20230517Reply Comments REDACTED.pdf

May 17, 2023

VIA ELECTRONIC DELIVERY

Jan Noriyuki
Commission Secretary
Idaho Public Utilities Commission
11331 W Chinden Blvd.
Building 8 Suite 201A
Boise, ID 83714

Re: CASE NO. PAC-E-23-09
IN THE MATTER OF THE APPLICATION OF ROCKY MOUNTAIN POWER
REQUESTING APPROVAL OF $32.5 MILLON ECAM DEFERRAL

Dear Ms. Noriyuki:

Pursuant to Commission Order No. 35740 providing public notice of the Company’s Application,
authorizing the processing of the Application by Modified Procedure, and establishing the
procedural schedule please find Rocky Mountain Power’s Reply Comments in the above
referenced matter.

Informal inquiries may be directed to Mark Alder, Idaho Regulatory Manager at [phone].

Very truly yours,

Joelle Steward
Senior Vice President of Regulation and Customer Solutions

Enclosures

CC: Ron Williams
Eric Olsen
TJ Budge

RECEIVED
Wednesday, May 17, 2023 3:03:54 PM
IDAHO PUBLIC
UTILITIES COMMISSION

Page 1
Joe Dallas (ISB# 10330)
PacifiCorp, Senior Attorney
825 NE Multnomah Street, Suite 2000
Portland, OR 97232
Email: [e-mail]
Attorney for Rocky Mountain Power

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF THE APPLICATION
OF ROCKY MOUNTAIN POWER
REQUESTING APPROVAL OF $32.5
MILLON ECAM DEFERRAL
) CASE NO. PAC-E-23-09
)
) REPLY COMMENTS OF
) ROCKY MOUNTAIN POWER

Pursuant to Rule 202.01(d) of the Rules of Procedure of the Idaho Public Utilities
Commission (“Commission”) and the Commission’s April 13, 2023, Notice of Application and of
Modified Procedure, Rocky Mountain Power a division of PacifiCorp (the “Company”) hereby
submits reply comments in the above-referenced case.
I. BACKGROUND
1. On March 30, 2023, the Company applied for Commission authorization to adjust
its rates under the Energy Cost Adjustment Mechanism (“ECAM”) and requested approval of
approximately $32.5 million in deferred costs from the deferral period beginning January 1, 2022,
through December 31, 2022, with a 2.3 percent overall increase to Electric Service Schedule No.
94, Energy Cost Adjustment (“Schedule 94”).
2. On April 13, 2023, Commission Order No. 35740 provided public notice of the
Company’s Application, authorized processing of the Application by Modified Procedure, and
established the procedural schedule allowing persons who would like to file written comments to
have until May 10, 2023, and the Company having until May 17, 2023, to file reply comments.

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3. In addition to the Commission Staff, P4 Production, L.L.C. (“P4”) filed a petition
to intervene and was granted intervener status in the case.
4. On May 9, 2023, P4 filed comments and on May 10, 2023, Commission Staff filed
comments.
II. REPLY COMMENTS
A. Commission Staff’s Comments:
5. Staff conducted a thorough review and audit of the 2022 ECAM, which involved
multiple production requests, an on-site visit to the Company facilities in Salt Lake City to meet
with the Fuel Resources group, and also an on-site visit to Portland to meet with the Company’s
Net Power Costs (“NPC”) group. Based on their findings, Staff is recommending that the
Commission approve the 2022 ECAM deferral balance and approve the proposed Schedule 94
rate. However, Staff also recommends the Commission defer its decision on the prudence of 2022
NPC until an investigation is completed into the Company’s ability to economically dispatch its
coal plants. Staff suggests that the Company provide a report within six months, which should
include a comprehensive assessment of the Company’s dispatch of its coal plants. The report
should include details of the Company’s forecasted load and its plan to meet this load requirement,
a timeline of events leading to coal shortages and the inability to dispatch coal plants, a list of
issues that resulted in a significant increase in NPC, documentation of the Company’s awareness
of the shortfalls, alternative solutions considered, and the Company’s proposed actions for the
future to address these challenges effectively. Staff requests the authority to make adjustments to
the recovery of actual NPC until the next ECAM filing, if it is determined that the Company was
not prudent in its management of coal supply.

