20151113Lobb Direct in Support of Stipulation.pdf

rDAHo puBLrc urrLrnEQ*g$$&lsffiS$,cn
IN THE MATTER OF THE APPLICATION
OF AVISTA CORPORATION DBA AVISTA
UTILITIES FOR AUTHORITY TO INCREASE
ITS RATES AND CHARGES FOR
ELECTRIC AND NATURAL GAS SERVICE
IN IDAHO.
BEF.RE THE f;rc*YEn
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CASE NO. AVU-E-I5.05
AVU-G-I5-01
DIRECT TESTIMONY OF RANDY LOBB
IN SUPPORT OF THE STIPULATION
AND SETTLEMENT
IDAHO PUBLIC UTILITIES COMMISSION
NOVEMBER 13,2015
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O. Please state your name and business address for the
record.
A. My name is Randy Lobb and my business address is
472 West Washington Street, Boise, Idaho.
O. By whom are you employed?
A. I am employed by the Idaho Public Utilities
Commissi-on as Utilities Division Administrator.
O. What is your educational and professional
background?
A. I received a Bachelor of Science Degree in
Agricultural Engj-neering from the University of ldaho in L980
and worked for the Idaho Department of Water Resources from
,June of l-980 to November of 1"987. I received my fdaho
license as a registered professional Civil Engineer in l-985
and began work at the Idaho Public Utilities Commission in
December of L987. I have analyzed utility rate applications,
rate design, tariff filings and customer petitions. I have
testified in numerous proceedings before the Commission
including cases dealing with rate strucLure, cost of service,
power supply, line extensions, regulatory policy and facility
acquisitions. My duties at the Commj-ssion include case
managrement and oversight of all technical Staff assigned to
Commission filings.
O. What is the purpose of your testimony in this case?
A. The purpose of my test,imony is to describe the
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proposed comprehensive settlement in this case and explain
Staff's support.
O. Please summarize your testimony.
A. The proposed Stipulation and Settlement (the
"SettlemenL" ) provides an electric rate increase on ,.Tanuary
A, 201"6 of $1.7 mil-lion (0.59?) and a natural gas rate
increase of $2.5 million (3.492). It also provides for a
Fixed Cost Adjustment (fCa; mechanism for both electric and
gas servj-ce t,o track recovery of Commission authorized fixed
costs and either surcharge for shortfalls or credit for over
coll-ection on an annual basis.
Af ter comprehensive review of t,he Company's
Application, thorough audit of Company books and records and
extensive negotiation with parties to the case, Staff
supports the proposed Settlement. Staff believes that the
Settlement, supported by all parties to the case is in the
public interest and should be approved by the Commission.
Background
0. Please describe Avj-sta's original filing.
A. Avista made its origJ-na1 filing on May 13, 2015
requesting authority to increase it.s raLes by $13.2 million
(5.22) and i3.2 million (4.52) for electric and gas service,
respecti-ve1y, effective ,.Tanuary !, 2015. The Company also
requested to increase its rates by an additional $13.7
million (5 . l-?) and $1 . 7 million (2 .22 ) f or electric and gas
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service, respectively, ef fective ,January a, 201-7. The
Company proposed a capital structure of 50/50 and a return on
common equity of 9.92.
The Company proposed to spread the revenue increase
in both years to electric and gas customer classes using a
25? move and a 33? move toward cost of service, respectively.
Residential customer charges would j-ncrease from #5.25 to
$8.50 and from $4.25 to $8.00 per month for electric and
natural gas service, respectively.
Fina11y, the Company proposed an FCA for both gas
and electric servj-ce to track monthly recovery of fixed costs
on an annual basis in between rate cases. If cost recovery
was below that authorized by the Commission, then customers
would receive a surcharge. If cost recovery exceeded that
authorized by the Commission, customers would recej-ve a
credit.
