20160310Comments.pdf

KARL T. KLEIN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720.0074
[phone]
IDAHO BAR NO. 5156
Street Address for Express Mail:
472W, WASHINGTON
BOISE, IDAHO 83702.5918
Attorney for the Commission Staff
IN THE MATTER OF PACIFICORP DBA )
ROCKY MOUNTAIN POWER'S APPLICATION )
FOR APPROVAL OF ITS $16.7 MILLION )
DEFERRAL OF NET POWER COSTS, AND )
AUTHORTTY TO DECREASE RATES BY $9.0 )
MILLION
RECEIVED
?ii6:,ti.R I 0 PH 2: 29
', ,
"::l.i.jiSstou
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. PAC.E-16-05
COMMENTS OF THE
COMMISSION STAFF
)
)
The Staff of the Idaho Public Utilities Commission comments as follows on PacifiCorp dba
Rocky Mountain Power' s Application.
BACKGROUND
On February 1,2016, PacifiCorp dba Rocky Mountain Power applied to the Commission for
an Order authorizing the Company to adjust its rates under the Energy Cost Adjustment Mechanism
(ECAM). The ECAM allows the Company to adjust its rates each year to capture the difference
between the Company's actual power supply expenses and the power expenses already embedded in
base rates. The adjustment appears as a separate line item on customer bills that increases if power
supply costs are higher than the amount embedded in base rates, or decreases if power supply costs
are lower. The ECAM does not affect the Company's earnings.
The Commission first approved an annual ECAM in 2009, and the mechanism has been
modified several times since then. See OrderNos. 30904,32432,32910,33008, and 33440. In
summary, the ECAM allows the Company to increase or decrease rates each year to reflect changes
STAFF COMMENTS MARCH IO,2016
in the Company's power supply costs over the year. These costs vary with changes in the
Company's fuel (gas and coal) costs, surplus power sales, power purchases, and the market price of
power. Each month, the Company tracks the difference between the actual Net Power Costs (NPC)
it incurred to serve customers, and the embedded (or base) NPC it collected from customers through
base rates. The Company defers the difference between actual NPC and base NPC into a balancing
account for later disposition at the end of the yearly deferral period. At that time, the ECAM allows
the Company to credit or collect the difference between actual NPC and base NPC through a
decrease or increase in customer rates.
Besides the NPC difference, this year's ECAM components include: (1) a Load Change
Adjustment Rate (LCAR); (2) a credit for SO2 allowance sales; (3) an adjustment for load control
(DSM); (a) an adjustment for the treatment of coal stripping costs; (5) a true-up of 100% of the
incremental Renewable Energy Credit (REC) revenues; (6) Deer Creek amortization expense; (7)
Lake Side 2 generation resource adder; (8) a back cast adjustment that accounts for any over/under-
collection of NPC, LCAR, DSM costs, Deer Creek amortization expense, and REC revenues; and
(9) a "90/10 sharing band" in which customers paylreceive 90%o of the increase/decrease in the
difference between actual NPC and base NPC, LCAR, SO2 sales, DSM costs, and the coal stripping
costs, and the Company incurs/retains the remaining 10%.
OVERVIEW OF COMPANY APPLICATION
The Company's Application seeks to revise Schedule 94,Energy Cost Adjustment, to
recover about $16.9 million in total deferred NPC over the collection period from April 1,2016
through March 31,2017 . It is intended to recover total deferred net power costs of about $ 16.7
million (with interest) for the period beginning December 1,2074, and ending November 30,2075,
as illustrated by the following table:
Balances for Collections allocated bv Class
E.lancc of Prcvlous D€feml pdot lo 12,/1114
Unamorlized PrB\ious Balance
ECAM Rider R€Enues
All ldaho Cu$om€r
$ 16,393,738 S$ (11,714,98e) $$ 134,437 $
Tarlff Cudomer
1,760,965 $
(1,629,547) $
(134,437\
Sch,o0
7,949,050 $
(5,957.572) $
Tarifi Customsr mo€d to All ldaho Customet 4l'll2115
lntoEst on Debmls
2016
lnt8Est on Curent Oef€ral
s 129.351 $77'.t S
616,484
Tota I
26,720,238
(19,769,949)
'186.950
(467.U
3.809
16,629,
97 008
't76)
12.O74
16.871,223
16,629.079 $
STAFF COMMENTS
8.416 S
MARCH 10, 2016
The proposed $16.9 million recovery represents about a $9.0 million decrease in revenue, or
an overall 3.0 percent reduction in current Schedule 94 rates. Of this decrease, $7.0 million is
allocated to Monsanto, $0.5 million is allocated to Agrium, and $1.4 million is allocated to tariff
customers, for rate reductions of 7 .l percent, 7.3 percent, and 0.7 percent, respectively. The large
reductions in Monsanto and Agrium's rates are due to full amortization of deferral balances from
2012 through 2014 and elimination of associated payments in proposed rates. According to the
Company, if its Application is approved, rates will decrease for all customer classes, with an
average residential customer's bill decreasing by about $0.58 per month. A copy of Company
Exhibit No. 2--detailing the impact of the new rates for individual customer classes-appears as
Attachment A to these Comments.
