20180817Cross Petition for Reconsideration.pdf

WILLIAMS BRADBI]RY
ATTORNEYSATLAW F.ilCTtVED
iii:E &ilG t7 PH 2: 23
I i/-', :_...Li..y-: : t, ;i.{1.'lS.SlOi,lAugust 17,2018
Ms. Diane Hanian
Commission Secretary
Idaho Public Utilities Commission
472W. Washington
Boise, ID 83702
Re: Case No. PAC-E-17-07
Dear Ms. Hanian:
Please find enclosed for filing in the above referenced case the original and seven
copies of PacifiCorp Idaho Industrial Customers' Cross-Petition for Clarification and
Reconsideration.
Thank you for your assistance in this matter. Please feel free to give me a call should
you have any questions.
Sincerely,
R,^UrtW
RLW
Enclosures
Ronald L. Williams
P.O. Box 388 - Boise, ID 83701
Phone: [phone] - wwwwilliamsbradbury.com
Ronald L. Williams, ISB No. 3034
Williams Bradbury, P.C.
P.O. Box 388
Boise ID, 83701
Telephone: [phone]
ron@williamsbradbury. com
Attomeys for PIIC
IN THE MATTER OF THE APPLICATION )
oF ROCKY MOUNTAIN POWER FOR )
CERTIFICATES OF PUBLIC )
CONVENIENCE AND NECESSITY AND )
BINDING RATEMAKING TREATMENT )
FOR WIND AND TRANSMISSION )
FACILITIES
RTCiIVED
BEFORE THE IDAHO PUBLIC UTILITES COMMISSION
Case No. PAC-E-17-07
PACIFICORP IDAHO INDUSTRIAL
CUSTOMERS CROSS-PETITION FOR
CLARIFICATION AND
RECONSIDERATION OF ORDER NO.
34104
Pursuant to Rules 331 - 333 of the Idaho Public Utilities Commission's Rules of Practice
and Procedure, PacifiCorp Idaho Industrial Customers ("PIIC") cross-petitions the Idaho Public
Utilities Commission (the "Commission") to clarify that project capital cost caps are "hard" caps
above which rate recovery will not be allowed, and for clarification that hard caps also apply to
construction costs that are included in the resource tracking mechanism (RTM). If the
Commission grants Rocky Mountain Power's ("RMP" or the "Company") petition for
reconsideration, PIIC also requests that the Commission reconsider the issuance of a Certificate
of Public Convenience and Necessity ("CPCN") to RMP to construct the combined projects, and
reconsider imposing hard caps on distinct segments of the combined projects, instead of on the
overall project.
I. CLARIFICATION OF ORDER NO. 34104
Order No. 34104 clearly establishes a hard cap at project construction cost estimates,
but in light of RMP's Petition, the Commission shouldfurther clarify that a hard cap
PIIC,S CROSS-PETITION FOR CLARIFICATION AND RECONSIDERATION PAgE 1
I
means that RMP is categorically prohibitedfrom any rate basing of capital costs that
exceed the combined projects' construction cost estimates.
a. Discussion: It is clear from the record that the term "overall capital cost cap"
used by the Commission was meant to be a "hard" cap. That was how the term was defined in
the Stipulation, and the settlement testimony offered by both Staff and the Company demonstrate
that all parties shared the understanding that an "overall capital cost cap " was a o'hard" cap.
The issue of whether there should be an overall capital cost cap was such a significant
issue in the case that the two stipulating parties (Staff and the Company) could not find
agreement on the point to include in the stipulation. Paragraph 23 of the Stipulation states, "[t]he
Stipulating Parties agree that this Stipulation represents a compromise of their positions on all
but one issue - an overall capital cost cap." Paragraph 16 of the Stipulation states, "[t]he
Stipulating Parties reserve all rights to argue in this case for or against an overall capital cost cap
for construction of the Stipulated Projects." The language "overall capital cost cap" was not a
term of art created by the Commission. Rather it was a term from the Stipulation, which was
understood by the stipulating parties to be a "hard" cap.