Settlement Overview
O. Please summarize the proposed Settlement.
A. The proposed Settlement specifies a rate increase
of $1.7 million (0.692) and $2.5 million (3.492) for electric
and natural gas service, respectively, effective 'January l,
201,5. It. also specifies a 50/50 debt to equity capital
structure, a 5.342 cost of debt and a 9.5* return on common
equity.
Besides specifying capital structure, equity return
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and the debt cost for both electric and gas service, the
Settlement also specifies a variet.y of expense and investment
adjustments. The electric and gas revenue adjustments faII
primarily into three categories: 1) eliminate test year
proforma expense and investment beyond December 31, 201,5; 2)
modify miscellaneous test year expenses; and 3) lengthen
amortization periods for deferred accounts. Electrj-c revenue
requirement is further adjusted by continuing Palouse Wind
expense recovery through the Power Cost Adjustment (PCA)
mechanism rather t.han through base rates.
The revenue increase will be spread to each
electric and gas customer class based on a 25* and 33? move
toward class cost of service, respectively, 6rs originally
proposed by the Company. Electric residential energy rates
wiLl increase by a uniform percentage to generate the
additional revenue. The basic charge for residential
electric customers will remain at #5.25 per month while the
basic charge for residential gas service will increase from
54.25 to $5.25 per month. The remaining increase will be
spread uniformly to commodity rates.
The Settlement also est.ablishes an FCA for 3 years
for both electric and natural gas service to track and defer
over or under collection of Commission authorized fixed costs
on an annual basis. The Settlement describes a varj-ety of
FCA requirements including treatment of new and existing
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customers and annual reporting.
A. Are there any ot,her provisions included in the
proposed Settlement?
A. Yes. The Set.tlement also specifies base power
supply expenses for use in the PCA mechanj-sm, exLension of
electric and natural gas rebates and an agreement for t.he
part.ies to meet and confer on low income weatherization
programs and 1ow income consumption data.
Settlement Process
O. What was the process that lead t,o t.he a1I-party
Settlement?
A. After the Company's initial filing on May 13, 201-5,
the Commission issued a Notice of Applicatj-on and set an
intervention deadl-ine of June 29, 2015. Five parties
intervened in t,he case: l-) Clearwater Paper, 2) Consumer
Act.ion Partnership of Idaho (CAPAI), 3) Idaho Conservation
League, 4) Idaho Forest Group and 5) Snake River A1liance.
Avista, Staff and the j-ntervening parties then
conferred and set a schedule that included settlement.
workshops, filing dates for direct and rebuttal testimony and
a date of November 23, 201.5 for a technical- hearing. Part.ies
convened a workshop on September 18, 20L5 to discuss case
settlement.
Through extensive discussions and give and take on
a variety of issues that included over 23 revenue requj-rement.
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adjustments, class cost of service, revenue spread, rate
design, multi-year rate plans and fixed cost adjustment
mechanisms, the parties came to tentative agreement. Over
the next month, the parties agreed to language culmj-nating in
the proposed Settlement and Stipulation filed on October :.-9,
20]-5.
Staff Investigat,ion
a. What type of investigation did Staff conduct to
evaluate the Company's rate increase request?
A. There were fifteen Utilities Division Staff
assigned to extensively review the Company's applicat.ion and
identify issues in preparation for litigation at hearing.
Staff conducted two weeks of onsite audits, submitted 155
production requesLs, and reviewed rate increase requests
filed by the Company in other state jurisdictions.
Staff identified twenty three adjustments to the
Company's requested revenue requirement, evaluated and
developed annual power supply expense for the PCA, compared
and contrasted past and present class cost of service models
and assessed the need for an FCA mechanism. Staff prepared a
revenue requirement and est.ablished positions on all of the
major issues in preparation to file direct testimony on
Oct.ober 21, 20L5 .
A. How did Staff prepare for the settlement workshop?
A. Staff prepared for the settlement workshop by
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preparing f or testimony in t.he lit.igated case. Staf f
developed its revenue requirement adjustments and positions
on various issues for presentation at the workshop in
conjunction with preparing testimony for hearj-ng.
