20230510Comments.pdf

DAYN HARDIE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE,IDAHO 83720-0074
[phone]
IDAHO BAR NO.9917
Street Address for Express Mail:
11331 W CHINDEN BVLD,BLDG 8,SUITE 201-A
BOISE,ID 83714
Attorneyfor the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF ROCKY MOUNTAIN )POWER'S APPLICATION REQUESTING )CASE NO.PAC-E-23-09
APPROVAL OF $32.5 MILLION ECAM )DEFERRAL )COMMENTS OF THE
)COMMISSION STAFF
STAFF OF the Idaho Public Utilities Commission,by and through its Attorney of record,
Dayn Hardie,Deputy Attorney General,submits the followingcomments.
BACKGROUND
On March 30,2023,PacifiCorp dba Rocky Mountain Power ("Company")applied for
authorization to adjust its rates under the Energy Cost Adjustment Mechanism ("ECAM").The
Company seeks an order approving approximately $32.5 million in ECAM deferred costs and a
2.3%increase to Electric Service Schedule No.94,Energy Cost Adjustment ("Schedule 94").
The monthly bill of an average residential customer using 783 kilowatt-hours of electricity
would increase by about $1.57.The Company requests its proposed adjustment be processed by
Modified Procedure and become effective on June 1,2023.
The ECAM allows the Company to increase or decrease its rates each year to reflect
changes in the Company's power supply costs.These costs vary by year with changes in the
Company's fuel (gas and coal)costs,surplus power sales,power purchases,and associated
STAFF COMMENTS 1 MAY 10,2023
transmission costs.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 an increase or decrease in customer rates.Neither the Company nor
its shareholders will receive any financial return because of this filing.
Besides the NPC difference,this year's ECAM includes:(1)the Load Change
Adjustment Revenues ("LCAR");(2)an adjustment for coal stripping costs;'(3)a true-up of
100%of the incremental Renewable Energy Credit revenues ("REC");(4)Production Tax
Credits;(5)reasonable energy price ("REP")qualified facility ("QF")adjustment;2 (6)wind
liquidation damages;and (7)interest on deferral.
With its Application,the Company seeks an order approving the Company's:(1)request
for a $32.5 million ECAM deferral;and (2)a 2.3%increase for Schedule 94.The Company
states that if its proposal is approved,prices for customer classes would increase as follows:
Residential Schedule 1 -(1.6%)
Residential Schedule 36,Optional Time-of-Day Service -(1.9%)
General Service Schedule 6 -(2.3%)
General Service Schedule 9 -(2.9%)
Irrigation Customers -(2.1%)
General Service Schedule 23 -(2.0%)
General Service Schedule 35 -(2.2%)
Public Street Lighting -(1.1%)
Tariff Contract,Schedule 400 -(3.0%)
Application,Meredith Direct,Exhibit No.2.
'The ECAM includes a "90/10 sharing band"in which customers pay/receive 90%of the increase/decrease in thedifferencebetweenactualNPCandbaseNPC,LCAR,and the coal stripping costs;and the Company incurs/retainstheremaining10%.
2 The REP QF adjustment flows from the 2020 Inter-Jurisdictional Allocation Protocol where,during the InterimPeriod,"energy output of New QF PPAs will be dynamically allocated ...using the SG Factor,priced at a
forecasted [REP]...and any cost of a New QF PPA above the forecasted [REP]will be situs assigned and allocatedtotheStateofOrigin."Direct Testimony of Jack Painter at 10;Order No.34640.
