20161216Donohue Direct.pdf

BEFORE THE F.::.C--IV D
· ~.u. r ·-·: 1 6 P 1 I : " 9 L" t i.,, ·---~· l
) IN THE MATTER OF INTERMOUNTAIN
GAS COMPANY'S APPLICATION TO
CHANGE ITS RATES AND CHARGES
FOR NATURAL GAS SERVICE.
) CASE NO. INT-G-16-02
)
)
)
___________ )
DIRECT TESTIMONY OF STACEY DONOHUE
IDAHO PUBLIC UTILITIES COMMISSION
DECEMBER 16, 2016
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Q. Please state your name and business address for
the record.
A. My name is Stacey Donohue. My business address is
472 West Washington Street, Boise, Idaho.
Q.
A.
By whom are you employed and in what capacity?
I am employed by the Idaho Public Utilities
Commission as a Utilities Analyst in the Utilities Division.
Q.
A.
What is your education, experience and background?
I received a B.A. in History from James Madison
University in 1999 and a Master's of Public Administration
(M.P.A.) from Boise State University in 2010. Prior to
joining the Commission Staff in 2010, I was employed as an
Energy Specialist at the Idaho Office of Energy Resources
where my main responsibility was managing the administration
of stimulus-funded energy efficiency and renewable projects.
While completing my M.P.A., I was hired by the Boise State
University Department of Public Policy and Administration to
conduct survey research and author a report on customer
service and state-wide interagency relationships for the
Idaho Transportation Department (ITD), which was presented
to the ITD Board . I have attended the New Mexico State
University Center for Public Utilities' course in Practical
Regulatory Training, the National Regulatory Research
Institute's course on "Electricity's Current Challenges,"
International Energy Program Evaluation Conferences, and the
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Association of Energy Services Professional Annual
Conference, as well as dozens of web trainings related to
utility issues. I serve on Idaho Power's Energy Efficiency
Advisory Group, Avista's Energy Efficiency Advisory
Committee, the Regional Technical Forum's Policy Advisory
Committee, the Northwest Energy Efficiency Alliance's Cost­
Effectiveness Committee, and Idaho Power's Integrated
Resource Planning Advisory Council. I have filed comments
representing Staff's position on electric and gas demand­
side management (DSM) program design and prudency, low­
income weatherization programs, demand response, fixed cost­
adjustment mechanism design and associated recovery,
integrated resource plans, and most recently, community
solar. In addition, I have filed testimony on DSM issues in
two general rate cases. In 2015, I was recognized by the
Northwest Energy Coalition with its 4 Under 40 leadership
award for my work in clean energy.
Q.
A.
What issues will your testimony address?
My testimony will address Intermountain Gas
Company's DSM proposal. I will focus on four particular
aspects of the proposal: 1) the Company's avoided cost
calculation and use of the Utility Cost Test (UCT); 2) the
proposed measures, cost-effectiveness calculations, and
incentives for efficiency and fuel-switching measures; 3)
concerns with the Conservation Potential Assessment (CPA)
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analysis, findings, and five year projections; and 4)
recommendations for aligning the Company's portfolio with
standard Idaho Commission DSM expectations.
Q.
A.
Please summarize your testimony.
I maintain that the Company's avoided cost
calculation and use of the UCT are reasonable. I also
believe that the cost-effectiveness calculations, sources,
and assumptions for Tier 1 energy efficiency rebates are
reasonable, but should be updated using a discount rate that
reflects the Company's real Weighted Average Cost of Capital
(WACC) rather than 20 year mortgage rates. However, I
recommend removing the Tier 2 direct use incentives for all
measures except for Energy STAR Certified Homes, because the
Company did not provide sufficient evidence quantifying the
benefit to customers. In addition, my review of the
Company's CPA found that the analysis and methodology are
not consistent with industry norms, which explains the very
small amount of forecasted savings for the first year and
for every year in the five year ramp-up period. Lastly, I
propose a handful of recommendations that would align the
Company's portfolio with standard Idaho Commission DSM
expectations.