The Commission, in its discussion of the "Overall Cost Cap" in Order No. 34104,
recognizes Intervenors' opposition to the proposed project, and that Intervenors' "argument and
analyses of the issues assisted in our ultimate decision to impose an overall cost cap set at the
Company's overall project estimate." Order No. 34104, p. 13. In light of Intervenors' "argument
and analyses", as well as the testimony and analysis of Staff, PIIC does not share RMP's
confusion regarding the Commission's "decision to impose an overall cost cap set at the
Company's overall project estimate." Id. It is disingenuous for the Company to argue that a
o'cost cap" does not bar the Company from later asking for rate recovery of costs exceeding the
cap.
PIIC,S CROSS-PETITION FOR CLARIFICATION AND RECONSIDERATION PAgE2
Brad Mullins, expert witness for PIIC, specifically provided argument and analysis that if
the Commission were to grant RMP a Certificate to build the combined projects, ratepayers
would be greatly harmed if the Company's modeling assumptions proved to be false. Mullins,
Di-Supp. 3. Mr. Mullins recommended that rate base amounts for the combined projects be
capped at the capital expenditures assumed in the benefits study presented in the Company's
supplemental direct testimony. Mullins, Di-Supp. 4. As also noted by Mr. Mullins, the margin
for achieving ratepayer benefits for the majority of the Company's benefits models was "very
thin." Mullins Di-Supp.-3.
Similarly, Staff recommended that the combined projects be approved, but conditioned
on a'ohard" cap being established at the Company's own construction cost estimates. Staff
explained the "hard" cap on capital cost recover as putting a ceiling on the amount the Company
can put in rate-base and recover in rates. Louis, M. Supp-15. As Staff Witness Lewis noted, a
relatively small percentage capital cost overun could otherwise eliminate any net customer
benefits in the medium gas/ medium CO2 [base modeling] case. Louis, M. Supp-13.
Consequently, Mr. Lewis recommends placing a "hard" cap on the projected capital costs for the
combined projects at the Company's construction cost estimate. Furthermore, Mr. Lewis and
Staff witness Randy Lobb explained why the traditional prudency test for capital investment is
inapplicable in this case - for the reason that once the Company reached the point of no return in
terms of project investment, cost escalations become a secondary concern to finishing
construction by the PTC deadline. Louis Supp - 15; Lobb Di - 6,7. Staff also argued that
"narrow margins make a Hard Cap essential to increase the probability that the Stipulated
Projects are prudent resources that are developed at a reasonable and economic cost." Carlock,
Di - 5. Staff notes that RMP proposed a "soft" cap. Id.
PIIC,S CROSS-PETITION FOR CLARIFICATION AND RECONSIDERATION PAgE 3
In contrast, the Company argued against an overall capital cost cap: "Staff believes that
the Commission should impose an overall cost cap, and the Company believes that a cost cap is
unprecedented and unnecessary based on the provisions ofparagraph 17 [ofthe stipulated
settlement] related to cost overruns." Steward, Sett - I l. Clearly, the Company understood term
overall cost cop to by synonymous with a "hard" cap.
In Order No 34104, the Commission stated that "the Company has failed to establish that
reliability requires new generation facilities." Id., p. 8. The Commission finding notes that
existing generation is sufficient for reliability purposes for "at least the next decade". Id These
findings would normally be grounds for the dismissal of a CPCN. In this case, however, the
Commission provided the CPCN based on its finding that economic benefit that can be realized
in connection with federal income tax credits. 1d. Since the project justification was economic in
nature, as opposed to being needed to provide safe and reliable service, the Commission found
"that the risk inherent in this business decision should not be entirely borne by the ratepayers."
Id. p. 13. Setting of an overall capital cost cap at the project estimate was justified based on this
finding, and RMP has neither discussed nor contested this finding.