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6. Staff also states they were made aware of coal dispatch issues at the Jim Bridger
plant during 2022 by Idaho Power. Staff expresses deep concern that PacifiCorp did not disclose
this in the Company’s production request responses.
7. The Company respectfully disagrees with the necessity of a six-month
investigation, as Staff has already conducted a comprehensive investigation, and the existing
record provides a clear explanation of the coal supply challenges faced by the Company.
PacifiCorp dispatched its coal units in 2022 in accordance with prudent utility practice, ensuring
the maintenance of an adequate coal stockpile and consistent with least-cost economic dispatch
principles. Moreover, the Company believes that there may be a misunderstanding regarding the
coal dispatch at the Jim Bridger plant. Accordingly, the Company requests that the Commission
deny Staff’s request for additional process in this proceeding and approve the 2022 ECAM deferral
as prudently incurred.
i) Coal Acquisition Process
8. As an initial matter, the Company believes it would be beneficial to provide an
overview of its coal acquisition process before delving into the operational details of the 2022
calendar year. Staff has requested a report from the Company, outlining the forecasted 2022 load
and its plan to meet this requirement at the least-cost to customers prior to the 2022 ECAM year.
It is important to note that PacifiCorp operates on a least cost basis and does not rely on a
weather-normalized forecast such as one prepared to set base NPC in a general rate case. It is
essential to understand that each hour, day, or season presents unique conditions that differ from
the weather normalized rate case forecast. These differences arise due to changes in market
conditions, including market prices, load demand, hydroelectric generation, wind generation and

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solar generation. Consequently, the variance between forecast and actual conditions largely
accounts for the difference between forecast and actual NPC.
9. Base NPC in the ECAM was established in the Company’s most recent rate case,
(“2021 Rate Case”).1 The test period for this case was based on the historical twelve-month period
ending December 31, 2020, with adjustments made for known and measurable changes through
December 31, 2021. As determined in the 2021 Rate Case, the total-Company base NPC was set
at $1.368 billion.
10. In the 2021 Rate Case, the calendar year 2021 load forecast was an input to
determine the base NPC. This load forecast was a weather-normalized projection created in the
spring of 2020 but was only one of many load forecasts across time that the Company has used to
forecast coal plant generation and acquire fuel in a manner that benefits customers. To better
understand the Company’s fuel supply planning process, a brief outline of the planning conditions
are presented below.
11. PacifiCorp’s goal in fuel supply planning is securing the least-cost and least-risk
fuel supply for customers. To achieve this, the Company follows a comprehensive fuel supply
planning process. It begins with estimating the annual and future generation forecast of the plants,
considering many factors including historical usage patterns, sales and load forecasts, market
prices, changes in available generation, operating lives, and reliability requirements. Subsequently,
the Company then develops fuel volume, pricing, and sourcing assumptions, as well as
transportation costs. If applicable, operating and capital costs for the plant are considered. In cases
where a plant is supplied by a dedicated, jointly owned mine, PacifiCorp collaborates with other

1 In the Matter of the Application of Rocky Mountain Power for Authority to Increase its Rates and Charges in
Idaho and Approval of Proposed Electric Service Schedules and Regulations. Docket No. PAC-E-21-07.

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owners to develop a mine plan to support the long-term fueling forecast. All costs from all sources
are combined and evaluated to establish a fueling plan that is least-cost and least-risk.
12. PacifiCorp negotiates with third-party suppliers to secure fuel contracts to meet its
generation forecasts in a manner that is least-cost and least-risk. The Company’s process for
developing and negotiating these contracts considers a range of important factors, including
contract term, price, volume, supplier credit worthiness, plant location or coal region, coal supply
options, coal transportation options, and coal quality. It is important to note that coal contracts can
vary in length and are often renewed or replaced on a rolling basis. The forecasts used for one
contract may differ from those used for another contract executed on a different date. Furthermore,
subsequent contracts are often negotiated during different market conditions, given the
ever-changing nature of the coal market.
13. It is also important to recognize that coal quality specifications vary across different
regions, and transportation costs play a significant role in the overall fuel procurement process.
Moreover, PacifiCorp’s coal plants are situated in diverse geographic locations throughout the
western U.S. in strategic locations, typically adjacent to or near coal sources to minimize
transportation costs. This diversity serves to reduce overall system risk since there may be
locations where transportation, labor, or supplies may be limited for a given time yet other
locations may not have those same limitations. Given these factors, PacifiCorp considers term,
price, volume, and coal quality when negotiating third-party coal supply agreements and seeks to
strike the optimum balance among these factors. Negotiations for bilateral coal supply agreements
are specific to the individual plant, mine or mines that can serve the plant, transportation
requirements, and overall coal market.

