20171120Keller Direct.pdf

RECEIVED
BEFORE THE 2gggy gg 7 .
IDAHO PUBLIC UTILITIES COMMIS$lbN 00 SSION
IN THE MATTER OF THE APPLICATION )
OF ROCKY MOUNTAIN POWER FOR A )CASE NO.PAC-E-17-07
CERTIFICATE OF PUBLIC )
CONVENIENCE AND NECESSITY AND )
BINDING RATEMAKING TREATMENT )
FOR NEW WIND AND TRANSMISSION )
FACILITIES )
DIRECT TESTIMONY OF RICHARD KELLER
IDAHO PUBLIC UTILITIES COMMISSION
NOVEMBER 20,2017
1 Q.Please state your name and business address for
2 the record.
3 A.My name is Richard Keller.My business address
4 is 472 West Washington Street,Boise,Idaho 83702.
5 Q.By whom are you employed and in what capacity?
6 A.I am employed by the Idaho Public Utilities
7 Commission as a Staff Engineer.
8 Q.What is your educational and experience
9 background?
10 A.I received my Bachelor of Science degree,with
11 Honors,in Mechanical Engineering from the University of
12 Wyoming in 1994.I have been registered as a professional
13 engineer in Idaho since 2002.In addition to my formal
14 education,I attended the Electric Utility Basic Practical
15 Regulatory program offered by New Mexico State University's
16 Center for Public Utilities,and also attended Michigan
17 State University's Institute of Public Utilities
18 Electricity Grid School.
19 I started my engineering career working for the
20 Kiewit Industrial Company as an estimator,and progressed
21 into the positions of field engineer and mechanical lead
22 engineer.As an engineer,I was involved in the
23 construction of large industrial projects including
24 Amtrak's Northeast Corridor Electrification,a northeast
25 segment of Level 3 Communications long haul fiber optic
CASE NO.PAC-E-17-07 KELLER,R.(Di)111/20/17 STAFF
1 network,and initial support of a combined cycle power
2 plant in Washington State.
3 In 2001,I began working for POWER Engineers
4 Inc.,holding positions as mechanical engineer,lead
5 mechanical engineer,and project engineer.My roles
6 included engineering,design,project oversight,and the
7 sealing of project documents as a registered professional
8 engineer responsible for mechanical engineering and design.
9 Several projects that I was directly involved with during
10 this period include reciprocating engine generating plants;
11 simple cycle and combined cycle power plants;and retrofits
12 to existing coal fired power plants.
13 I began work at the Idaho Public Utilities
14 Commission in 2015.My work responsibilities include a
15 variety of electric and water utility cases including
16 integrated resource plans,depreciation,purchased gas and
17 power cost adjustment,prudence review of investments,line
18 extension,and general rate cases looking specifically into
19 capital investment.
20 Q.What is the purpose of your testimony in this
21 proceeding?
22 A.The purpose of my testimony in this case is to
23 review and provide Staff's position regarding the Company's
24 analysis of the Application for determining the prudence of
25 a proposed investment in new wind and transmission.
CASE NO.PAC-E-17-07 KELLER,R.(Di)2
11/20/17 STAFF
l In addition,I address whether or not the
2 Company's proposal for the project is a least-cost and
3 least-risk alternative for meeting a system capacity
4 deficit projected to occur in the year 2028.
5 Q.Could you please summarize your testimony?
6 A.Yes.Although not needed to meet system capacity
7 requirements until 2028,I believe that the new wind and
8 transmission project as presented by the Company could be
9 the least cost,least risk alternative to meet future
10 resource needs over the next 30 years.I believe the
11 assumptions used by the Company in its economic analysis
12 fall within a reasonable range and support the Company's
13 proposal.
14 The Company completed an analysis to determine
15 the net benefit difference between the proposed project,
16 and a baseline across nine alternative futures with
17 different natural gas forecasts and CO2 prices.