The total proposed $16.7 million deferral amount consists of cost and revenue components
as illustrated in the table below:
Summary Table of 2016 ECAM Deferral
Description
NPC Differential for Deferral
Load Change Adjustment (LCAR)
s02
Load Control (DSM)
EITF 04€ Adjustment
Total
Sharing Percentage
Customer Respons ibil ity
REC Deferral
Lake Side 2 Resource Adder
Deer Creek Depreciation Expense
Back cast adjustment
2016 ECAM Deferral (without interest)
lnterest on Deferral
2016 ECAM Deferral (with interest
Dollar Amount
$ 9,269,760
(38e,
(543,
(82,474
$ I,254,213
$ 7,428,792
6,160,1 70
4,101,943
626,238
(1,688,064
$ 16,629,079
97,008
16,726,087
For the l2-month period ending November 30,2015, the NPC differential for deferral was
about $9.3 million before applying the 90o/o (customers)ll0% (Company) sharing band. The
differential roughly calculates the difference between actual NPC and base NPC. As noted earlier,
other components subject to the 90110 sharing band in this year's ECAM include: (l) a Load
Change Adjustment Rate (LCAR); (2) a credit for SO2 allowance sales; (3) an adjustment for load
control cost (DSM); and (4) an adjustment for the treatment of coal stripping costs (EITF 04-6).
STAFF COMMENTS MARCH 10, 2016
Components not subject to sharing include: (1) a true-up of incremental Renewable Energy Credit
(REC) revenues; (2) aLake Side 2 generation resource adder; and (3) Deer Creek amortization
expense. The back cast adjustment, which is an accuracy verification step ordered by the
Commission (Order No. 33008), adjusts any ECAM component that currently has cost or revenue
embedded in base rates. This adjustment reduces this year's ECAM deferral balance by about $1.7
million. A copy of Company Exhibit No. l-detailing the Company's deferral calculations-
appears as Confidential Attachment B to these Comments.
STAF'F REVIEW
Staff thoroughly reviewed the Company's Application and focused on three critical areas.
First, Staff analyzed whether the costs and revenues in the Company's NPC were reasonable during
the deferral period. Second, Staff reviewed whether the Company accurately calculated the defenal
amount, account balances, and resulting rates in compliance with past Commission orders. Finally,
Staff audited contracts, invoices, and other documents to authenticate the actual cost and revenue
reflected in the Company's defenal balance. Based on this review, Staff concluded:
l. The Company's back cast adjustment did not account for the Separation of Deer Creek
Depreciation from NPC on January 1,2015. Staff thus recommends that the Commission
decrease the Company's proposed deferral by about $51,343.
2. The Company overstates interest on the deferral amount in the balancing accounts by about
$8,019 because the Company reflected the back cast adjustment amount in the last month of
the deferral period instead of spread across the l2-month deferral period.
3. The Company did not include the tariff customer ending balance amount for March in the
interest calculation of the April All Customer Balancing Account. Although inaccurate, the
amount was immaterial.
4. There were no anomalies in the Company's actual costs, revenues, or loads.
Staff s analysis and conclusions are further explained below.