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14. Coal supply contracts play a vital role in ensuring reliable and uninterrupted supply
of coal will be available to fuel the Company’s plants at known and predictable prices, terms, and
conditions. In contrast, relying solely on spot market purchases to supply its plants poses
significant risks. Relying exclusively on the spot market is an extremely risky strategy because it
would expose customers to substantial and unreasonable price and supply risk, especially in the
illiquid markets in which most of PacifiCorp’s coal plants are located. On the other hand,
multi-year contracts significantly reduce the risk to customers associated with market price
volatility or fluctuations. It is also critical to emphasize that without the security of fuel supply
contracts, there may be an elevated risk of fuel shortages during certain times of the year.
15. The request made by Staff for a load forecast and a corresponding planning process
assumes that the Company procures all its coal purchases for the 2022 calendar year, based solely
on a single forecast. However, this does not accurately reflect the Company’s approach to securing
coal for its power plants. PacifiCorp maintains that Staff’s request for a load forecast and a specific
planning process is not the most effective approach for evaluating a complex and ever-evolving
planning process. During their visit to PacifiCorp’s office in Salt Lake City, Staff had the
opportunity to review all of the Company’s coal contracts. The Staff visits to the Company offices
have been done for many years, with the exception of a virtual presentations during the pandemic,
and the Company appreciates the opportunity to meet with Staff in person and present the coal
contracts. The Company has cooperated fully by providing Staff with all the necessary documents
to assess whether the Company made prudent decisions at the time of signing those contracts,
taking into account the preparation made for the 2022 fuel year.

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ii) Jim Bridger Coal Supply
16. Staff claims that the Company did not disclose coal supply issues at the Jim Bridger
plant in 2022, and only learned about such issues from Idaho Power Company. Based upon
discussions with and information obtained from Idaho Power, Staff incorrectly speculates that
PacifiCorp faced the exact same coal supply challenges that Idaho Power experienced at Jim
Bridger plant in 2022. PacifiCorp did not reduce generation at the Bridger plant during 2022 due
to a lack of coal supply. PacifiCorp’s minimum stockpile reliability target for 2022 was deemed to
be 530,000 tons or 45 days of expected consumption of 4.3 million tons. As illustrated in Table 1
below, PacifiCorp’s inventory stockpile at Jim Bridger exceeded that target throughout 2022.
Table 1: 2022 Jim Bridger Coal Inventory

17. As 67 percent owner of the Bridger plant, PacifiCorp is responsible for supplying
its ownership portion of the coal at the plant. PacifiCorp prudently managed its inventory in 2022
by beginning the year with just over one million tons of coal which equated to 78 percent of the
coal at the plant. It ended the year with a supply of approximately 719,000 tons which equated to
90 percent of the coal inventory. PacifiCorp entered 2022 with enough coal to be able to draw from
2022 Tons
Consumed
Beginning
Inventory as
Expected
Days Burn
Ending
Inventory as
Expected
Days Burn
Tons %Tons %
PacifiCorp 1,008,008 78% 718,623 90% 4,215,793 86 61
Idaho Power 276,559 22% 79,160 10% 1,885,327 54 15
Total Plant 1,284,567 100% 797,783 100% 6,101,120 76 47
Jim Bridger Plant Inventory
12/31/2021 12/31/2022
Note: PacifiCorp's Days Burn is calculated using Expected 2022 Consumption of 4.3
million tons. Idaho Power's Days Burn is calculated using actual 2022 consumption.
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its coal stockpile without placing inventory at a level that could jeopardize reliability for its
customers. As shown above, PacifiCorp’s coal inventory exceeded its minimum stockpile
reliability target of 45 days of inventory throughout 2022. There was no need for PacifiCorp to
reduce generation at the Bridger plant in 2022 to conserve coal. Thus, PacifiCorp did not reduce
generation in 2022 to conserve coal inventory at the Bridger plant. As shown in Confidential Table
2 below, the coal supply shortfall experienced at Jim Bridger did not reach a level critical enough
for PacifiCorp to take measures to reduce generation in 2022.
Confidential Table 2: 2022 Jim Bridger Coal Supply (PacifiCorp Share)
18.It is important to recognize the distinction between the situations faced by
PacifiCorp and Idaho Power in 2022 concerning coal supply issues and the resulting generation
curtailment at the Jim Bridger plant. Through proactively managing coal supply, PacifiCorp
successfully avoided the need to reduce generation to ensure an adequate coal stockpile to meet
reliability standards. Specifically, PacifiCorp took the following actions to ensure an adequate coal
supply at Jim Bridger for the relevant time-period:
In August 2022, PacifiCorp directed the plant to begin using coal permitted for long-term
storage. A total of 407,395 tons (shared between PacifiCorp and Idaho Power) were
consumed from the long-term storage pile in 2022.
Plant Supplier
Budgeted
Tons
Delivered
Tons Variance Explanation
Bridger Bridger Coal Company 2,653,333 2,648,039 (5,294)
Black Butte Coal Company 1,278,948
3,926,987
REDACTED