O. What is Staff's settlement objective?
A. The objective of settlement is to achieve an
outcome that is better for customers than what otherwise
could be achieved through a litigated case. Successful
settlement from Staff's perspective is to convince the
Company and other parties to accept the majority of Staff
revenue adjustments and positions as part of the proposed
Settlement rather than risk losing those issues at hearing.
O. Does the Settlement achieve those objectives?
A. Yes, I believe that it does. Of the 23 electric
revenue requirement, adjustments that St.aff identified,
roughly 17 were encorporated ej-ther totally or partially in
the Settlement. Rather than an j-ncrease of $l-3 .2 million as
proposed by the Company, the Settlement specified an elect.ric
increase of only $1.7 miIlion. On the gas side, 14 of 16
adjustments were fu1Iy or partially included in the
Settlement reducing the increase from $3.2 million to $2.5
mi1lion.
O. What type of revenue requirement adjustments were
proposed by Staff and included in the Settlement?
A. Besldes a reduction in return on common equity, the
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adjust.ments generally fa11 into three categories: 1)
eliminate test year proforma expense and investment beyond
December 3l-, 20L5; 2) modify miscellaneous test year expense;
and 3) lengthen amortizat,ion periods for deferred accounts.
O. What effect did equity return have on revenue
requirement?
A. The Company had originally proposed a return on
common equity of 9.9+ while the Settlement specifies a reEurn
of 9.52. Staff notes that. the lower return is consistent
with return on equity established in Avista's Washington
jurisdiction and Staff believes it is within a reasonable
range for Avista's financial situation and represents a
reasonable compromise in this case.
The return on equity adjustment reduced electric
revenue requirement, by $2.44 million and natural gas revenue
requirement by $415,000. Capital strucLure and cost of debt
remain as orlginally proposed by the Company.
O. What effect did limiting the test year proforma
perJ-od have on revenue requirement?
The Company's original proposal included a multi-
year rate increase with budget.ed expense and capital
additions included through December 31, 201-7. The Settlement
specifies a single year rate increase on ,January 1, 201-5 with
expense and j-nvestment included through December 31, 201,5.
The Settlement specifically reduces electric t,est year
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revenue requirement by $3.9 million to reflect reduced leve1s
of actual 2015 capital investment and removes planned capital
additions in 20]-6.
The Settlement further removes nearly $l- million in
electric revenue requirement for insurance, lnformatlon
services and technology and non-executive labor expense
increases planned for 201,6. Adjustment for these items on
the gas side reduced revenue requirement by $333,000. Staff
maintains that limitlng test year proforma expense and
investment to December 31, 201-5 better refl-ects known and
measurable costs actually incurred by t.he Company and is
consistent with past Commission Order (Uo. 30772).
O. What test year expenses where actually reduced from
the Company' s proposal?
A. The second category of adjustments reflects a
$588,000 reductj-on in electric revenue requirement and a
i279,000 reduction in gas revenue requirement to reduce
proposed expense recovery in rates. The parties agreed to a
variety of adjustments that Staff believes reflect.ed more
appropriate leveIs of expense.
Injuries and damage expenses were reduced for both
electric and gas operations t.o reflect average expenses
incurred over the last 5 years. Officer incentives were
removed and non-officer incentives were reduced to reflect
l-00? rather than a 1-02? payouE. Other miscellaneous
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administ,ration and general expenses were reduced for such
items as insurance expense for directors and officers, a
1ega1 expense error, abnormally high cleanup expenses
incurred in 20L4, Board of Director expense allocated to
shareholders and miscellaneous account 930 expenses.
O. What impact did extended amortj-zation of deferral
balances have on stipulated revenue requirement?
A. The third category of adjustments extended deferral
balance amortj-zation periods to reduce test year revenue
requirement. by $788,000 and $158,000 for electric and gas
service, respectively. Staff maintained that amortj-zation
periods for project Compass and Lake Spokane project
deferrals should be set at 4 years rather than 2 years as
proposed by the Company. The parties agreed to 4 years for
the purpose of settlement.
