page 19 of 2l
$33.48
$5 r .67
$15.74
$2s.70
$22.88
$36.97
$33.48
$s 1.67
$45.74
$3.66
s5.41
s'7.52
$9,1 5
$370.00
$ t 0.26
$7.74
$ r 0.26
$7.74
3.883s r
s r 4.00
$4 r.00
s23.00
$5.98
8.s312 (
6,3103 g
4,6577 (
1.2164 (,
s33.74
s52.07
s46. I 0
$25,90
$23.06
$37.26
s33.74
s52.07
s46. r 0
$3.69
$s.45
s7,58
qo ,?
$370.00
$ r0.26
$7.14
s r 0.26
$7.74
3.9283 (
s r 4.00
s4l .00
$23.00
s5.98
8.6 r06 I
6.3691 0
4.70n t,
7.2836 f,
Page 3 of 5
Attachment I - Settlement Rates
ROCKY II'IOUNTAIN POWER. STATE OF IDAHO
cAsE NO. PAC-E-13-04
Present
Price
Settlement
Price
utnol4
19,500 MetalHalide
32.000 Metal Halide
9,000 Metal Halide - Series I
12,000 Metal Halide - Series I
9,000 Metal Halide - Series 2
12,000 Metal Halide - Series 2
$34.60
$41.97
$3 r.s2
s36.24
$30.67
s32.38
$34.87
$42.30
$31.77
$36.52
$30.91
$32.63
SCHEDULE NO. 12E - Customer-Owned Street Lighting Service'Energy Only
Charges per Lamp
33,000 Lumens, LPSV $9.16
12,000 MetalHalide $7.05
19,500 MetalHalide $9.65
32,000 Metalllalide $15.17
107,800 Metal Halide $36.32
9,000 Metal Halide S4.01
5,800 Lumens, HPSV $2.84
9,500 Lumens, HPSV $3.97
16,000 Lumens, HPSV $5.91
27,500 Lumens, HPSV $10.10
50,000 Lumens, HPSV $15.52
Non-Listed Luminaire - Enerry Only 10.2944 i,
SCHEDULE NO. l2F - Customer-Owned Street Lighting Service-Full Maintenance
Charges per Lamp
5,800 Lumens, HPSV $6.56
9,500 Lumens, HPSV $8.36
16,000 Lumens, HPSV $10.04
2'7,500 Lumens, HPSV $13.16
50,000 Lumens, HPSV $17.55
SCHEDULE NO. I2P - Customer-Owned Street Lighting Service-Partial Maintenance
Charges per Lamp
10,000 Lumens, MV $16.42
20,000 Lumens, MV $21.98
5,800 Lumens, HPSV $5.88
9.500 Lumens, HPSV $7.57
27,500 Lumens,l{Psv $12.14
50,000 Lumens, HPSV $16.36
SCHEDULE NO. l9 - Commercial and Industrial Space Heating
Customer Charge Secondary
All kwh (May - Oct)
Allkwh (Nov - Apr)
s9.23
$7.1 0
$9.73
$r s.29
$36.60
$4.04
$2.86
s4.00
$s.96
s 10.18
$ 15.64
10.3745
$6.61
$8.43
$10.r2
$ 13.26
$r 7.69
$16.55
s22. l 5
$s.93
$7.63
$t2.23
$ 16.49
$23.00
9.39t6 F
6.9s89 i
s23.00
9.3152 (
6,94n g
Exhibit No. 101
Case No. PAC-E-13-4
R. Lobb, Staff
8116113 Pase 20 of 21
Page 4 of 5
Attachment 1 - Settlement Rstes
ROCKY MOUNTAIN POWER . STATE OF IDAHO
cAsE NO. PAC-E-i3-04
Present
Price
Settlement
Price
ult20t4
SCHEDULE NO.23l23A - General Service
Customer Charge Secondary
Customer Charge Primary
All kwh (May - Oct)
Allkwh (Nov - Apr)
Seasonal Service Charge (Secondary)
Seasonal Service Charge (Primary)
Voltage Discount
SCHEDULE NO.35 - General Service - Optional TOD
Customer Charge Secondary
Customer Charge Primary