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 In September 2022, PacifiCorp issued a request for proposals (RFP) to Powder River Basin
(PRB) coal suppliers for future deliveries to the plant, specifically targeting deliveries for
the fourth quarter of 2022 and 2023.
 In September 2022, PacifiCorp initiated discussions with Union Pacific railroad regarding
the delivery of PRB coal to the plant. These discussions aimed to ensure reliable
transportation and delivery of the required coal to Jim Bridger.
 PacifiCorp also embarked on a search to lease 120 coal railcars, further demonstrating its
commitment to securing adequate transportation resources for coal deliveries.
19. These proactive actions ultimately led to the successful delivery of PRB coal to the
Jim Bridger plant, commencing in April 2023. By taking these steps, PacifiCorp effectively
managed its coal supply and ensured the availability of coal for the Jim Bridger plant and the
benefit of customers. These measures highlight PacifiCorp's proactive approach to addressing the
unprecedented coal supply challenges that occurred in 2022 while maintaining reliable generation.
Please note that although PacifiCorp did not limit generation to conserve coal inventory at Jim
Bridger in 2022, the Company did limit generation between January 2023 and April 2023 to ration
coal for the summer months of 2023 when the value of Jim Bridger generation is expected to be
significantly higher and power market rates are typically elevated.
20. Of note, the total installed capacity of coal and wind resources in Wyoming is
greater than the transmission capacity available to move that total coal and wind generation out of
the region to serve system load. Consequently, coal generation competes with wind generation for
available transmission capacity and the reduction in Wyoming coal generation in calendar year
2022 is partially attributable to this dynamic. From calendar year 2021 to calendar year 2022, the
generation from Company-owned Wyoming wind increased by approximately 760,000 MWh and

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the generation from Company-owned Wyoming coal inversely decreased by approximately
740,000 MWh. Of that 740,000 MWh decrease in Wyoming coal generation, replaced by
zero-cost fuel wind generation, Jim Bridger accounted for approximately 400,000 MWh.
Additionally, the decrease in Jim Bridger fuel costs from 2021 to 2022 is $13.5 million while the
total-Company increase in PTC benefits from Wyoming wind facilities from 2021 to 2022 is $25.2
million.
iii) Utah Coal Supply
20. PacifiCorp’s coal suppliers in Utah encountered production difficulties due to
various challenges in 2022, including geological, logistical, and financial issues. Mine operators
saw production constraints caused by unfavorable geologic conditions, labor shortages,
transportation limitations, and financing and solvency problems. In response, the coal suppliers
invoked force majeure claims under coal supply agreements. Notably, the Lila Canyon mine, which
produced roughly 25% of the State of Utah’s coal in the last few years, stopped operations in
September 2022 due to a mine fire, leading to extensive damage and reconstruction delays.
Confidential Exhibit No. 4, attached to these reply comments, provides the Force Majeure claims
received by PacifiCorp from the two coal suppliers to the Hunter and Huntington coal plants.
Specifically, the Company received a force majeure claim from Bronco Utah Operations, LLC on
June 22, 2022, and Wolverine Fuels, LLC on September 22, 2022.
21. As illustrated in Table 3 below, PacifiCorp’s began 2022 with 132 days of inventory
at the Utah plants based upon expected consumption of 7.0 million tons.