O. Were there other revenue requirement adjustments
included in the Settlement that did not fit i-nto the three
categories?
A. Yes. The Settlement included an electric expense
adjustment of $3.5 mllIion for the Palouse Wind project.
Expenses and benefits associated with this project are
currently include for recovery in the Company's PCA
mechanism. The Settlement specifies that Palouse Wlnd
expenses will continue to be recovered in the PCA rather than
included in base rates as originally proposed by the Company.
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O. Why does Staff believe it is appropriate to
contlnue PCA treatment of Palouse Wind expense?
A. Staff maintains that the Palouse Wind project was
never acquired to meet loads in Idaho. It was acquired to
comply with Resource Portfolio Standards in Washington State.
While the project does generate energy and provide some value
to Idaho customers, the cost, for Avista to purchase the
project output exceeds the value of the energy generated.
Conseguently, Staff believes that. Company sharehol-ders should
share in the annual economic loss created by the project.
Avista disagrees with Staff's position but accepts the
stipulated treatment for purposes of this case. The net
customer benefit of continued PCA treatment of Palouse Wind
expense is approxi-mately $fS0,000 or the Company's 10? share
of $3 .5 million t,hat, would be eliminated with base rate
treatment.
Revenue Spread and Rate Design
O. Please explain the Settlement with respect to class
cost of service and revenue spread.
A. The Company's original applicatlon in this case
incl-uded class cost of service st.udies for both electric and
natural gas service. Those studies both showed that
resident.ial and small commercial customers were paying less
than their appropriate cost of service and large high load
factor customers were paying more than their appropriate cost
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of service. The Company consequently proposed moving
electric customers 25e, toward cost of servj-ce and gas
cusLomers 33? toward cost of servi-ce.
While no party specifically agreed with the
methodology used in the Company's cost of service study, all
parties agreed t.hat the study results generally indicated
whether customer classes were above or beLow cost of service.
Therefore, all parties accepted the Company's proposed
incremental move toward cost of service.
Staff fuI1y reviewed the Company's class cost of
service studies submitted in this case and those submitted by
the Company in prior cases. Staff agrees for the purposes of
this case that cost of service trends support the j-ncremental
move as proposed in the Settlement. The resulting percentage
increase by customer class is shown on page 15 of the
Sett.Iement.
O. How does the Settlement specify that rates will
change?
A. The Settlement specifJ-es that the volumetric energy
rate will increase by a uniform percentage for all customer
classes and residential basic charges wil-I remain at $5.25
per mont,h. The basj-c charge for natural gas residential
customers will increase from $4.25 per month to $5.25 per
month with a uniform percentage increase in the volumetric
energy rate for the remaj-ning revenue requirement balance.
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The revenue requirement for all other gas service schedules
will- be applied as a uniform percentage increase in the
volumetric energy rate.
Staff supports the increase in the natural gas
basic charge for resj-dential customers that equals the
current electric basic charge for resj-dential customers.
Staff also believes the uniform percentage increase ln
volumetrj-c energy charges is appropriate in this case given
the sma11 overall increase in revenue requirement.
O. Could you please describe t,he electric and natural
gas rebate extension?
A. Yes, electric customers are current.ly receiving an
annual rebaEe through December 31-, 201-5 of approximately $2.8
miIlion for 2013 earnings sharing approved by the Commission
in Case No. AVU-E-I-4-05. The Settlement specifies that the
$2.8 million annual rebate w111 continue through December 31,
2Ol7 using $5.6 million in 201,4 revenue sharing.
The natural gas rebate of approximately #A.2
million annually for 2013 revenue sharing and unused energy
efficiency balance is also set to expire on December 31,
2OL5. The Settlement specifies that $0.2 million in 20L4
revenue sharing will be used to partially offset the l1-.2
million rebate that will expire on ,January 1 , 20:..6.
Staff believes that use of revenue sharing funds to
prolong rebates that would otherwise expire or to mitigate a
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portion of an expiring rebate is appropriate. Customers are
entitled to these funds and Staff supports the rate
stabilizing effect that occurs from including them in the
Settlement.