18 Results for seven of nine alternative future
19 scenarios show a net benefit to customers when compared to
20 the baseline alternative.Assuming there is an equal
21 probability that each scenario will occur,the expected
22 value of the net benefit difference is about $191 million
23 in favor of the project (see Exhibit No.101).
24 A significant portion of economic benefit
25 associated with the new wind and transmission project
CASE NO.PAC-E-17-07 KELLER,R.(Di)311/20/17 STAFF
l occurs as a result of the Company's reliance on capturing
2 100 percent of the federal wind Production Tax Credits
3 (PTCs).Without receiving the full benefit from the PTCs,
4 the project economics would not be beneficial to customers.
5 I maintain that risks and uncertainties can be
6 categorized into one of two groups:those the Company can
7 control and those it cannot.Project risks that the
8 Company can control include overall project costs and
9 timely project completion.Project risks that the Company
10 cannot control include changes in corporate tax rate,
11 future natural gas prices,and CO2 mitigation costs.
12 I believe the Company must protect customers from
13 risks that it can control and look to mitigate those risks
14 that are beyond its control,primarily with respect to
15 corporate tax rate changes.
16 Successful completion of the new wind and
17 transmission project by the Company is subject to
18 significant risk because the project has a "time-limited
19 opportunity"tied to qualifying for the $24 per megawatt-
20 hour PTC benefit by year end 2020.Completing the project
21 by the deadline is within the Company's control.
22 A potential change to the corporate tax rate as
23 proposed in legislation currently being considered by
24 Congress could make the project uneconomical before
25 construction even begins.
CASE NO.PAC-E-17-07 KELLER,R.(Di)411/20/17 STAFF
1 To reduce risk whether within or outside the
2 Company's control,the Company should continually assess
3 the liability posed by the various risks to reduce,limit,
4 or prevent negative impacts on customers.
5 Q.Please provide a summary of the Company's
6 proposed project.
7 A.The Company proposes to construct or acquire new
8 Wyoming wind resources with a total capacity of 860
9 megawatts.The Company has submitted a request for
10 proposal seeking competitive bids.The Company plans to
11 bid directly into this proposal with four projects of its
12 own that the Company identifies as benchmark resources.
13 The Company also proposes construction of a 140-
14 mile segment of the Energy Gateway West transmission
15 project from Aeolus-to-Anticline in southern Wyoming.This
16 500 kV transmission line will include upgrades and improved
17 interconnection to several sub-stations along the route.
18 The Company presents this project as a "time-
19 limited opportunity"to obtain cost-effective generation
20 and construct the necessary transmission facilities with
21 minimal impact to customer rates.The Company states that
22 without the new PTC qualified wind,the transmission
23 project would not be economic.
24 Q.What is your perspective of the Company's need
25 for this project?
CASE NO.PAC-E-17-07 KELLER,R.(Di)511/20/17 STAFF
1 A.The 2017 IRP indicates that the Company does not
2 require added system capacity until 2028.The Company's
3 conclusion is based on its 13 percent planning-reserve
4 margin,assumed coal unit retirements,incremental energy
5 efficiency savings,and available wholesale-power market
6 purchases.
7 Aside from this lack of current need,if the
8 Company delivers the project as described,the new wind and
9 transmission project would provide benefit to customers by
10 providing lower cost energy to the system,provide improved
11 transmission system reliability,and would add diversity to
12 the Company's generating resources.
13 I believe that in implementing the new wind and
14 transmission project there are numerous and significant
15 risks.If not properly mitigated,the result could be a
16 project that is not beneficial to customers.
17 Q.What is your opinion regarding the Company's
18 method for evaluating the economics of the project?
19 A.I believe the Company's method for economically
20 evaluating the project is reasonable and in several ways
21 conservative.The Company compared the relative system net
22 present value revenue requirement difference (PVRR(d))
23 between operating with the project and operating without
24 the project over the investment's 30-year useful life.The
25 Company also calculated the PVRR(d)across nine different
CASE NO.PAC-E-17-07 KELLER,R.(Di)611/20/17 STAFF
1 alternative futures including different combinations of
2 low,medium,and high natural gas price forecasts,and
3 zero,medium,and high carbon dioxide prices to understand
4 their economic impact.