The record the Commission relied on to establish its cost cap at construction cost
estimates uniformly spoke to the caps being'ohard" caps, and not the "sofrt" caps the Company
now argues for. Had the Commission intended a "soft" cap it would clearly have said so.
Commission Order No. 34104 instead said that the "cost cap . . . compels the Company to rely on
its models that predict benefits." Id., p. 13. In essence, the case for a CPCN was won by the
Company's forecasting models. As the Order noted, "[a] cost cap reduces ratepayer risk"1 and
I Id,
PllC'S CROSS-PETITION FOR CLARIFICATION AND RECONSIDERATION Page 4
that ratepayer risk reduction is meaningless if there is not requirement - a compulsion - for the
Company to live by its model results.
b. Clarification Needed: PIIC recommends that Order No. 34104 be clarified so
that RMP clearly and unequivocally understands that the Commission's "cost" cap imposed for
rate basing the combined projects is a "hard" cap at the Company's project cost estimates.
Furthermore, the clarification should unequivocally state that the Company is barred from
including in rate base and recovering in rates any capital costs that exceed the cost cap. The
Commission should find that costs exceeding the cost cap will not and cannot be used and useful,
for the reason that they can never be proven at alater time to be economically acquired, when
that economic need determination was made in 2018.
Finally, the Commission should find that in accordance with Idaho Code $ 61-526,the
present and future public convenience and necessity prohibits expenditures above the hard cap
estimates from ever being rate-based, for the same reason that the "need" for the combined
projects is not based on based on safety or reliability, but rather, on economic forecasts and
models created by the Company in20l7 and2018.2 Any construction cost overruns, no matter
how "prudent" they may seem at that later date in the construction schedule, destroys the
economic ooneed" which is the core basis for granting the Company the 2018 CPCN to build.
2. The Commission should also clarify that the RTM will not include capital costs that
exceed the "hard" cap of the combined projects construction cost estimqtes.
a. Discussion: The Resource Tracking Mechanism (RTM), as a sub-component of
the ECAM (electric cost adjustment mechanism), is admittedly a complicated series of
2 "We find . . . that the future need for new generation facilities . . . is met with the proposed projects because the
economic benefit captured through the PTCs is in the public interest." Order No. 34104, p. 8. See a/so p. 1l of
Order No. 34104 where the Commission references Staff testimony that the "Stipulated Projects are based on
economics rather than a need for generation and capacity."
PllC'S CROSS-PETITION FOR CLARIFICATION AND RECONSIDERATION Page 5
calculations. Order No. 34104 attempts to describe the various components and workings of the
RTM, but unfortunately, RMP "cherry-picks" some of the descriptive language or phrases from
pages 1 1 and 12 of the Order in an attempt to justifu an un-justifiable conclusion that 'ohard" or
"cost" caps do not apply to the RTM.
The obvious and clearly stated position of the Commission with respect to the RTM is
that "actual capital costs included in the RTM, before the next general rate case, cannot exceed
estimated costs for Stipulated Projects." Order No. 34104, P. 12 - 13. This is not an ambiguous
or confusing statement. Rather, it is a clear and concise "finding" by the Commission that the
RTM contains the same "hard" cap on construction costs, for ECAM flow through purposes, as
will apply once the Company brings its next general rate case.
b. Clarification Needed: To the extent that the Company cherry-picks various other
phrases from the Order to the effect that the RTM does not contain construction cost caps, the
Commission can correct this misunderstanding by rephrasing or eliminating language that the
Company uses to quibble.
Alternatively, the Commission can, on reconsideration, eliminate this entire risk by
adopting the recommendation of Monsanto to reject the RTM3, and require the Company to
bring a general rate case at the completion of construction of the combined projects. Such a
position would be consistent with actions taken by the Public Service Commission of Utaha, or
3 See Iverson, Di-6.
a, "We deny PacifiCorp's request to establish an RTM." Report and Order issued June 22,2018, Docket No. 17-035-
40, Utah PSC. "[W]e conclude here that PacifiCorp has sufficient means through ordinary available ratemaking
mechanisms, such as general rate cases or requests for deferred accounting treatment to seek recovery for its
investment in the Combined Projects. 1d.