STAFF COMMENTS 2 MAY 10,2023
STAFF ANALYSIS
ECAM Calculation
Staff verified the Company's method for calculating the ECAM complies with previous
Commission orders.Staff further verified that the Company used accurate actual loads,actual
costs incurred,and revenues received,and applied the correct loads,costs,and revenues
embedded in base rates.Based on its review,Staff believes the Company's ECAM deferral
balance properly accounts for the difference between energy costs and revenues included in base
rates and the actual costs and revenues during 2022.Staff recommends the Commission
authorize the 2022 ECAM deferral as shown below:
Table No.1:Deferred ECAM Balance
NPC Differential for Deferral $35,322,826
EITF 04-6 Adjustment 190,656
LCAR (1,578,588)
Total Deferral Before Sharing 33,934,894
Sharing Band 90%
Customer Responsibility 30,541,405
Production Tax Credits 1,388,020
REP QF Adjustment 634,305
Wind Liquidated Damages (295,039)
REC Deferral (130,679)
Interest on Deferral 326,544
Annual Deferral (Jan -Dec 2022)32,464,556
Unamortized Previous Balance 29,925,543
Total ECAM Rider Revenues (20,448,621)
Total Company Recovery $41,941,478
Staff reviewed the Company's external audit reports,journal entries,invoices,contracts,
and customer bills.Staff also reviewed the Company's adjustments to actual costs and
reconciled the general ledger amounts to the NPC provided in Company Exhibit No.1.
STAFF COMMENTS 3 MAY 10,2023
Additionally,Staff reviewed the Company's hedge contracts and policies and believes these
mechanisms reasonably safeguard price and fuel stability.Staff also reviewed transactions and
invoices for Energy Imbalance Market ("EIM")revenues.Finally,Staff reviewed the Resource
Tracking Mechanism ("RTM")adjustment calculations included in the ECAM.Staff concludes
that the ECAM deferral shown in Table No.1 is accurate and complies with ECAM orders.
Net Power Cost Deferral
The NPC adjustment within the ECAM allows the Company to collect or credit the
difference between NPC incurred to serve customers in Idaho and the NPC collected from Idaho
customers through base rates during the deferral period.In Order No.35277,the NPC embedded
in rates was set at $24.54 per megawatt hour ("MWh").
The revenue collected through base rates is calculated by multiplying$24.54 by
3,706,984 MWh of actual Idaho sales,for a total of $90.9 million.The difference between base
rate revenue and Idaho's share of actual 2022 NPC of $126.3 million,leaves an under-collected
balance of $35.3 million.The under-collected balance is subject to a 90/10 customer sharing
band,with the Company paying 10%of the NPC balance.3 After removing the Company's 10%,
the amount customers are responsible for through Schedule 94 rates is $30.5 million.
Emergine Issues Taskforce ("EITF")
The EITF 04-6 adjustment is the difference between coal stripping costs the Company
incurred and recorded,as stated in the accounting pronouncement EITF 04-6,and the
amortization approved by Order No.30987 in Case No.PAC-E-09-08.The Company uses this
account to "undo"the effects of EITF 04-6 that requires the Company to expense coal stripping
costs opposed to amortizing it over the coal produced from the section of open mines.The
adjustment decreases the deferral by $190,656.Staff reviewed the adjustment and believes it
was accurately calculated.
3 Under the 90/10 sharing band customers pay 90%of the under-collected balances and the Company pays the
remaining 10%.For over-collected balances,customers receive 90%of the benefit and the Company keeps 10%.
STAFF COMMENTS 4 MAY 10,2023
Load Change Adjustment Revenues
Staff believes the Company's LCAR adjustment complies with Order No.35277.The
LCAR adjusts for the under-or over-recovery of fixed energy-classifiedproduction cost
(excluding NPC)resulting from the difference between Idaho sales used to determine base rates
and the sales from the deferral year.The LCAR of $8.74 per MWh was set in Case No.PAC-E-
21-07.Multiplyingthe LCAR by the actual Idaho sales of 3,706,984 MWh shows that the
Company collected $32.4 million of energy-classified fixed production costs through base rates.
The $1.5 million difference between the actual energy-classified fixed production costs collected
and the $30.8 million embedded in base rates will be returned to customers by offsetting the
ECAM deferral.
Lake Side 2 Resource Adder
In Order No.32910,the Commission approved a stipulation wherein the parties to that
case agreed the Company could recover its investment in the Lake Side 2 generationfacility
through the ECAM until its investment was included in base rates.In the Company's recent
general rate case,Case No.PAC-E-21-07-rates effective January 1,2022-Lake Side 2's
recovery was moved into base rates and is no longer included in the ECAM.