Analysis of Deferral
Audit Results
Staff thoroughly audited the Company's
Company's Portland and Salt Lake City offices.
books and performed on-site audits at the
Staff reviewed the Company's internal audit work
STAFF COMMENTS MARCH 10,2076
papers, control processes, journal entries, invoices, and contracts. Staff also reviewed the
Company's adjustments to its actual costs. Staff reconciled the general ledger amounts to the net
power costs provided in Company Exhibit No. 1. Staff reviewed the Company's hedge contracts
and policies and believes they reasonably safeguard price stability and fuel availability. In addition,
Staff reviewed the entries for the regulatory depreciation of the Deer Creek mine closure, and
believes they comply with Order No. 33304 from Case No. PAC-E-14-10. Staff believes the NPC
in Company Exhibit No. 1 is accurate and complies with ECAM policies.
Cost/Revenue Dffirences
In this year's ECAM, three components account for almost all of the Company's proposed
deferral: (1) the $6.8 million difference between actual NPC and the NPC already embedded in
base rates; (2) base rate recovery versus actual REC revenue at $6.4 million; and (3) an adder for
recovery of Lakeside 2 expense at $4.1 million.l Each component is described below.
$6.8 Million NPC Difference
Staff analyzed the Company's NPC categories as reflected in the table below. Changes in
natural gas prices had the largest impact on the NPC difference, with actual expenses being $35.58
per MWh lower than those embedded in base rates. The decrease in gas prices helped lessen the
impact of a$11.77 per MWh increase in purchased power expense, a $6.08 per MWh increase for
wheeling, hydro and other expense, and a $2.70 per MWh increase in coal expense. Staff believes
the Company made prudent tradeoffs to reduce actual NPC incurred. This is demonstrated by a 53
percent increase in the amount of actual natural gas generation when compared to the amount
assumed in the base to take advantage of lower natural gas prices and a decrease in the amount of
electricity purchases and generation in other categories that experienced higher unit price increases.
In addition, the Company saw off-system sales decrease by 48 percent as compared to the base.
Staff believes this is reasonable given the lower market prices relative to actual production costs.
I The three components total $ I 7.3 million, which is more than the proposed $ I 6.9 million deferral amount. This is
because the proposed deferral amount includes sales for resale and wheeling revenue, which both reduce the deferral
amount.
STAFF COMMENTS MARCH 10,2016
Ba$ wrs Ac'tuel olIlcroncr
{cl Powor Cod AnalydE Difirrcncc lMWh Dfhronc. lunit Cot Dlft!ronE NPC lsll Erlrov lfifwhll ljnlt Cod
/Vholesale Sal6 ReEnu6
)urchased Porer Expens€
)oal Fu€l Expense
{atuml Gas Expense
lrheelim. Hvdro aM Oth6r ExoeEe
246,671,938 6,259,734 (3.461(0,709,599) (6,311,004) 17.77101,143,798 (633,84s) 2.70(111,990,006) 3,23'1,830 (3s.581901.141 (1.680.4071 6.08
-{E%
a%
14%
-28Yo
't%
-43%
-36%
.2%
53%
-23%
.10Y
519
169
309
Nlt Tohl 2,,3.017.271 866.308
The 54 percent increase in purchased power unit cost as compared to the base was higher
than expected. Staffrequested copies ofcontracts and explanations ofthose electricity purchases.
Staff concluded that changing market conditions and contracts that provided historically low
purchase prices had expired. However, several higher cost per unit contracts remain in place. The
Commission had previously approved these contracts, and Staff believes the expenditures were
reasonable.
$6.4 Million REC Adjustment
REC prices remain low compared to REC prices used to estimate REC revenues embedded
in base rates established in Case No. PAC-E-l l-12. The Company only earned $366,000 (Idaho
share) in REC revenue as compared to $6.5 million included in base rates. Staff believes the
resulting net deferral of about $6.4 million (without sharing) is reasonable.
In Case No. PAC-E-15-09, the Commission approved a settlement that shifted $3 million in
Idaho-allocated NPC and $6.5 million in REC-related expense from the ECAM to the base rates
effective January 1,2076. See OrderNo. 33440. Staff thus expects NPC and REC deferrals to be
less in next year's ECAM than they are for this ECAM.
$4.2 Million Lake Side 2 Adder
In Case No. PAC-E-13-04, the Commission approved a Settlement Stipulation to allow the
Company to recover Lake Side 2 generation costs through the ECAM until the Company has the
opportunity to include them in base rates. See Order No. 32910. Staff believes the Company has
complied with this order by using the authorizedrate of $1.99 per MWh of generation, and that the
Company can include the full $4.1 million amount (Idaho's allocation) in the deferral (without
sharing) by remaining under the $5.43 million authorized cap. This component will be eliminated
from the ECAM when Lake Side 2 costs are built into base rates in the next general rate case.