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Table 3: 2022 Utah Plants (Hunter and Huntington) Coal Inventory

22. PacifiCorp determined the minimum stockpile reliability target for Huntington to
be 380,000 tons or approximately 45 days of expected consumption of 3.0 million tons. Similarly,
PacifiCorp determined the minimum stockpile reliability target for Hunter to be 500,000 tons or
approximately 45 days of expected consumption of 4.0 million tons. The data provided in
Confidential Table 4 below details the impact of the force majeure claims on total 2022 coal
deliveries at the Hunter and Huntington plants.
2022 Tons
Consumed
Beginning
Inventory as
Expected
Days Burn
Ending
Inventory as
Expected
Days Burn
Tons Tons
Hunter 1,243,842 514,358 3,303,195 114 47
Huntington 473,092 436,165 2,520,067 58 53
5,823,262
Rock Garden
Transferred
to Huntington
Safety Pile 817,837 298,796 519,041 100 36
Total Utah 2,534,771 1,249,319 132 65
Utah Plants Inventory
12/31/2021 12/31/2022

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Confidential Table 4: 2022 Hunter and Huntington Plants Coal Supply

23. It is worth highlighting that the Hunter and Huntington plants have operated by
relying on coal sourced from nearby mines, and the transportation of coal has been efficiently
facilitated through trucking. However, Utah plants currently lack rail infrastructure for receiving
coal from other coal basins. This limitation in rail infrastructure restricts PacifiCorp’s ability to
procure coal outside of the state of Utah.
24. Upon learning of the supply constraints, PacifiCorp immediately began
transporting coal from the Rock Garden safety pile for consumption at the Huntington plant to
compensate for reduced coal deliveries.
25. In addition, the Company began working with current suppliers to secure additional
coal and exploring alternative coal sources. In the third quarter of 2022, an RFP was issued to
identify new sources of coal supply, and collaboration with a co-owner of the Hunter plant resulted
in the acquisition of additional coal from one of their mines.
26. Due to the force majeure events illustrated in Table 4, PacifiCorp also began
reducing generation at the Hunter plant in September 2022 and at the Huntington plant in
November 2022 in order to maintain the minimum stockpile reliability target of 45 days inventory.
Accordingly, and based upon industry standard practice regarding the dispatch of fuel limited
Plant Supplier
Tons
Under
Contract
Tons
Delivered Variance Explanation
Hunter Wolverine 1,831,679
Bronco 727,689
Other 14,343 14,343
2,573,711
Huntington Wolverine 1,966,980
Total 4,540,691
REDACTED

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resources (example - hydro), PacifiCorp calculated the dispatch price for the fuel limited Hunter
and Huntington units to maintain minimum stockpile reliability coal inventories and secure
availability for the benefit of customers during critical periods. The dispatch price for these units
was calculated, to ensure an adequate coal stockpile, at $50-$70 per MWh at Hunter in September
and later in November at Huntington. By the end of 2022, the price was recalculated to
approximately $90 per MWh. The higher dispatch prices ensure the optimization models do not
lower inventory to unacceptable levels. PacifiCorp’s decision to calculate the dispatch price based
on the economics of fuel-limited resources reflect its commitment to upholding reliability
standards; ensuring the availability of coal units when they are most needed. Although this
calculation rendered the units less economically favorable to dispatch within the operational
optimization model in late 2022, it was necessary to maintain a prudent coal stockpile level, in the
aftermath of the unprecedented force majeure claims made by the units two coal suppliers, and to
ensure reliability during high-demand periods.
27. Therefore, PacifiCorp maintains that the lower coal generation dispatch noted by
Staff was simply reflective of prudent utility practice to maintain system reliability in the aftermath
of unprecedented events that occurred in 2022 and the outcome dictated by industry standard
optimization software and the CAISO market optimization software. The traders, in tandem with
the optimization software, took into consideration all relevant factors in determining the economic
dispatch of PacifiCorp's coal units during 2022, ensuring the most efficient and cost-effective
fulfillment of system obligations. Based on the foregoing, PacifiCorp respectfully requests that the
Commission deny Staff's request for additional process and approve the 2022 ECAM deferral as
prudent.