Production Tax Credits ("PTC")
In Order No.33440,the Commission approved a settlement in Case No.PAC-E-15-09
that moved the PTC true-up to the ECAM,with a $1.99 per MWh benefit to customers included
in base rates.In Order No.35277 the Commission approveda settlement increasing the PTC to
$4.16 per MWh.In 2022,base rates included a $15.5 million benefit from PTCs;however,the
actual PTCs allocated to Idaho customers in 2022 was $14.1 million.The $1.4 million
difference between the PTCs in base rates and the actual PTCs is a surcharge to the customers.
Compared to last year's PTCs,this is a significant decrease to the number of PTCs the Company
received.
RTM Adjustment
In Order No.33954,the Commission approved a stipulation allowing the Company to
recover costs related to wind repowering projects throughthe ECAM.After the Company's most
STAFF COMMENTS 5 MAY 10,2023
recent general rate case,Case No.PAC-E-21-07 with rates effective January 1,2022,the
recovery of costs for these wind repowering projects moved into base rates so they are no longer
included in the ECAM.
Reasonable Energy Price QF Adjustment
The 2020 Protocol,approvedby Order No.34640,included a provision that all QF
contracts approved in 2020 and after would be subject to a reasonable price adjustment.The
amount the Company paid for energy under each QF contract over a reasonable energy price
would be SITUS allocated to the state that approvedthe QF contract.Painter Di.at 10.
In this case,there are 11 contracts requiring comparison for the reasonable energy price
QF adjustment-withfour incurringa SITUS allocation adjustment to Idaho.Staff reviewed the
process for creating the reasonable energy price and the energy price for those contracts and Staff
believes it complies with the 2020 Protocol.The reasonable energy price QF adjustment results
in a $634,305 increase to the deferral to Idaho.
Renewable Energy Credits ("REC")
In Order No.35277,the Commission approved $0.07 per MWh in REC revenues to be
included in base rates.The difference between the embedded amount and actual REC revenue is
trued-up in the ECAM.In 2022,base rates included $253,744 in benefits from REC revenues.
Idaho's share of the Company's actual REC revenues was $384,423.The difference of $130,679
offsets the deferral balance.
Wind Availability Liquidated Damages
The Company has included a $295,039 credit to customers for a wind availability
liquidated damages credit.In the stipulation approved in Order No.33954,Case No.PAC-E-17-
06,the Company agreed to pass on all liquidated damages received from suppliers in case the
repowered equipment does not meet the specifications required.The Company allocated
liquidated damages by the system generation ("SG")factor and then applied that credit to
customers.Staff reviewed the supporting documentation provided by the Company and agrees
with the inclusion of this reduction to NPC.
STAFF COMMENTS 6 MAY 10,2023
Analysis of Actual NPC
Staff reviewed the Application,exhibits,and testimony to identify and understand the
various contributors to this years'higher levels of actual NPC,compared to the base amount set
to be recovered through rates during the 2022 deferral period.The 2022 annual ECAM deferral
of $32.5 million is the largest ever requested for recovery in Idaho.On a total Company basis,
actual NPC for 2022 increased 47.5%to $2.02 billion.For Idaho,the allocated actual NPC was
45.9%above the amount recovered in base rates.The Company's base rates were reset by the
Commission in Case No.PAC-E-21-07,with the new base rates going into effect on January 1,
2022.
There are indications that the root cause for the high actual NPC is attributed to a lack of
coal generation due to a shortage of coal supply.Staff recommends the Commission withhold its
decision on whether actual NPC attributed to the 2022 ECAM deferral is prudent,but allow
actual NPC included in the filing to be used to calculate the ECAM deferral and Schedule 94
rates.Staff also recommends the Company provide the Commission and customers a full
accounting of the issues causing the extraordinarilyhigh NPC,with a focus on the lack of coal
generationand coal supplies,by directing the Company to perform a full investigation starting
with a comprehensive report from the Company within six months of the Commission's final
order.