PIIC,S CROSS-PETITION FOR CLARIFICATION AND RECONSIDERATION PAgE 6
agreed to by the Company, the Wyoming Staff and Wyoming Intervenors in its Wyoming
Settlement.s
II. P[C'S CROSS-PETITION FOR RECONSIDERATION
If the Commission grants RMP's petition for reconsideration, PIIC hereby cross-petitions
for reconsideration of the grant of a CPCN for the combined projects, and for applying a cost cap
to the overall project, instead of discrete project segments.
1. In reconsideration, the Commission should deny the CPCN for the combined
projects and reject the Stipulated Settlement.
In Order 34104, the Commission "condition[ed its] acceptance of the Stipulation upon
the setting of an overall capital cost cap at the project estimate." Id. p. 13. The acceptance of an
overall capital cost cap at the overall project estimate was a key condition that the Commission
(in exercising its authority under Idaho Code $ 6l-528) found to be necessary in order to grant
RMP its requested CPCN for the combined projects. Accordingly, if the Commission is to
reconsider the central issue surrounding the application of an overall capital cost cap, then it
would necessitate the Commission to also reconsider its acceptance of the stipulation and the
issuance of the CPCN based on that stipulation.
The Commission found that the combined projects are not necessary for reliability
purposes for at least 10 years. Id. p. 8 The Commission determined that a cost cap was required
since the projects' "need" was economic, rather than based on electric system reliability. Id.
Essentially, "necessity" for the combined projects was determined to be a somewhat distant
o'future" economic need, rather than a "present" reliability need. The overall cost'ohard" cap was
5 "All costs and benefits associated with the Stipulated Projects will flow through to customers through normal
ratemaking mechanisms such as general rate cases and the Energy Cost Adjustment Mechanism. [] The RTM
proposed by the Company shall not be adopted." Section 80(a), Stipulation and Settlement Agreement, April 10,
2018: Wyoming Public Service Commission, Docket No. 20000-520-EA-17.
PIIC,S CROSS-PETITION FOR CLAzuFICATION AND RECONSIDERATION PAgET
a condition attached to the CPCN that is critical in order to meet the future economic need test
for the project. Absent the hard cap condition, the combined projects do not satisfy the
requirements of Idaho Code $ 61-526, that "the [ ] future public convenience and necessity [ ]
will require such construction." Without the hard cap, the future need disappears.
In addition, market conditions and cost assumptions are always changing, and if the
Commission is to reconsider the cap, then the economic case for making the investment is called
back into question. If RMP now believes that its project costs are going to be higher than it
anticipated, there is reason to conduct additional analysis and process to determine whether it
continues to make economic sense for ratepayers to invest in the combined projects.
PIIC requests the Commission reconsider whether the Commission erred when granting a
CPCN for a project where the utility failed to establish that reliability requires new generation
facilities, and where existing resources were found to be sufficient to service the utility's loads
for at least 10 years. Id., p.8. The Commission suggests that a future need for new generation
facilities is most efficiently, effectively and reasonably met with the proposed combined projects.
Id. The criteria by which the Commission considered whether a "firture" need exists, and the
degree to which that future need warranted early resource action, however, was not described in
the Order. The phrase'ofuture public necessity and convenience" found in Idaho Code $ 6l-526
cannot be interpreted so broadly as to apply to any potential resource need that might arise at
some point in an indefinite future. Otherwise, virtually any resource proposal at any point out in
the future would qualify for a CPCN, rendering $ 61-526 essentially meaningless. The
Commission's reliance on a distant, undefined future resource need as the basis for granting the
CPCN should be reconsidered.
PIIC'S CROSS-PETITION FOR CLARIFICATION AND RECONSIDERATION Page 8
In reconsideration, hard caps should be individually placed all (i) wind, (ii)
transmission, and (iii) network upgrade segments of the combined project, rather
than a single cap applied to the entire project.