STAFF COMMENTS MARCH T0,2016
Deferral Calculation
As a result of its review, Staff believes the Company's deferral calculations are accurate
except for two calculations related to the Company's back cast adjustment. Consequently, Staff
proposes additional adjustments to the back cast. If approved by the Commission, the Company's
deferral calculation, as adjusted by Staff, would reduce the Company's total deferral amount by
$51,343. A summary of the Company's proposed deferral and the effect of Staff s adjustments are
illustrated in the table below:
2016 ECAM Debml Summary Company Filinq Statr Prop6al
curent Mgthod Total D€taral lwilhoul interesl Siafi Adiustm6n Toial Defeml fwiihout Interesl
Subiect to 90% sharino:
NPC Adjustment
LCAR Adjustm€nt
SO2 Adjustment
DSM Load Control Adjustment
EITF 045 Adjustment
10O% Recowry:
REC Adjustment
Lakeside ll Resource Adder AdjustmBnt
Deer Cre€k Depreciation ExDense Adiu!
8,342,7U (1,509,503(350,1s1) (378,739
(18)(489,599) (37,768
(74,223')
6,'t60,170 261,983
4,'101, 3626)?A t?4038
6,833,280
(728,890
(18
(527.367
(74,223
6,42.,'153
4,10'1,943
60? 200
(47,539
13 805
6,785.742
(728,890)
(18)
(527,367)
(74,223)
6,422,153
4,101,943
598 396
By way of background, the Commission had previously ordered the Company to use a back
cast adjustment to ensure the costs the Company recovers through base rates and the ECAM are no
more and no less than actual NPC. See Order No. 33008. Next year's ECAM will not include a
back cast adjustment, because the Company will change its deferral calculation method to directly
calculate the difference between actual cost and the NPC recovered through base rates. See Order
No. 33440. Until the new method is implemented, the Company must incorporate the back cast
adjustment into its deferral calculation to ensure accuracy.
Staff s two concerns with the Company's proposed back cast calculation relate to the
separation of Deer Creek depreciation/amortization expense from NPC that started on January l,
2015. See Order Nos. 33304 and33440. First, the Company failed to establish two separate NPC
embedded base rates to calculate base rate recovery: $26.31 per MWh for December 2014 and
$26.11 per MWh for the period of January 2015 through November2015. Staff s proposed
correction increases the NPC back cast adjustment from $1,509,503 to $1,557,042, and decreases
the NPC deferral by $47,539.
Second, the Company failed to annualize the amount of Deer Creek depreciation expense in
its calculation of Deer Creek base rate recovery. Staff believes the embedded rate should include
the full 12 months of Deer Creek depreciation authorized in Case No. PAC-E-71-72, not just 11
STAFF COMMENTS MARCH 10,2016
months of depreciation expense. Including 12 months of depreciation expense in the embedded rate
increases the Company's Deer Creek amortization back cast adjustment from $24,038 to $27,843,
and decreases the Deer Creek deferral by $3,805. Staff s calculation of its proposed back cast
adjustments appear in Confidential Attachment C to these Comments.
Analvsis of Balancing Accounts
In Order No. 33265, the Commission approved the Company's adoption of an equal
monthly payment approach under which Monsanto and Agrium would make equal monthly
payments to retire their ECAM balances. The Company was to maintain separate balancing
accounts for Monsanto, Agrium, and tariff customers. After reviewing the Company's ECAM
balancing accounts, Staff believes the Company complied with Commission Order No. 33265 by
applying an equal payment approach starting April 2015 to satisfy Agrium and Monsanto deferral
amounts that accrued in the 2012tfuough2014 defenal periods. Staff believes the amounts will be
fully collected if carried forward through March of 2016, and that separate balancing accounts will
no longer be needed. However, Staff believes the Company's All Customer Balancing Account is
problematic for three reasons.
First, the Company miscalculated April 2015's "Interest on Balancing Account" (see
Company Exhibit No. 1) by omitting the March tariff customers' ending balance and rolling that
balance into April's All Customer Balancing Account. The resulting $113 error is immaterial, and
Staff merely mentions it in the interest of accuracy going forward.