5 The analysis and assumptions used in this case
6 were based on the Company's 2017 IRP.The project is also
7 included in the Company's 2017 IRP preferred portfolio as a
8 result of its analysis.
9 Q.What is your assessment of the Company's
10 methodology used to determine the difference in net
11 benefits between the project and the baseline?
12 A.I believe the factors selected and the
13 methodology used to evaluate the cost effectiveness and
14 risk in the Company's analysis are reasonable.The
15 Company's approach is similar to the methodology used for
16 the 2017 IRP.
17 There are two factors that make the Company's
18 results conservative.First,the Company used 300
19 megawatts of low cost PTC qualified wind generation as a
20 proxy to utilize 240 megawatts of existing transmission
21 capacity in its baseline alternative.In actuality there
22 are PURPA qualified facilities which have priority for
23 interconnection.Replacing the 300 megawatts of wind proxy
24 resources with PURPA qualified generation would increase
25 the revenue requirements in the baseline because the proxy
CASE NO.PAC-E-17-07 KELLER,R.(Di)711/20/17 STAFF
1 wind receives PTC benefits making the costs much lower than
2 the PURPA projects.This would result in a more beneficial
3 PVRR(d)for the new wind and transmission case.
4 Second,the Company did not reflect any benefit
5 for the sale of RECs associated with new wind generation.
6 The Company indicates the present value benefit to the
7 project through 2050 would increase by $34 million (Link
8 direct testimony,p 4)for every dollar assigned to the
9 incremental RECs generated from new wind.When considering
10 the adjustments for PURPA wind and the value of RECs,all
11 nine scenarios would show a positive economic benefit to
12 customers.
13 Q.What is the benefit of the Production Tax Credit
14 and why is it important to project economics?
15 A.The Company's analysis shows the present value
16 benefit of the PTCs for the project through 2050 is $795
17 million (Link,Exhibit 25).The amount is conditioned on
18 recovering 100 percent of the PTC benefit.The PTC value
19 is one of the most important factors for providing economic
20 benefit to customers.If the project is not operational by
21 December 31,2020,each year of delay reduces the PTC
22 benefit by 20 percent.A reduction of the benefit by just
23 one year or 20 percent equates to a present value reduction
24 of the PTC benefit by $159 million.This reduction would
25 make the project uneconomic ($137 million PVRR(d)benefit
CASE NO.PAC-E-17-07 KELLER,R.(Di)811/20/17 STAFF
l minus $159 million reduction to PTC benefit)costing
2 customers $22 million based on the medium natural gas and
3 CO2 pricing forecasts which are used to support the
4 Company's Application.
5 Q.What are the project risks that prevent the
6 Company from realizing full PTC benefits?
7 A.In order for the Company to be eligible for the
8 full PTC benefit,each project must meet specific
9 requirements prior to January 1,2017.Beginning
10 construction is the most visible way to meet eligibility
11 requirements.Alternatively,the Company has relied on a
12 five-percent Safe Harbor option in order to satisfy the
13 requirements.The Company has both contracted directly
14 with a wind turbine manufacturer and a developer for the
15 Company's four proposed benchmark resource sites to capture
16 the Safe Harbor.However,any change to the current
17 interpretation of the five-percent Safe Harbor rule may put
18 PTCs at risk.
19 Based on the current status of the Company's
20 benchmark sites,the projects will need to be operational
21 by December 31,2020.Although the Company seems confident
22 it can meet this date,there are numerous steps that need
23 to be completed.The Company indicates that the
24 transmission line is on the critical path for meeting the
25 operational deadline.In order to complete the
CASE NO.PAC-E-17-07 KELLER,R.(Di)911/20/17 STAFF
1 transmission portion of the project,the Company still
2 needs to secure the remaining federal permits,Wyoming
3 approval of a CPCN,and secure the remaining transmission
4 rights of way.