PIIC witness Brad Mullins recommends that separate hard cost caps be established for
"[t]he collective rate base for the Wind Projects", "[t]he collective rate base for the network
upgrades associated with constructing the Wind Projects" and "[t]he rate base for the
Transmission Projects." Mullins, Di. - 4.
If the Commission grants reconsideration of its decision to impose a cap that precludes
rate recovery for cost ovemrns incurred in building the combined projects, then PIIC requests
that the Commission also reconsider imposing hard caps on each of the three distinct elements of
the combined project, instead of imposing an "overall" hard cost cap. Mr. Mullins testimony on
the point provides substantial evidence on which the Commission could further protect
ratepayers for the different types of construction risk associated with the three components of the
combined projects.
III RMP'S PETITION FOR RECONSIDERATION SHOULD BE DENIED
The Company's request for Reconsideration is misplaced, unjustified, and should be
denied. The notion of an overall cost cap was a major issue in the case, with Intervenors and
Staff arguing for a "hard" cost cap, and RMP arguing against. Given the intense focus on the
cost cap in the proceeding, PIIC cannot imagine any new evidence or arguments that RMP might
make in order to justify reconsideration of this most significant issue.
Imposing an overall project cap is not unreasonable, unlawful, or eroneous. The
Commission's decision to impose 'hard" caps on RMP's rate basing of the costs to build the
combined projects was based on substantial evidence. "Substantial evidence is that which affords
'a substantial basis in fact from which the fact in issue can be reasonably inferred."' Boise Water
PIIC'S CROSS-PETITION FOR CLARIFICATION AND RECONSIDERATION Page 9
2
Corp 555 P.2d 163,170 (citing NLRB v. Columbia Enameling & Stamping Co.,306U.5.292,
299-300,59 S.Ct. 501, 505, 83 L.Ed. 660 (1939)). The Commission's pursuit of regulatory
authority is valid as long as its findings are supported by substantial evidence, or that the
Commission did not improperly employed its own methods of rate determination. Intermountain
Gas Co. v. Idaho Public Utilities Com'n,971 Idaho 113,127,540P.2d775,789 (1975). The
substantial evidence record that in part formed the basis of the Commission's decision to impose
a "hard" caps is amply described herein.
The Company offers five contentions to support its claim that a "hard" cap is unnecessary
and unreasonable. PIIC disagrees with those contentions, as outlined below.
a. RMP's burden of proof does not make hard cost caps unnecessary.
The Company argues that because it has the burden of proof with respect to
demonstrating the reasonableness of costs and investments that an overall cost cap is not
necessary. Petition, 9. This argument incorrectly presumes that the purpose of the overall
capital cost cap was to disallow costs which are the result of imprudent management. That is not
the case. As noted above, the purpose of the overall capital cost cap is to ensure that there was
an equitable sharing of the resource risk between ratepayers and shareholders, for the reason that
the combined projects'need was based on future economic benefits to ratepayers of substituting
company owned assets for market purchases.
PIIC, and other parties filed extensive testimony on the risks inherent in projects that are
not necessary for reliability purposes, but instead being proposed for economic purposes. Mr.