Fixed Cost Adjustment
O. What is an FCA mechanism?
A. An FCA mechanism is designed to track fixed cost
(Company costs that do not change with energy consumption)
recovery and either surcharge for under recovery or rebate
for over recovery on an annual basis. The mechanism
decouples fixed cost recovery from energy consumption to
assure that. fixed costs are recovered no matter how much
energy is consumed.
O. Please explain the Company's proposed FCA
mechanism.
A. The Company proposed a permanent electric and
natural gas FCA based on a Commission approved 1evel of fixed
cosL recovery per customer, known as the Fixed Cost
Adjustment Revenue-Per-Customer. The proposal included two
Rate Groups, Residential and Non-Residential. The
Residential Rate Group included Schedul-e 1 for the electric
FCA and Schedule l-01- for the natural gas FCA. The Commercial
Rate Group for the electrj-c FCA included Schedules 11, a2,
2A,22,31, 32. The Commercial Rate Group for the gas FCA
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j-ncluded Schedules 111 and 112. Each Rate Group had a
distinct Fixed Cost Adjustment Revenue-Per-Customer.
The Company proposed an annual filing for each rate
group to recover or rebate the approprj-ate deferred revenue
amount over a 12-month period (,January-December) . The
surcharge/rebate reconciles mont,hly differences between fixed
costs allowed to be collected on a per-customer basis, and
the non-weather normalized actual fixed costs collected. The
deferred revenue under/over collection would then be
separately surcharged or rebat,ed to each customer group
through the Company's proposed electric tariff Schedule 75 or
the natural gas tariff Schedule 1-75.
a. Is the stipulated FCA mechanism identical- to the
Company' s original proposal?
A. No. The parties have only agreed to a 3-year
pilot, with a review following the end of the second fuII
year. This will aIlow Staff and other parties an
opportunity to evaluate the mechanism and determine whether
it is functionj-ng as intended. The mechanism can be
modified or discontinued if it is found to be operatJ-ng
improperly. In order to facilitate on-going review, the
Company agreed to provide quarterly reports showing the
mont.hly deferrals by rate group, what the deferrals would
have been if tracked by rat.e schedul-e, use and revenue-per-
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customer for existing and new customers, and other summary
f inancial information.
The Company had proposed to use the FERC interest
rate on the unamortized FCA balancing accounts. Instead,
the Parties have agreed to calculate the accrued interest
based on the Customer Deposit Rate, which is consistent with
prj-or Commission Orders. 1
While the Company's original proposal did not
include a cap on annual surcharges, the Parties have agreed
that. FCA surcharges in any given year cannot exceed 3?. The
cap will be applied by rate group with any unrecovered
balances carried forward to future years for recovery.
Staff believes the cap is necessary to prevent large annual
surcharges if weather or economic conditions vary
significantly in a particular year.
The FCA mechanics proposed in the Settlement are
nearly identical to t.he Company's proposal. The only
difference is that Fixed Cost Adjust,ment Revenue-Per-
Customer for new customers added after the test perj-od will
be less than that for existing customers.
O. Why should Revenue-Per-Customer differ for new and
existing customers in t.he FCA?
1 Based on Order No. 33187 in Case No. GNR-U-L4-L2, thedeposit rate for 2015 is 1-.0?. The rate is updated annua11y.
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A. The Parties agreed that the Fixed Cost Adjustment-
Revenue-per-customer for new elect.ric customers will exclude
fixed production and transmission costs. For new natural
gas customers, recovery of costs related to fixed production
and underground storage would also be excluded. This
disparate treatment will limit fixed cost recovery for new
customers in between rate cases to fixed costs that are more
certain to occur.
St.aff maintains t.hat cert.ain t.ypes of investments
are "Iumpy" and may not actually be required Lo serve new
customers in between general rate cases. Rather than assume
these costs are incurred for automatic recovery in the FCA,
they are removed from new customer revenue and only those
incremental costs directly related to serving new customers
are included.