5 Securing the remaining wind turbine equipment and
6 the potential for construction delays could add even more
7 risk to capturing full PTC benefits from the project.
8 Q.Is the amount of wind energy used to support the
9 Company's economic analysis reasonable?
10 A.Yes,I believe the amount of wind energy assumed
11 in the Company's Application is reasonable for the four
12 benchmark resource sites.
13 I reviewed several factors tied to the
14 reliability of wind turbine generators,wind turbine
15 efficiency,and the average wind velocity for the area
16 considered for the Company's proposed benchmark sites.
17 Industry datal 2 indicates the mechanical
18 availability of modern wind turbines to be almost 97
19 percent.This value represents the percent of time a wind
20 turbine generator is available to generate whether or not
21
22
1 GE's Onshore Wind Services -GE Renewable Energy
23 https://www.gerenewableenergy.com/content/dam/gepower-renewables/global/en_US/downloads/brochures/wind-onshore-
24 services-gea31819b.pdf;
2 Siemens -Harnessing opportunities for better results
25 https://www.siemens.com/global/en/home/markets/wind/service
.html
CASE NO.PAC-E-17-07 KELLER,R.(Di)1011/20/17 STAFF
1 the wind is blowing.This high availability can be
2 attributed to the continued advancement in wind turbine
3 technology,industry requirements for wind turbine
4 generator reliability,and mechanical operational data from
5 the large installed base of wind turbines placed into
6 service in recent years.If the Company's wind turbine
7 generators are properly operated and maintained,this
8 equipment should perform equivalent to those currently
9 operated within the industry.
10 Based on information from the National Renewable
11 Energy Laboratory (NREL)for south central Wyoming,the
12 area (at a specified hub height 80 meters above the surface
13 elevation)has an average annual wind speed near or above
14 10 meters per second.NREL also provides wind related
15 capacity factors for some of the existing sites within the
16 area.These capacity factors are consistent with values
17 used by the Company for its economic analysis.
18 Q.Should the Company be held responsible for
19 mitigating the risk associated with qualifying for full PTC
20 benefits?
21 A.I believe the Company is responsible for
22 mitigating the risks in order to qualify for full PTC
23 benefits because the factors of success are within the
24 Company's control.In order to satisfy the Safe Harbor
25 requirements,the Company is responsible for insuring that
CASE NO.PAC-E-17-07 KELLER,R.(Di)1111/20/17 STAFF
l five percent of the capital cost were expended prior to the
2 year 2017.Furthermore,the Company is responsible for
3 meeting a schedule the Company developed to insure the new
4 wind and the transmission are operational by December 31,
5 2020.
6 Q.Have the Company's actions demonstrated its
7 commitment to achieving full PTC benefits?
8 A.Yes.It's evident the Company understands the
9 project economics rely on achieving full PTC benefits and
10 considers the risk acceptable given its application to the
11 Commission requesting a CPCN.The Company's Application is
12 supported by significant analysis related to the economics
13 of the project and likewise has committed to a compressed
14 schedule for completing the project prior to the December
15 31,2020 PTC deadline.In addition,the Company has
16 committed significant capital in order to qualify for the
17 five-percent Safe Harbor requirements.
18 The Company is also in the midst of completing a
19 request for proposal for PTC qualified wind projects,which
20 the Company is bidding into based on its benchmark
21 resources.In total,these actions reflect the Company's
22 commitment to an expected successful outcome of the
23 project.
24 Q.Are there any other considerations related to
25 meeting the December 31,2020 deadline?