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iv) Economic Dispatch of Coal Plants
28. In response to Staff's request for a six-month investigation into PacifiCorp's
economic dispatch of its coal units, the Company believes that such an investigation is
unwarranted. PacifiCorp relies on a least cost optimization model to ensure the cost-effective
fulfillment of its system obligations. This optimization model takes into consideration various
factors such as load resource balance, generator characteristics, system obligations, fuel supply,
and transmission limits to determine the most efficient unit dispatch schedule. Due to expected
variations between input forecasts and actual real-time operating conditions, market traders use
the modeled results as a guide when making decisions on how to best economically serve the
system obligations. This approach enables PacifiCorp to economically meet its obligations through
coal generation, other resources, or market purchases.
29. Regarding the economic dispatch of coal units in 2022, PacifiCorp's least cost
optimization model and the CAISO Energy Imbalance Market (EIM) optimization model
accounted for the challenges related to coal supply that were discussed above in the economic
dispatch of coal generating units. The year witnessed historically low coal inventories and surging
natural gas prices, necessitating increased coal purchases to meet immediate consumption needs
and replenish depleted inventories.
B. P4’s Comments:
30. P4 had concerns similar to those by Staff regarding the coal generation levels for
2022. Additionally, P4 has requested a detailed discussion on the costs of short-term purchases in
relation to the coal expense. P4 seeks an explanation of the Company’s ability to generate
electricity from its coal units considering such factors as forced outages, scheduled maintenance,
and operating constraints. It is important to note that the Company has already addressed these

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matters in discovery responses, including the Company’s response to Staff audit request 6, which
has been provided to P4. In the Company’s response to that data response, the Company detailed
the forced and maintenance outages longer than 72 hours and derates at 50 percent or more of net
capacity and longer than 72 hours.
III. CONFIDENTIAL INFORMATION
31. This filing contains information that is Confidential and/or constitutes Trade
Secrets as defined by Idaho Code Section 74-101, et seq. and 48-801 and protected under IDAPA
31.01.01.067 and 31.01.01.233. Specifically, the contracted coal amounts on Table 2 and Table 4
contain Company proprietary information that could be used to its commercial disadvantage.
IV. REQUEST FOR RELIEF
32. The ECAM deferral of $32.4 million, including interest, for calendar year 2022,
was accurately calculated in compliance with previous Commission orders. The Company believes
the record is complete and shows that the Company prudently managed its coal supply and
dispatched is coal plants, and additional reporting is not necessary or likely to enhance the record.
Based on the foregoing, the Company respectfully requests that the Commission approve this
application as filed with rates effective June 1, 2023.
33. However, in the event that the Commission determines that further processes are
required in this proceeding, the Company proposes not to accept Staff's proposal for a six-month
investigation. Instead, the Company recommends that the Commission allow for an additional
one-month for the process in this proceeding. PacifiCorp believes that an additional six-month
process is unduly burdensome and unnecessary, given the clear evidence presented in this
proceeding, which demonstrates the Company's efficient dispatch of its coal units, proactive
handling of coal supply issues, and maintenance of an adequate coal stockpile for reliability

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purposes in 2022. During this additional one-month process, the Company commits to working
closely with Staff, providing any additional information requested, and granting access to any
Company subject matter experts necessary to facilitate Staff's recommendation on the 2022 ECAM
deferral. Following this one-month extension, the Company requests that Schedule 94 rates be
effective from July 1, 2023. However, if the Commission determines that more time is required
beyond this proposed one-month process, the Company requests that the Commission issue an
interim order2 approving the 2022 ECAM Deferral with the proposed Schedule 94 rates, effective
from June 1, 2023, pending the completion of the additional process.

DATED this 17th day of May 2023.

Respectfully submitted,
ROCKY MOUNTAIN POWER

__________________________
Joe Dallas (ISB# 10330)
PacifiCorp, Senior Attorney
825 NE Multnomah Street, Suite 2000
Portland, OR 97232
Email: [e-mail]
Attorney for Rocky Mountain Power

2 Grindstone Butte Mut. Canal Co. v. Idaho Power Co., 98 Idaho 860, 574 P.2d 902 (1978) (“Although no statute
gives explicit authority to Public Utilities Commission to enter “interim” or “temporary” orders, Commission has
authority to enter such orders given statutory mandate that Commission continue to evaluate rates charged and make
changes as necessary, for implied in directive of on-going investigation is power to make orders effecting rates that
are temporary in nature.”).
Confidential
Exhibit No. 4
THIS ATTACHMENT IS CONFIDENTIAL IN ITS
ENTIRETY AND IS PROVIDED UNDER SEPARATE
COVER