Mullins testified that "[w]hen a legitimate resource need has been established, a resource must be
acquired, irrespective of whether the resource produces financial benefits to ratepayers, or
increases overall financial risk to ratepayers." Mullins, Di, p. 10. Mr. Mullins noted, however,
PIIC'S CROSS-PETITION FOR CLARIFICATION AND RECONSIDERATION Page l0
that "the decision of whether to proceed with a resource acquisition is fundamentally different
from a ratepayer perspective, depending on whether a resource need has been established, or
not." Id. Mr. Mullins also testified that "there were thousands of megawatts of wind available
through PPA agreements with a comparable cost," which do not carry the same risk of cost
overruns. Mullins, Supp. Di,74,. Mr. Mullins testified that "due to the existence of these low
cost PPA options, it is critical for ratepayers to be insulated from all fuither development risk
associated with the combined projects, through the imposition of project-by-project hard cap on
all construction costs at the level assumed in PacifiCorp's benefits study." Mullins, Supp. Di, 14
Given the fact that the economic benefits of the project were small, and there were other
comparable alternatives available that did not carry the same risk of capital cost over runs, an
overall capital cost cap is necessary and appropriate. While RMP will carry the burden of proof
regarding the reasonableness of costs in cases going forward, the prudence with respect to
starting its investment in the combined projects has been confirmed by the issuance of a CPCN
in this case.6
b. An overall capital cost cap was not imposed in order to incent or motivate RMP to
control construction costs.
The Company argues that an overall capital cost cap is not necessary to motivate or
incentivize it to prudently manage and minimize project implementation costs. Once again,
RMP has disregarded the purpose of an overall cost cap as explained in Order No. 34104 and the
findings that led the Commission to adopt the cost cap. The purpose of the cost cap was not to
incentivize the Company to control costs. The Commission found that an overall capital cost cap
6 Prudency of continuing to build the projects, if circumstances change in the future, is another matter.
PIIC'S CROSS-PETITION FOR CLARIFICATION AND RECONSIDERATION Page 11
is necessary because the projects are justified based on providing economic benefits to
ratepayers, rather than satisfying a reliability need.
c. An overall capital cost cap for rate basing is not punitive.
Establishing a hard cap at estimated construction costs in the context of a request for
proposal is not punitive, as RMP suggests. In essence, the Company argues that it should get a
'second bit' of the apple regarding reasonableness, prudency and public interest, as they are the
"well established ratemaking principles" that should be applied.
If traditional ratemaking standards are to be applied in this case, PIIC submits that the
traditional ratemaking principal that resource need be based on resource adequacy should also be
applied, rather than resource economic substitution. If this traditional needs test were applied, a
CPCN would not be granted.
The Company's argument in this instance [that a hard cap condition is contrary
ratemaking principles and is unreasonably punitive] also potentially implies that the
Commission's imposition of a hard cap is outside the Commission's authority. To the contrary,
Idaho Code g 6l-528 clearly gives the Commission authority to "attach [to a CPCN] such terms
and conditions as in its judgement the public convenience and necessity may require."
d. Actual ratepayer net benefits will be either positive or negative, for a variety of
reasons, and RMP should not get a second chance to recover cost-overruns,
based on the Company's net benefits models.
The Company argues that it is possible that project capital costs might increase, but that
the projects could still provide benefits to ratepayer. True. It is also true that actual construction
costs could come in above estimates but result in negative net benefits. It is also true that other
cost assumptions contained in the benefits models, such as future gas prices and/or carbon costs,
could change to either enhance or adversely impact net ratepayer benefits, regardless of whether
PIIC'S CROSS-PETITION FOR CLARIFICATION AND RECONSIDERATION Page 12
construction costs are below, at or above estimates. It is a virtual certainty that ratepayer net
benefits will be different when the combined projects are built, than what they are projected to be
today.
At a future rate basing point in time, it will be difficult, if not impossible, to determine
the precise amount of net customer benefits associated with capital cost ovemrns, verses other
modeling variables. Giving the Company a second 'bite' in the future at net benefits, in the
context of cost overruns, would divert benefits associated with lower than expected carbon or gas
prices from ratepayers to RMP shareholders. The Company's ratepayers are taking the risk that if
gas and carbon prices contained in the Company's models are higher than expected, they bear
that risk. Conversely, the Company should not be able to convert the rewards of these gas or
carbon prices being less than modeled, in order to cover cost ovemrns above a hard cap.
e. RMP is in control of project costs and cost estimates, and should bear the burden
of that risk.