The new customer investment issue is further
highlight.ed when the FCA reconcj-Ies the monthly difference
between fixed costs allowed to be collected on a per-
customer basis and fixed costs actually collected. As the
number of customers increase between rate cases, the total
fj-xed costs allowed to be collected increases beyond the
amounL reviewed and authorized by the Commission. An FCA
should not become a substitute for general rate case
filings, whereby the Company requests rate treatment for
investments actually incurred. Staff believes limiting FCA
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recovery to.specific types of fixed costs better assures
that costs recovered through the FCA are actually incurred
to serve a new customer.
A. When will the Company file a proposed surcharge or
rebate?
A. FCA implementatj-on will commence concurrently with
the natural gas and electric rat.e changes January 1, 201,6 .
On or beforeJuly 1, 20!7 the Company will file its first
proposed rate adjustment surcharge or rebate based on
deferred revenue recorded from ,January 20L6 through December
20L6. The proposed tariff (Schedule 75 for electric,
Schedule 1-75 for natural gas) included with that filing will
show the adjustment as a rate per kWh for electric and a rate
per therm for natural gas. This FCA rate will be determined
using expected energy sales to surcharge/rebate the
appropriate deferred revenue amount over a twelve-month
period effective October 1, 201,7 for electric (to coincide
wit.h the PCA period) and November !, 2Ol7 for natural gas (to
coincide with the Purchased Gas Cost Adjustment period). The
annual FCA will be filed consistent with this schedule for
t,he remaining 2 years.
O. Please explain why an FCA is necessary and how it
benefits customers?
A. Hj-storica11y, Staff has generally supported rate
design proposals that keep fixed charges 1ow in order t.o
CASE NOS. AVU-E-l-5-05/AVU-G-L5-0l-
1-t/ 13 / 1-s
LOBB, R. (Di) 18
STAFF
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encourage conservation and al1ow customers to control their
bil-Is. While the Company's fixed costs do not necessarily
change with the leve1 of energy consumptj-on, recovery of
those fixed costs does. For example, when weather or
favorable economic conditions contribute to higher than
normal energy or natural gas sales, the Company may over-
recover its fixed costs. Conversely, when Demand-Side
Managemen! ("DSM") or price signals from certain rate
designs cause customers to use less energy or natural- g&s,
the Company may under-recover its fixed costs.
Consequently, there's a financial disincentive for the
Company to encourage conservation. The table below shows
the Company's revenue from fixed charges as a percenL of its
total fixed costs for each schedule included in the FCA.
* Calculated using page 1 of Appendix B and C. For purposes of this table,Distribution and Customer Related Costs, and Common Costs are assumed to befixed costs. NaturaL Gas Fixed Costs also include the demand related charges in
Schedul-e 150.
CASE NOS. AVU-E-15-05/AVU-G-15-01-
1"1/ L3 / 1-5
LOBB, R. (Di) 19
STAFF
Electric Schedule 1 Schedul-ett/12 ScheduLe
2L/22
Schedule3t/ 32
Fixed Costs 79,71,0,926 28 ,188 ,1-28 38,749,289 3 ,96 g, 533
Fixed Charge
Revenue 6 ,484 , L65 2,453,750 4,935, 600 l.33 ,57 6
Fixed Charge
Z of Fixed
Costs
8.10?8.70*L2 -sO+3.40?
Natural Gas Schedul-e
10l-
Sc hedu1e
1"1"1/ LL2
Fixed Costs 31 ,448 ,841-9 ,37 4 ,373
Fixed Charge
Revenue 4 ,7 69 ,536 1,677,185
Fixed Charge* of Fixed
CosLs
L2 .7 4e"1-7 - 892
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The FCA reduces the financial disincenti-ve to
encourage conservation by decoupling a portion of revenue
from the Company's energy and gas sa1es. Consequently, the
Company will be at less rj-sk of not. fu1ly recovering its
fixed costs when it promotes cost-effective DSM programs
and/or rate designs that, send a price signal to conserve
energy or natural gas. If t,he Company successfully
encourages lower energy and gas consumption, Staff bel-ieves
the FCA will undoubtedly save customers money in the long-
run by deferring or eliminating capital cosEs that might
otherwise be required to serve growing 1oad.