Under Staff's proposal,this report would comprehensively assess events and factors that
contributed to the inability of the Company to dispatch its coal plants to meet native load and to
dispatch into the market by providing a detailed analysis of the factors,impacts,and actions
taken by the Company leading up to and during the 2022 ECAM year.Following submission,
Staff believes the Commission should direct Staff to review and assess the results of this report
and recommend to the Commission whether any subsequent adjustment should be made in the
balancing account in next year's ECAM filing.This report should include,but not be limited to,
the items listed below:
1.Provide past details of the Company's forecasted 2022 load and how the
Company planned to meet this load requirement at a least-cost to customers prior
to the 2022 ECAM year;
2.For each coal plant,if shortages occurred,provide an analysis and a timeline of
events such as decisions and actions taken by the Company relative to coal supply
STAFF COMMENTS 7 MAY 10,2023
contracts or investments in coal mines to maintain coal supply leading up to
shortages in coal supply and the inability to dispatch coal plants that occurred
during the ECAM year;
3.List issues that occurred during the ECAM year (high natural gas cost,lack of
hydro generation,high market prices,etc.)which caused the significant increase
to NPC and for each,provide:
a.A full explanation of the issue and how lack of coal generation factored into
the issue;and
b.The cost impact of the issue and how much of the impact could have been
mitigated if coal generation was available.
4.For each coal plant,if shortages occurred,provide an analysis that traces and
compares the Company's coal generation forecasts and the corresponding coal
supply orders and deliveries starting in January 2021 to the present documenting
who was aware of any shortfall between the two,and when;
5.For each coal plant,if shortages occurred,discuss alternativesthe Company
considered,decisions made,and action plans taken (with dates and action owners)
to either acquire additional coal supply,or mitigate the impact of a lack of coal
supply;
6.For each coal plant,if shortages occurred,discuss and fully explain what the
Company will be doing differentlyin the future to maintain operation of its coal
plants needed to meet delivery of electricity at least cost to customers;and
7.Provide an appendix to the report with documents that supports the Company's
analysis and provides evidence showing what the Company knew,and when they
knew it.
Root Cause Analysis
Staff believes that the cause of high actual NPC in this year's ECAM was due to the
Company's inability to dispatch its coal plants,while required to dispatch its higher cost natural
gas plants and purchase higher cost market power in order to meet its load obligations.Staff's
conclusion,is based on four types of analysis:
STAFF COMMENTS 8 MAY 10,2023
1.A comparison of costs used to determine NPC in base rates to actual cost broken
down by sources the Company uses to meet load;
2.A comparison of the amount of generation from each source used to determine
NPC in base rates versus the amount of generation used to meet load during the
ECAM year;
3.A comparison of the actual monthlyamounts of coal generationacross the 2022
ECAM year to historical amounts;and
4.Information contained in discovery and from other sources to identify the root
cause leading to lack of coal generation.
Staff compared 2022 actual NPC by FERC account/resource type to NPC embedded in
base rates,as shown in Table No.2 below.It illustrates the impact of actual NPC on the deferral
amount with positive amounts showing an increase in the deferral and negative amounts showing
a decrease.
Table No.2:
Adjusted Impact to PercentageSourceBaseNPC4
Actual NPC Deferral Impact
Wholesale Sales (revenue)($285,405,303)($463,692,258)$178,286,9556 38.4%
Purchased Power /Net $942,771,832 $844,451,804 $98,320,028 11.6%Interchange (cost)
Wheeling (cost)$164,088,727 $154,137,105 $9,951,622 6.5%
Coal (cost)$581,031,513 $599,876,421 ($18,844,908)-3.1%
Gas (cost)$610,525,466 $228,727,764 $381,797,702 166.9%
Other -Primarily Wind $5,382,209 $4,416,584 $965,625 21.9%(cost)
Total System $2,018,394,444 $1,367,917,419 $650,477,024 47.6%
Examining Table No.2,the largest impacts to the deferral amount in order of magnitude
is the increase in natural gas generation,a reduction in the amount of wholesale sales revenue,
and an increase in purchased power expense.However,there is a significant reduction in the
4 Referenced to Case No.PAC-E-21-07 PacifiCorp -General Rate Case.
6 The positive amount for the wholesale sales base-to-actual difference represents a reduction in revenue from thetotalactualamountofsalesrelativetothebaseamounts;whereas positive amounts for base-to-actual cost
components represent increases in actual cost as compared to base amounts.