CASE NO.PAC-E-17-07 KELLER,R.(Di)1211/20/17 STAFF
1 A.In order to capture the full PTC benefit,the
2 Company faces significant pressure to meet the December 31,
3 2020 deadline.Any delay to the project will serve to
4 further compress the schedule.This is especially true for
5 any delays to the construction of the transmission line,
6 given that the transmission line is on the critical path
7 for full operation of the project.The combination of hard
8 deadlines and project uncertainties can lead to delays
9 which can only be remedied by increasing cost,authorizing
10 overtime,and adding incremental resources.This risk will
11 adversely affect capital cost and cost effectiveness to
12 customers if not mitigated.
13 Q.How much additional transmission capital
14 investment makes the project no longer economically
15 beneficial to customers?
16 A.Based on the Company's model,if the $681 million
17 capital investment for the transmission portion of the
18 project increases by 24.8 percent,the project is no longer
19 beneficial to customers.This analysis is based on the
20 medium natural gas and CO2 pricing forecasts which are used
21 to support the Company's Application.
22 Q.Are there factors that are outside of the
23 Company's control?
24 A.Yes.There are several,but three risk factors
25 pose the greatest risk to the economic viability of the
CASE NO.PAC-E-17-07 KELLER,R.(Di)1311/20/17 STAFF
l project:changes to the corporate tax rate,the price of
2 natural gas,and changes to the price of CO2.
3 Q.Can you please characterize the risk created by
4 changes in the corporate tax rate and how it can be
5 mitigated?
6 A.If corporate income tax rates are lowered from
7 the current rates assumed in the Company's economic
8 analysis,there will be a significant negative impact for
9 two reasons:1)a lower income tax rate could significantly
10 reduce the PTC benefit amount,and 2)the Company has
11 little control of the circumstances other than exiting the
12 project if the new rates cause the project to be
13 uneconomic.Corporate tax reduction is currently a high
14 priority in Congress.
15 The Senate and House currently have proposed
16 legislation to reduce the corporate tax rate somewhere in
17 the 20 percent to 25 percent range.If this occurs,it
18 would significantly reduce the PVRR(d)of the project
19 primarily by reducing the after-tax benefit of the PTC.
20 For example,if the corporate tax rate was reduced from
21 current levels to 20 percent,the net present value of the
22 PTC's over the ten-year eligibility period would be reduced
23 from $795 million to $627 million making the project much
24 less economically viable.
25 There is a good chance the outlook for reducing
CASE NO.PAC-E-17-07 KELLER,R.(Di)1411/20/17 STAFF
1 the corporate income tax will be known before the Company
2 commits to significant capital expenditure.To mitigate
3 this risk,the Company needs to monitor corporate tax rate
4 status.If tax rates are reduced,the Company should be
5 required to make a filing with the Commission for
6 additional review before proceeding with the project.
7 Q.Can you please characterize the risk created by
8 natural gas prices and how it can be mitigated?
9 A.Yes.The risk is that actual natural gas prices
10 turn out to be lower than those assumed in the Company's
11 analysis.This makes the next best alternative,which
12 includes gas-fired generation,more beneficial in
13 comparison to the proposed project.While natural gas
14 prices can have a large impact on project economics,the
15 Company used a reasonable range of natural gas price
16 forecasts and are somewhat conservative with respect to
17 what future natural gas prices will actually be.This
18 conservative natural gas price assumption will likely
19 result in greater project benefits than those estimated by
20 the Company.For example,the Company evaluated the
21 project using low,medium,and high natural gas price
22 forecasts.The Company's PVRR(d)results for the different
23 forecasts,keeping the CO2 price constant to isolate the
24 effects of natural gas,are reflected in the table below.
25
CASE NO.PAC-E-17-07 KELLER,R.(Di)1511/20/17 STAFF
1 Modeled Scenario PVRR(d)
2 Low Gas,Medium CO2 $93 million
3 Medium Gas,Medium CO2 ($137)million
4 High Gas,Medium CO2 ($351)million
5
6 As can be seen from the table,different natural
7 gas forecasts have a large effect on the economics of the
8 project.The low natural gas price forecast results in a
9 project that costs more than the Company's next best
10 alternative,but costs less for both the medium and high
11 forecasts.