Second, the Company inaccurately reflected the back cast adjustment in the deferral by
putting the total negative adjustment amount in the last month, which overstates the amount of
interest the Company should earn. Realistically, the back cast adjustment's base rate revenue
stream and actual costs are incurred across the l2-month defenal period. Staff thus believes it is
more accurate to calculate the interest against the back cast adjustment amount across the entire
12-months. Doing this results in an interest expense reduction of about $8,019.
Third, if the Commission authorizes Staffs proposed $51,343 deferral adjustment from the
previous section, that amount along with a corresponding amount of interest should be deducted
from the balancing account shown in the table below. Staff s resulting adjustments would decrease
the Company's total recovery (as of November 30, 2015) from $23,863,325 to $23,804,075:
STAFF COMMENTS MARCH 10,2016
Summarv of Balancinq Accounts (thru Nov. 30, 2015)
Unamortized Pre\ious Balance
ECAM Rider Re\,enues
2016 ECAM DeEnal
lnterest on DeErral
Companv Filinq Stafi DeEnal Adiustments
26,720,238
(1 9,769,949)
16,629,079 (51,343)
97,008
1 86.950
Staff lnterest Adiustmenls Staff Proposal
26,720,238
(1 9,769,949)
16,577,736
88,989
187,063
Finally, Staff notes that there was a March ending balance of $134,000 in the "Tariff
Customer Balancing Account" that was rolled into the April "All Customer Balancing Account."
Staff believes that this is a reasonable treatment given the small size of the amount.
Analvsis of Proposed Rates
Staff thoroughly reviewed the Company's rate design and found that it complies with past
Commission orders and that the Company's calculations are accurate and reasonable. Given the
limited size of Staff s proposed adjustments, Staff does not recommend a change in the Company's
proposed rates. Rather, Staff recommends that the adjustments be carried forward with any
remaining balances to be collected in next year's ECAM.
CUSTOMER RELATIONS
The Company's Application includes a press release and customer notice. The customer
notice was mailed with cyclical billings. The last notice was mailed on February 24,2016, which
allowed customers a reasonable opportunity to file timely comments with the Commission by the
March 10, 2076, deadline.
As of March 10,2016, the Commission has received no comments from customers.
STAFF RECOMMENDATION
Staff recommends that a total deferral amount of $16,577,736 (without interest) for the
period of December 1,2014 through November 30,2015 be approved for recovery from ratepayers.
In addition Staff recommends that:
1. The Company decrease interest amounts reflected in the balancing accounts by
$7,907 based on Staff s proposed adjustments.
9STAFF COMMENTS REVISED MARCH II,2016
2. Schedule 94 ECAM rates, as illustrated in Attachment A, should be approved by
the Commission with an effective date of April1,2016.
3. The Company should file tariffs that reflect Commission approved rates.
Respecttully submitted this !0+ day of Mar ch20l6.
Technical Staff: Mike Louis
Joe Terry
Daniel Klein
Johanna Bell
i:umisc/commentVpace I 6.5kkmljtdkjb comments
Karltr.V0ei
STAFF COMMENTS MARCH 10,2016
rrqo9\OOOO
ooodaeaer
Ndo
N
_a €S 6==ng h?='N -VV
-l-o-l 6l<l?? :21
I
-€ olFr€lN--l
N-6144 4l
I
Q
z
o
?>l1
ti
Ndn=
60€O
G
d
6N
+N
o-q90
El.