Q. How will your testimony be organized?
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A. I will first describe the Company's proposed DSM
portfolio. My testimony will then be subdivided under the
following headings:
1) Avoided Cost and the UCT, p. 5
2) Proposed Measures, p. 8
3) CPA Analysis, p. 14
4) Idaho Commission's Standard DSM Expectations, p.
20
Q. Please explain the Company's DSM portfolio
proposal.
A. The portfolio consists of seven measures and the
Company offers two tiers of incentives for each measure.
Tier 1 is for "Energy Efficiency Rebates." Tier 2 is for
"Direct Use Rebates," also commonly known as fuel
conversions. The only exception to the two tier structure
is the Energy STAR Certified Home measure -it is only
available as a direct use measure.
The measures in both tiers are identical; the only
difference is the circumstance in which the measures are
installed. Tier 1 rebates apply when a measure replaces an
existing natural gas appliance (i.e. a natural gas furnace)
Tier 2 rebates apply when a measure is installed during a
fuel conversion (i.e. when a customer switches from electric
to natural gas space).
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As illustrated in Table 1, rebates for fuel conversions
are higher than energy efficiency rebates.
Table 1: Intermountain Gas's Proposed DSM Portfolio
Tier 1 Tier 2
EE Direct Measure Rebate Use
Rebate
Energy STAR Certified Homes n/a $1,200
95% AFUE Natural Gas Furnace $350 $500
Hi-EF Combination Radiant Heat $1,000 $1,200
80% AFUE Natural Gas Fireplace Insert $200 $250
70% FE Natural Gas Fireplace $100 $200
.67 Natural Gas Water Heater $50 $75
.91 EF Condensing Tankless Water Heater $150 $200
Source: Company Witness McGrath, Exhibit 31, page 12
Avoided Cost and the UCT
Q. Please explain your review of the Company's
avoided cost calculation and the use of the UCT.
A. The Company proposes to use a levelized avoided
cost target of $0.53182 that includes a $0.32764 commodity
cost and the fixed cost of gas, which the Company represents
are pipeline and storage costs at $0.20418. Staff was able
to closely replicate this value and confirmed that it aligns
with the avoided cost methodology approved by the Commission
in Order Nos. 33444 and 33464.
I also agree with the Company's use of the UCT.
The UCT is a test that measures the cost-effectiveness of
DSM measures. As Company Witness Spector correctly states:
"Idaho regulators now [accept] the Utility Cost Test (UCT) ."
Spector Direct at 7. Staff has long maintained that the UCT
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assesses cost-effectiveness more accurately and
transparently than the other cost-effectiveness tests do,
because the UCT is limited to the costs and benefits that
accrue to the utility, and hence, ratepayers. The
Commission has ·allowed utilities to use the UCT as the
threshold for determining cost-effectiveness. See Order No.
33365.
All of the energy efficiency measures (incented at
the Tier 1 level) are anticipated to be UCT cost-effective
with levelized costs per therm ranging from $0.393 to
$0.507, for an average of $0.379. About half of the direct
rebate measures (incented at the Tier 2 level) are
anticipated to be cost-effective under the UCT, with
levelized costs ranging from $0.424 to $0.610. The Company
anticipates that combined Tier 2 rebate offerings also will
be UCT cost-effective, with an average levelized cost of
$0.5214.
Q. Although you generally agree with the Company's
Tier 1 energy efficiency cost-effectiveness assumptions and
methodology, are there any aspects of the methodology with
which you disagree?
A. Yes. Although the Company's cost-effectiveness
assumptions for Tier 1 rebates are reasonable, I disagree
with the Company's use of the 20 year mortgage rate as a
discount rate for residential measures under the UCT.
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Q. Please explain why the 20 year mortgage rate is
not appropriate for the UCT, and recommend an alternative.
A. It is commonly accepted to use a 3-5% discount
rate for another cost-effectiveness test, the Total Resource
Cost Test (TRC). Further, I acknowledge the credible
argument made by Company Witness Spector around a very low
discount rate in her publication "Natural Selection: the
Evolution of DSM Valuation and the Use of the UCT" that was
provided in response to Staff Production Request No. 180.