A. What impact might t,he FCA mechanism have on
customers?
A. Staff looked at t.he last two years to see what the
impact would have been had the proposed mechanism been in
place. fn 201-3, residential customers would have received a
rebate of 0.792 for electric and 0.02* for gas. For the
same time period, commercial customers would have received a
rebate of 2.072 for electric and a surcharge of L.5OZ for
gas. ln 2014, residential customers would have received a
rebate of 0.05? for electric and a surcharge of L.l.7Z for
gas. For the same time period, commercial customers would
have received a rebate of 2.24* for electric and a surcharge
of L.972 for gas.
cAsE NOS . AVU-E- l-s - 0sIAVU-G- 15 - 0L
t1-/1-3/ts
LOBB, R. (Di) 20
STAFF
Staff believes the mechanism will be largely
impacted by weather, economic conditions, DSM/conservation,
and rate design. For example, if t.emperatures are relatively
mild (warm winters and cool summers), customers could see FCA
surcharges. Conversely, if temperatures are extreme (co1d
winters and hot summers), customers coul-d see FCA credits.
O. Are there any other provisions in the Settlement?
A. Yes, the Settlement specifies that the parties will
collaborate on Iow income weatherization and 1ow income
energy efficiency education. The objective of the
collaboratj-on is to identify energy and gas consumption
leveIs of 1ow income cust.omers and identify the proper
energy efficiency funding leveIs in the future.
The Settlement also specj-fies that the parties will
initially meet no later than ,June L, 201"6 to discuss these
j-ssues. Staff fu11y supports collaboration on the 1ow
income energy efficiency issues and looks forward to
actively participating in all associated meetings.
O. Does this conclude your testimony in this case?
A. Yes, it does.
cAsE NOS. AVU-E-l-s-0s/AW-G-l-5-01tt/L3/as LOBB, R. (Di) 21-
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CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 13TH DAY OF NOVEMBER 20T5,
SERVED THE FOREGOING DIRECT TESTIMONY OF RANDY LOBB IN
SUPPORT OF THE STIPULATION AND SETTLEMENT, IN CASE NOS.
AVU-E-15-05/AVU-G-15-OI, BY MAILING A COPY THEREOF, POSTAGE PREPAID,
TO THE FOLLOWING:
KELLY NORWOOD DAVID J MEYER
VP - STATE & FED REG VP & CHIEF COUNSEL
AVISTA CORPORATION AVISTA CORPORATION
PO BOX3727 PO BOX3727
SPOKANE WA99220-3727 SPOKANE WA99220-3727
E-mail: [e-mail] E-mail: [e-mail]
DEAN J MILLER LARRY A CROWLEY
McDEVITT & MILLER LLP THE ENERGY STRATEGIES
PO BOX 2564 INSTITUTE INC
BOISE ID 83702 5549 S CLIFFSEDGE AVE
E-mail: [e-mail] BOISE ID 83716
E-mail: [e-mail]
CLEARWATER PAPER CORP DR DON READING
C/O PETER J zuCHARDSON 6070 HILL ROAD
RICHARDSON ADAMS PLLC BOISE ID 83703
515 N 27rH STREET E-mail: [e-mail]
BOISE ID 83702
E-mail : peter@,ri chardsonadams. com
BRAD M PURDY SNAKE RIVER ALLIANCE
ATTORNEY AT LAW BOX 1731
2019 N 17TH STREET BOISE ID 83701
BOISE ID 83702 E-mail: [e-mail]
E-mail: bmpurdy@,hotmail.com kmiller@,snakeriveralliance.org
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
7IO N 6TH STREET
BOISE ID 83702
E-mail: [e-mail]
'; 2u, -r,
SECRETARY
CERTIFICATE OF SERVICE