STAFF COMMENTS 9 (REPLACEMENTPAGE)MAY 15,2023
amount of coal generation cost.This is not the expected result since the Company should
dispatch its coal plants more,especially since the average unit cost of coal was $20.47/MWh
during the ECAM year while the unit cost of natural gas generation was $44.61/MWh (65.5%
higher than unit cost in the base)and the cost of market purchases was $65.03/MWh (40.8%
higher than the amount in the base).It is possible that the increase in overall NPC could be
solely attributed to higher natural gas prices and higher market purchase prices and that the
Company utilized its coal plants to their fullest potential to reduce costs.However,Staff does
not believe this was the case.
To verify this conclusion,Staff compared the amount of generationfrom each of its
sources to the amounts used to determine base rates as illustrated in Figure No.1 below.
Figure No.1:
GENERATION RESOURCE PERCENTAGES (2022 ECAM VERSUS BASE)
2022 ECAM,OTHER
GENERATION,11 2%
2022 ECAM,PUREHASED POWER
AND NE T INTERCHANGE,21 4%
2022 ECAM,HYDRO
GENERATION
11,7%
26.495
12 3%GENERALRATE CASE
PAC-E-21-07 BASE
2022 ECAM.COAL GENERATION.
42.5%
As illustrated above,the Company produced 0.7%(43.2%minus 42.5%)less coal
generation,or about 1,484 Gigawatt-hours ("GWh")less during the ECAM year as compared to
STAFF COMMENTS 10 MAY 10,2023
the amount of generation assumed in base rates.It is likelythis is a conservativeamount since it
is highly likely that the Company's coal plants were not fully utilized in the Company's model
used to determine base rate NPC.In fact,the model would have reflected even more coal
generation if market prices assumed in the model were as high as they actually were during the
ECAM year.This analysis provides a strong indication that the Company was not able to
dispatch its coal plants fully to reduce the high cost of natural gas generationand market
purchases during the ECAM year.
To further verify that the Company did not fully utilize its coal plants,Staff compared the
actual monthlyamounts of coal generationacross the 2022 ECAM year to the actual amount of
generation in 2021 and the average over five years as illustrated in Figure No.2 below.
Figure No.2:
COAL (TOTAL)-MONTHL¥GENERATION (MWH)
As can be seen from Figure No.2 above,the amount of actual generation was
consistently below the generationamounts from previous years confirming Staff's belief that the
Company was not able to dispatch its coal plants fully to reduce actual NPC during the 2022
ECAM year.These results also explain why the Company was not able to dispatch its coal
plants fully to dispatch more into the market contributing to the 38.4%reduction in Wholesale
Sales revenue,which was the second largest component of the large deferral balance.
STAFF COMMENTS 11 MAY 10,2023
To determine the root cause why the Company did not economically dispatch its coal
plants fully to reduce NPC,Staff asked discovery to determine if there was a significant amount
of plant downtime or if there were any coal supply issues.See Staff Production Request No.2
and No.6.Staff did not see a significant amount of forced or unforced downtime that could have
affected the economic dispatch of its coal plants.The Company did provide information about
coal supply issues affecting coal generation in Utah that would have forced the Company to
obtain supply from higher cost sources.However,the Company did not identify or disclose any
coal supply issues at the Bridger coal plant located in Wyoming.Staff has current information
related to coal shortages at the Bridger Coal plant from its partner utility,Idaho Power.Why the
Company did not disclose this in its production request concerns Staff greatly.Because of the
large deferral,the lack of disclosure,and concerns for future operation of the Company's coal
plants,Staff believes a more complete picture of coal plant operation and coal supply is needed,
especially since customers are being asked to bear the burden of the high NPC in this year's
ECAM.
NPC Natural Gas
During the deferral period,the total natural gas fuel expense in actual NPC increased
about $382 million over the base NPC cost embedded in base rates.The average cost of natural
gas generationincreased $17.66/MWh-from$26.95/MWh to $44.61/MWh.Higher natural gas
generation costs were primarily due to increases in natural gas fueled generationand commodity
costs.