12 The range of natural gas forecasts used in its
13 analysis are conservative when compared to the most recent
14 Energy Information Administration (EIA)forecasts.As can
15 be seen in the chart below,the Company's forecasts are
16 largely and consistently lower than EIA's forecasts through
17 2036.
18
19
20
21
22
23
24
25
CASE NO.PAC-E-17-07 KELLER,R.(Di)1611/20/17 STAFF
1 Comparison of Natural Gas Forecasts
2 (2017 EIA Annual Energy Outlook Forecasts to Pacificorp Proposals)
$16 00
3
8
9 ---Adocted Mediurn---Adopted High Adopted Low
10 --2017 Ref 6:^2017 Lo EiA ==2017 Hi EIA
11 There is very little that can be done to mitigate
12 changes in the price of natural gas once the project is
13 implemented.The only mitigation measure that the Company
14 can take is to re-evaluate natural gas prices and other
15 circumstances just prior to commitment of capital and
16 determine if an alternative course of action is warranted.
17 Q.Can you characterize the risk created by CO2
18 prices and how it can be mitigated?
19 A.Yes.The risk is that the actual cost to
20 mitigate CO2 is lower than that assumed in the Company's
21 analysis.This makes the Company's next best alternative
22 more economical when compared to the proposed project.
23 While CO2 prices can have a large impact on the economics
24 of the project,the Company used a conservative and
25 reasonable range of CO2 prices that support the Company's
CASE NO.PAC-E-17-07 KELLER,R.(Di)1711/20/17 STAFF
1 proposal.Given that current CO2 prices are relatively
2 non-existent,any increase in CO2 prices moving forward
3 will only make the proposed project more economical when
4 compared to available alternatives.
5 For example,the Company evaluated the project
6 economics on three different CO2 price forecasts:zero,
7 medium,and high.The zero price assumes no cost of CO2
8 throughout the project's life.The medium price forecast
9 ranges from $3.41 to $14.40 per ton and the high forecast
10 ranges from $4.73 to $38.42 per ton through year 2036.
11 The Company's PVRR(d)results for the different
12 forecasts,keeping the natural gas price constant to
13 isolate the effects of CO2 pricing,are reflected in the
14 table below:
15 Modeled Scenario PVRR(d)
16 Medium Gas,Zero CO2 $(53)million
17 Medium Gas,Medium CO2 ($137)million
18 Medium Gas,High CO2 ($317)million
19
20 As can be seen by the table,different levels of CO2
21 price have a large effect on the economics of the project.
22 The Company's next best alternative uses natural gas-fired
23 generation to fill the capacity deficit which makes system
24 costs higher compared to the new wind and transmission
25 project when considering increasing CO2 prices.
CASE NO.PAC-E-17-07 KELLER,R.(Di)1811/20/17 STAFF
l Because the Company uses zero priced CO2 as its
2 low case scenario,the Company has provided an evaluation
3 which represents a reasonable "worst case"in terms of CO2
4 pricing and project economics.Given the "worst case"
5 scenario as a starting point,the Company's analysis
6 provides an accurate evaluation of risk across a full range
7 of CO2 prices.
8 Because future implementation of Federal CO2
9 regulations are uncertain,there is little the Company can
10 do to mitigate future CO2 price risk.However,any future
11 legislation that increases the price on carbon emissions
12 would improve the economics of the proposed project.
13 Q.What project risks that are within the Company's
14 control?
15 A.The Company is in direct control of:
16 a)maintaining Safe Harbor qualification;
17 b)meeting regulatory requirements;
18 c)risks tied to the schedule for both the new wind
19 and transmission as it relates to capturing 100
20 percent of the PTC benefit;
21 d)costs tied to development and construction of the
22 new wind and transmission project;and
23 e)life cycle performance and availability of the
24 assets through proper operation and maintenance.