Nevertheless, it remains standard practice to use the WACC
for the UCT. In addition, the Company's response to Staff's
Production Request No. 192 indicates that Nexant, the
Company's DSM consultant, applied the WACC to the UCT when
it developed Cascade Natural Gas's DSM portfolio. In
discussions with Staff, Intermountain Gas frequently
referenced its alignment with Cascade Natural Gas's
methodology in developing its DSM proposal.
In this case, Staff proposes a 7.1% discount rate
for the Company in Staff Witness Carlock's testimony.
important to note that if approved, 7.1% would be the
Company's nominal discount rate. However, I recommend
It is
converting this to the "real" discount rate within the cost­
effectiveness analysis in order to account for the effects
of inflation. This aligns with the methods currently used
by both Idaho Power and Avista. Adjusting the 7.1% nominal
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discount rate to account for inflation at 2.6% results in a
real discount rate of 3.54%.
Q. Does the Company's DSM portfolio remain cost-
effective using a different discount rate?
A. Yes. Staff's recommended discount rate is
slightly lower than the discount rate proposed by the
Company, so it increases the portfolio's cost-effectiveness.
Proposed Measures
Q. Do you support the Company's proposal to incent
the Tier 1 energy efficiency measures included in its DSM
proposal?
A. Yes, I support the Company's proposal to offer
Tier 1 energy efficiency rebates to customers who upgrade to
more efficient natural gas equipment.
Q.
A .
Why do you support the Company's proposal?
I reviewed each of the proposed measures, the
assumptions the Company used in its cost-effectiveness
calculations, the sources for those assumptions, the cost­
effectiveness methodology, and the results of the
calculations. These assumptions generally look reasonable,
but it is important to understand there is less data, and
therefore less consensus, on the amount of natural gas
savings per measure than for electric efficiency measures.
However, Intermountain Gas has supplied savings estimates
from Cascade Natural Gas, Nexant, KEMA Laboratories, the
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Consortium for Energy Efficiency, the U.S. Department of
Energy, and a variety of national gas utilities which
combined provide a reasonable basis from which to launch a
portfolio. As is standard practice for electric DSM
program, I recommend that Intermountain Gas's programs be
subjected to impact and process evaluations to verify these
savings and ensure that DSM is a cost-effective investment
for customers.
Q. Do you support the Company's proposal to incent
the Tier 2 direct use measures included in its DSM proposal?
A. No, I do not support incentives for Tier 2 direct
use measures. I am not opposed to incentives for fuel
conversions, but utilities must be able to quantify the
value of the resource to its customers in order to use
customer funds to acquire that resource. Company witness
Kirschner's testimony provides a high-level explanation
regarding the benefits of the direct use of natural gas to
customers and the environment, but the cost-effectiveness
analysis provided by Company witness Spector did not
quantify any of those benefits as they relate to
Intermountain Gas's customers.
Q. Please explain the cost-effectiveness analysis
Company witness Spector provided in her testimony and
accompanying exhibits to justify incentives for fuel
switching.
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A. The Company used an interesting assumption
regarding conversions: instead of assuming that the
efficient gas furnace installed during the conversion
replaces electric/propane/wood heat, the Company assumed
that the efficient gas furnace would replace an inefficient
gas furnace that the customer would have installed during
the conversion without the incentive. This means that Tier
1 (energy efficiency) measures and Tier 2 (direct use
measures) have exactly the same amount of energy savings in
the cost-effectiveness analysis. See Spector Direct,
Exhibit 26. In fact, all assumptions in the cost-
effectiveness calculations for Tier 1 and Tier 2 measures
are identical except for the increased incentives for Tier
2. Even though the Company's cost-effectiveness
calculations show the same amount of savings in both
circumstances, the Company is willing to pay a greater
incentive when the measure is part of a fuel conversion.
Q. Is this consistent with how other Idaho utilities
have valued fuel conversions in cost-effectiveness
calculations?
A. No. Avista also offers fuel conversions, but has
a very different approach. Because electric-to-gas fuel
conversions decrease electric consumption, Avista considers
fuel conversions to be an electric efficiency measure and
calculates the cost-effectiveness of the measure based on
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the avoided electric consumption plus the increased gas
consumption.