Finally, RMP argues that an overall cost cap results in the Company inappropriately
bearing the risk of increased cost outside of its control. The Company would like its customers
to bear all of that risk, despite the fact that customers'/intervenors representing approximately
65oh of the Company's revenues in Idaho object to the combined projects as being much too
risky to pursue. The Company controlled the project estimates (including construction
contingency estimates), and these estimates were extraordinarily important when making the
resource decision.
Further, RMP has absolute control over the project costs as the project is built, and
ratepayers have no management ability or obligation. Intervenors noted a large number of risks
that RMP did not consider, and in recognition of those risk, recommended that the Company not
be given a CPCN to proceed. The Company disagreed with Intervenors assessment of the project
PIIC'S CROSS-PETITION FOR CLARIFICATION AND RECONSIDERATION Page l3
risks. If RMP is no longer willing to assume the risks of the project, it should not proceed.
Ratepayers should not be the guarantors of all development risk.
vI. CONCLUSION
For the reasons outlined above, PIIC cross-petitions the Commission to clarify that the
cost cap imposed in Order No. 31104 is a "hard" cap that categorically precludes from recovery
capital costs of the combined projects that exceed their cost estimates. Furthermore, PIIC
requests that the Commission find that imposing and attaching such a condition to the issuance
of a CPCN for the combined projects is (i) within its statutory authority under Idaho Code $ 61-
528, (ii) that construction costs of the combined projects that exceed the cost cap will not and
cannot be used and useful, and (iii) the present and future public convenience and necessity
prohibits expenditures above the hard cap estimates from being rate-based.
Should reconsideration requested by the Company be granted, PIIC also requests that the
Commission reconsider its decision to issue RMP a CPCN based on a distant, undefined future
economic resource need, rather than an immediate resource adequacy need. In addition, PIIC
asks that the Commission also reconsider the imposition of o'hard" caps on the discrete segments
of the combined projects, instead of reconsidering an "overall" cost cap.
Dated this 17th day of August, 2018.
Respectfully submitted,
/?,^,tl ttu/;
Ronald L. Williams
Williams Bradbury, P.C.
Attorneys for PIIC
PIIC'S CROSS-PETITION FOR CLARIFICATION AND RECONSIDERATION Page 14
CERTIFICATE OF MAILING
I HEREBY CERTIFY that on this lTth day of August, 2018, I caused to be served
a true and correct copy of the foregoing document upon the following individuals in the
manner indicated below:
Diane M. Hanian, Secretary
Idaho Public Utilities Commission
P.O. Box 83702
472 W . Washington Street
Boise, lD 83702-0074
E-Mail : [e-mail]
Brandon Karpen
Deputy Attorney General
Commission Staff
472 W. Washinglon St.
Boise, lD 83720
E-Mail: [e-mail]
Ted Weston
Idaho Regulatory Affairs Manager
Rocky Mountain Power
1407 West North Temple, Suite 330
Salt Lake City, UT 84116
E-Mail : ted.weston@pacifi corp.com
Yvonne R. Hogle
Assistant General Counsel
Rocky Mountain Power
1407 West North Temple, Suite 320
Salt Lake City, UT 84116
E-Mail : [e-mail]
Data Request Response Center
PacifiCorp
825 NE Multnomah, Suite 2000
Portland, OR 97232
E-Mai I : datarequest@pacifi corp.com
RandallC. Budge
Racine, Olson, Nye & Budge, Chtd.
201 E. Center
PO Box 1391
Pocatello, ID 83204-1391
E-Mail : [e-mail]
Attorney for Monsanto Company
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Brubaker & Associates
16690 Swingley Ridge Road, #140
Chesterfield, MO 63017
E-Mail: [e-mail]
[e-mail]
Monsanto Company
Jim Duke
Idahoan Foods
357 Constitution Way
Idaho Falls, ID 83742
E-Mail : [e-mail]
PIIC
Kyle Williams
BYU Idaho
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PIIC
Val Steiner
Nu-West Industries, Inc.
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PUC
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Ronald L. Williams
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