€ $ s f 6- S S 6 6 F -o - ,X - €O - - \o^d ^i q- e-",1 c
-;$€Nqi
-lu-l
u ,-.1 'J-l
il
(nl -
\o?.\o*
rca[:.] al9<? E
otrtrooEZt)9 o.rF
r-. 6 -S{Ovr
'l B[3[
=l xilxil
€ N .s d F-s - + 6 - n €- N e € ne - N ; e + NNe^,4Sv-4-*vOh6-6d-4. 4.-6d r!2_ g a_
6 6 - -- 6 - -R R n nn n R n
€ @ € €€ € € €d d d NN N d dN R R RN R 1 NO O O OO O O O
6 - A f €N € - - € I N6 6 ^: 6 rN h + = 6 o 6N - \: s h€ €:; € $-j6_:4^i eq4 v;4q6eq
h 6 a 6 6: - N -. h O -N O = I Nr _ N _l € € €1\ t; -I €,€^ $^ €^ d q q -'lN 6 r; h -n O I h- N h -66\XN@€6=6-- ;-€ -i n-
f O N €- + O h 6r o i- @h 6 - ^: os- 9- i; s^--: t^ 6- d og
@ O 6 Nh N N ui -h6ilan-6
r € - € 9€ 6 Q A - f + €I - J N -m - r &i N € € r€A^:€-S6Oal-ON+d d ; d +e + -i ; e 'd .d s
d6^:6h-4jaqaslaa*jq
- o \. - 6- € o s m a €
- O . O €h < h -' O N €o^ a- \S o- Y: €- <l;<i ? o: n
-oM'-Nh66N'--rOo.;dOh-*i+O
r 6 A 6 d€ 6 r \^ 6 - €o h; € -d € I .: € h hh - .X 6 OG f - ^' € 6-_j4:6d e4da .,j4e66A
LI
N N d Nd d N N d d
= n = nn n n n n n
--Odaaa-4
NdNNnnnn
-o-onsnn
€€€€NdNNlnnR
-OOOqeei a
Egg g. H 8 E c Eg gl?' E 5 = E 3aa trY=
= ssE = =l:i:fl B.Ys€n, ; flEE5.? 3 E+
gIEEgE EIE!s s*I EEE Eiig! EIFEa?gE E E
o
Ndns
B
e
2
Q
=[uil
n[1[
*il=[
6il 3il
elel
B[;I
$ila
u[u
=l
:l
-l
-l
*l
=El
*l
r
N
d
N
d
r€
r
$r
F-r€ON-
d+O$
F- F-
N-
;l
;l
Bl
ill
L\
€9-oN€oo+orN+O +*
s\v-h
-*.€-Nq 6 '1 €q
+\i
-l
rl
I -^l-hI -r--l q salsd
I
I
I ^o-l-aa
^l a+
=l ^6N
=lh + Ndl- 4q-l
I
I --lo-El hollo 5n'l vN
,-1.
I
*l u
I
<i
o
bl
oo
>5
d-
2
FZa
ZlrJ^=q3=R
='a dc,aZ-l-)<O za
2.-\Aai
v<=r{
^za-(,)J+=??22o: !.r H*;a e;edFaz>1F,/)EI9q)42,*EEsEEEgnIEXErr!:tr>=2u)j6a=
a 9&
6ar+ ol6666o1N'l
I
I
*(-n'r--
o-N6Sh9r€dNNddNddd-No<r n€F-- o9= =|== !9==9
ATTACHMENT B
IS CONFIDENTIAL
AND PROTECTEI)
UNDERTHE
PROTECTIVE
AGREEME,NT
ATTACHMENT C
IS CONFIDENTIAL
AND PROTECTE,I)
UNDERTHE
PROTECTIVE,
AGREEMENT
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS IOTH DAY OF MARCH 2016,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN
CASE NO. PAC-E-16-05, BY MAILING A COPY THEREOF, POSTAGE PREPAID,
TO THE FOLLOWING:
DATA REQUEST RESPONSE CENTER RANDALL C BUDGE
TED WESTON
ID REG AFFAIRS MANAGER
ROCKY MOUNTAIN POWER
I4O7 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 841 16
E-MAIL: ted.weston@.pacifi corp.com
(Confi dential Attachments)
E.MAIL ONLY:
datarequest@pacifi corp. com
(Confi dential Attachments)
BRUBAKER & ASSOCIATES
16690 SWINGLEY RIDGE RD
#t40
CHESTERFIELD MO 63017
E-MAIL: [e-mail]
YVONNE HOGLE
ASSISTANT GENERAL COUNSEL
ROCKY MOUNTAIN POWER
1407 WEST NORTH TEMPLE STE 320
SALT LAKE CITY UT 84I 16
E-MAIL: [e-mail]
(Confi dential Attachments)
RACINE OLSON NYE ET AL
PO BOX 139r
POCATELLO ID 83204-1391
E-MAIL: [e-mail]
E-MAIL ONLY:
JAMES R SMITH
MONSANTO COMPANY
E-MAIL: j [e-mail]
CERTIFICATE OF SERVICE