AllOn-Peak kW
Altkwh
Seasonal Service Charge (Secondary)
Seasonal Service Charge (Primary)
Voltage Discount
SCHEDULE 4OO
Firm Energy and Power
Customer Charges
kwh
kw
Excess kVar
lnterruptible Energy and Power
kwh
kw
SCHEDULE 4OI
Customer Charges
HLH kWh (May-October)
HLH kWh (November-April)
LLH kWh (May-October)
LLH kWh (November-April)
AllkW (May-October)
All kW (November-April)
$ r 6.00
$49.00
9.r030 d
7.9463 g
$ 192.00
$588.00
(0.43e7) i
$67.00
s 165.00
$ r 6.45
4.9015 (,
$804.00
$ 1,980.00
($0.84)
s 1,586.00
3.0870 (
s r 5.91
$0.96
3.0870 I,
s I 5.91
$442.00
3.6332 i
3.0214 (
2.7243 (
2.7243 (
$ r7.60
sr4.r9
s r6.00
$49,00
9.182s (
8.0157 p
$ 192.00
s588.00
(0.43e7) I
$67.00
$ r 6s.00
$ 16.45
4.9609 f,
$804.00
s r,980.00
($0.84)
$ r,s86,00
3,1303 I
$ ls.9l
s0.96
3.1303 0
s r s.9l
s442,00
3.6855 I
3,0649 (,
2.7635 (
2.7635 (
$ 17.60
$ r 4.19
ExhibitNo. 101
Case No. PAC-E-I3-4
R. Lobb, Staff
8116113 Page2l of 21
Page 5 of 5
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 16th DAY OF AUGUST 2013, SERVED
THE FOREGOING DIRECT TESTIMONY OF RANDY LOBB IN SUPPORT OF
STIPULATION, IN CASE NO. PAC-E-13-04, BY E-MAILING AND MAILING A COPY
THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
TED WESTON
ID REGULATORY AFFAIRS MGR
ROCKY MOUNTAIN POWER
201 S MAIN ST STE 23OO
SALT LAKE CITY UT 84I I I
E-MAIL : ted.weston@pacifi corp. com
E.MAIL ONLY:
DATA REQUEST RESPONSE CENTER
datareq uest@paci fi corp. com
BRUBAKER & ASSOCIATES
16690 SWINGLEY RIDGE RD
#t40
CHESTERFIELD MO 63017
E-MAIL: [e-mail]
ERIC L OLSEN
RACINE OLSON NYE ET AL
PO BOX 1391
POCATELLO ID 83204-1391
E-MAIL: [e-mail]
RONALD L WILLIAMS
WILLIAMS BRADBURY PC
1OI5 W HAYS STREET
BOISE ID 83702
E-MAIL : [e-mail]
E.MAIL: ONLY
TIM BULLER
PACIFICORP IDAHO INDUSTRIAL
CUSTOMERS
AGRIUM US INCAIU-WEST INDUSTRIES
E-MAIL: [e-mail]
DANIEL E SOLANDER
REGULATORY COUNSEL
ROCKY MOLTNTAIN POWER
201 S MAIN ST STE 23OO
SALT LAKE CITY UT 841I I
E-MAIL: [e-mail]
RANDALL C BUDGE
RACINE OLSON NYE ET AL
PO BOX 1391
POCATELLO ID 83204-1391
E-MAIL: [e-mail]
E.MAIL ONLY:
JAMES R SMITH
MONSANTO COMPANY
E-MAIL: [e-mail]
ANTHONY YANKEL
29814 LAKE ROAD
BAY VILLAGE OH 44140
E-MAIL: [e-mail]
DON SCHOENBECK
RCS INC
9OO WASHINGTON STREET
STE 780
VANCOUVER WA 98660
E-MAIL: [e-mail]
BRAD M PURDY
ATTORNEY AT LAW
2019 N 17TH STREET
BOISE ID 83702
E-MAIL: [e-mail]
CERTIFICATE OF SERVICE
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
710 N 6ffi sr
BOISE ID 83702
E-MAIL: [e-mail]
KEN MILLER
SNAKE RIVER ALLIANCE
BOX r73l
BOISE ID 83701
E-MAIL: [e-mail]
CERTIFICATE OF SERVICE