25 Q.Is it appropriate for the Company to protect
CASE NO.PAC-E-17-07 KELLER,R.(Di)1911/20/17 STAFF
l customers from risks within its control?
2 A.Yes.The project is only economical for
3 customers if the project is constructed as proposed.
4 Customers should not be responsible for project costs if
5 the Company fails to complete the project at reasonable
6 cost and on schedule to obtain the necessary PTCs.
7 Q.What project risks are not in the Company's
8 control?
9 A.The Company does not have control of:
10 a)future pricing of natural gas;
11 b)future pricing of the CO2 cost;
12 c)future market price of electricity;and
13 d)any change to corporate tax legislation after
14 significant capital investment.
15 Q.Does this conclude your testimony in this
16 proceeding?
17 A.Yes,it does.
18
19
20
21
22
23
24
25
CASE NO.PAC-E-17-07 KELLER,R.(Di)2011/20/17 STAFF
Analysis based on equal probabilityof outcome
Reference -Link direct testimony,p38,Table 3:Annual RevenueRequirement PVRR (d)
No consideration of RECs
Scenario Natural Gas CO2 Probability Annual Annual
Percentage Company Expected
PVRR(d)Value (Million)
(Million)
1 Low Zero 11.1%$174 $19
2 Low Medium 11.1%$93 $10
3 Low High 11.1%($194)($22)
4 Medium Zero 11.1%($53)($6)
5 Medium Medium 11.1%($137)($15)
6 Medium High 11.1%($317)($35)
7 High Zero 11.1%($341)($38)
8 High Medium 11.1%($351)($39)
9 High High 11.1%($595)($66)
($191)
Note:Negative numbers represent benefit to customers
Exhibit No.10]
Case No.PAC-E-17-07
R.Keller,Staff
11/20/17
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 20TH DAY OF NOVEMBER 2017,
SERVED THE FOREGOING DIRECT TESTIMONY OF RICHARD KELLER,IN
CASE NO.PAC-E-17-07,BY MAILING A COPY THEREOF,POSTAGE PREPAID,
TO THE FOLLOWING:
TED WESTON YVONNE R HOGLE
ROCKY MOUNTAIN POWER ASSISTANT GENERAL COUNSEL
1407 WEST NORTH TEMPLE STE 330 ROCKY MOUNTAIN POWER
SALT LAKE CITY UT 84116 1407 WN TEMPLE STE 320
E-MAIL:[e-mail] SALT LAKE CITY UT 84116
E-MAIL:[e-mail]
DATA REQUEST RESPONSE CENTER RANDALL C BUDGE
E-MAIL ONLY:RACINE OLSON NYE &BUDGE
[e-mail] PO BOX 1391
POCATELLO ID 83204-1391
E-MAIL:[e-mail]
BRUBAKER &ASSOCIATES RONALD L WILLIAMS
16690 SWINGLEY RIDGE RD #140 WILLIAMS BRADBURY PC
CHESTERFIELD MO 63017 PO BOX 388
E-MAIL:kiverson consultbai.com BOISE ID 83701
bcollins consultbai.com E-MAIL:ron williamsbradbury.com
ELECTRONIC ONLY ELECTRONIC ONLY
JIM DUKE KYLE WILLIAMS
IDAHOAN FOODS BYU IDAHO
E-MAIL:[e-mail] E-MAIL:[e-mail]
ELECTRONIC ONLY ERIC L OLSEN
VAL STEINER ECHO HAWK &OLSEN
NU-WEST INDUSTRIES INC PO BOX 6119
E-MAIL:val.steiner agrium.com POCATELLO ID 83205
E-MAIL:[e-mail]
ANTHONY YANKEL BRADLEY MULLINS
UNIT 2505 333 SW TAYLOR
12700 LANE AVENUE SUITE 400
LAKEWOOD OH 44107 PORTLAND OR 97204
E-MAIL:[e-mail] E-MAIL:brmullins mwanalytics.com
SECRET Y
CERTIFICATE OF SERVICE