The Company increased natural gas fueled generation by 5,198 GWh or 61%.In the
winter of 2022,cold weather across the United States increased demand for natural gas which
contributed to large increases in market price of the commodity.Additionally,the region
experienced natural gas supply constraints which resulted in even higher market prices than
national averages,at the trading hubs serving the area.The Company asserts that natural gas
prices,at the Opal natural gas trading hub,one of the Company's natural gas delivery points,
were over 424%higher in December 2022 than in December 2021.Painter Direct Testimony at
13.Staff has followedthis situation and believes the Company's description of the events that
contributed to exorbitant natural gas prices is accurate.
STAFF COMMENTS 12 MAY 10,2023
Staff examined the Company's natural gas supporting workpapers and considered
industrytrends in commodity prices for the deferral period.Staff believes that the increased
natural gas costs in this filing are correct and reasonable.
Proposed Rates
Staff verified that the methods for determining the Company's proposed Schedule 94
ECAM rateS6 fOllOWS past Commission Orders and the calculations were accurate.The method
approved in Order No.33440 was used to spread the increase appropriately across each of the
different customer classes.The proposed ECAM rates in Schedule 94 are voltage-level specific,
which considers line losses due to the type of service for each class of customer.Table No.3
below reflects the proposed ECAM rate compared to the current ECAM rate.
Table No.3:Schedule 94 ECAM Adjustment
Service Type Secondary Primary Transmission
¢/kWh ¢/kWh ¢/kWh
Current Rates 0.733 0.720 0.696
Proposed Rate 0.934 0.917 0.886
Difference +0.201 +0.197 +0.190
Percent Difference 27.4%27.4%27.3%
Schedule 400 is a special contract customer that requires special treatment related to REC
revenue.The Schedule 400 baseline is the same proposed rate as other transmission level
customers,but accurately reflects the adjustment for its REC treatment.
The Company's proposed Schedule 94 revision to ECAM rates increases Company
revenue by approximately 2.3%;however,the revenue increases for specific customer classes
vary because of the rate design.The overall revenue increase for residential Schedule l
customers is 1.64%.Meredith's testimony includes both the Company's revised ECAM rates,
and the Company's proposed Electric Service Schedule No.94,as Exhibit 2,and Exhibit 3,
respectively.
6 See Case No.PAC-E-23-09 Exhibit No.2,Meredith Direct Testimony.
STAFF COMMENTS 13 MAY 10,2023
Customer Notice and Press Release
The Company's press release and customer notice were included with its application.
Staff reviewed the documents and determined that both meet the requirements of Rule 125 of the
Commission's Rules of Procedure (IDAPA 31.01.01.125).The notice was included with bills
mailed to customers beginning April 4,and ending May 2,2023,providing customers with a
reasonable opportunity to file timely comments with the Commission.As of May 10,2023,the
Commission has received one comment in opposition to the proposed rate increase.
STAFF RECOMMENDATION
Staff recommends that the Commission:
1.Approve the ECAM deferral balance;
2.Allow actual NPC included in the filing to be used to calculate the ECAM
deferral and Schedule 94 rates;
3.Withhold its decision on whether actual NPC is prudent until the Company,
with Staff's review,fully investigate the circumstances that led to the
inability of the Company to economically dispatch its coal plants;
4.Provide a report of its findings to the Commission within six months of the
Commission fmal order,which should include the items outlined in the
Analysis of NPC section;
5.Reserve the right to adjust the recovery of the actual NPC until the next
ECAM filing if the Company was not prudent in its management of coal
supply;and
6.Approve the proposed rates and tariffs as filed.
STAFF COMMENTS 14 MAY 10,2023
Respectfullysubmitted this day of May 2023.
D
Deputy AttorneyGeneral
Technical Staff:Ty Johnson
Curtis Thaden
Kevin Keyt
Joseph Terry
Leena Gilman
Rick Keller
i:umisc/comments/pace23.9dhtjetkkjtlgrk comments
STAFF COMMENTS 15 MAY 10,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 10th DAY OF MAY 2023,SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF,INCASENO.PAC-E-23-09,BY E-MAILING A COPY THEREOF,TO THEFOLLOWING:
MARK ALDER DATA REQUEST RESPONSE CENTERJOEDALLASE-MAIL ONLY:ROCKY MOUNTAIN POWER [e-mail]
1407 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 84116
E-MAIL:[e-mail]
[e-mail]
SECRE ARY
CERTIFICATE OF SERVICE