In contrast, Intermountain Gas's cost­
effectiveness calculations ignore the reduction in
electric/wood/propane use and the increased consumption of
natural gas that conversions generate. Instead, the Company
assumes that the customer was going to convert anyway and is
simply trying to ensure the conversion is as efficient as
possible. While that is a laudable goal, it means that the
resource the Company purchases with the incentive is the
efficient furnace or water heater, not the conversion.
Since the value of the resource for both stand-alone
efficiency measures and fuel conversions is the efficiency
of the new equipment, it is not reasonable to provide a
greater incentive for conversions.
Q. Why is the Company providing a higher incentive
for fuel switching than for energy efficiency?
A. The Company maintains that the higher incentive
for direct use measures offsets the higher cost that
customers incur when they convert to natural gas water or
space heat. Company witness Spector attests that "A higher
incentive will be provided for electric-to-gas equipment
upgrades in acknowledgment of the higher up-front equipment
costs and logistical costs of conversion." Spector Direct at
19.
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Q. On what basis do you oppose Intermountain Gas
paying a higher incentive for conversions, which certainly
have a higher incremental cost than efficiency measures?
A. It is a widely accepted industry practice to offer
higher incentives as necessary for measures with higher
incremental costs. An incentive to address the higher
incremental cost for fuel switching measures would also be
acceptable for Intermountain Gas if it had demonstrated
cost-effectiveness by accurately valuing the resource
deferred by the conversion (i.e. reduced
electric /wood/propane consumption plus increased natural gas
consumption). But since the Company only demonstrated the
cost-effectiveness of the efficiency aspect of the measure,
it is not reasonable to incent anything beyond the
incremental cost of the efficiency upgrade.
Q. The Company has stated that it needs to acquire
65,000 therms in energy savings for its DSM portfolio to be
cost-effective. How will removing the incentives for fuel
conversions impact this acquisition goal? For example, if
incentives for half of the measures are removed, will
savings drop by half (to 32,500 therms) and therefore no
longer be cost-effective?
A. The Company's energy savings goal (and therefore
cost-effectiveness of the portfolio) should not be adversely
affected by removing incentives for fuel conversions because
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the savings associated with fuel conversions and efficiency
measures are exactly the same-the only difference is the
amount of the incentive payment. Customers who are
converting to natural gas will still receive a rebate for
installing an energy efficient appliance as part of the
conversion, but under my proposal they will receive the Tier
1 incentive amount rather than the Tier 2 incentive amount.
It is possible that fewer people will upgrade to
an efficient appliance without the higher incentive when
converting to gas. However, this potential reduction in
savings will likely be offset in the cost-effectiveness
calculation by the reduction in expenses from removing the
higher Tier 2 incentive payments.
Q. Intermountain Gas already provides an incentive to
customers who convert to natural gas. How is that different
from the Company's proposal in this case?
A. The Company's current offering has some
similarities to its proposed Tier 2 rebates. The Company
currently offers incentives to customers for installing high
efficiency natural gas equipment when they convert to
natural gas. The current offering is reasonable because
incentive costs are not recovered in rates, but instead are
paid for by shareholders and, therefore, are not subjected
to the Commission's approval for recovery.
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Q. What is your recommendation regarding Tier 2:
Direct Use incentives?
A. Because it is not appropriate to value the
resource on an efficiency basis but pay the incentive based
on the cost of a conversion, I recommend that the Company
provide a Tier 1 rebate for each measure regardless of
whether it is installed in the context of a fuel conversion
or not.
The Company has categorized Energy STAR Certified
Homes as a direct use measure rather than an efficiency
measure because it is new construction. But because the
Company has only proposed one rather than two incentive
amounts for this measure, the distinction is not concerning.
I recommend including the Energy STAR Certified Homes
incentive in the single, consolidated list of incentives.
CPA Analysis
Q. Let's turn now to your concerns about the
Company's CPA analysis. To start, please explain what a CPA
is.
A. The National Action Plan for Energy Efficiency
(NAPEE) guide on potential studies states that a CPA -or
Conservation Potential Assessment -is "a quantitative
analysis of the amount of energy savings that either exists,
is cost-effective, or could be realized through the
implementation of energy efficiency programs and policies."
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See NAPEE 2007 at 2-1. CPAs are important because Idaho
utilities use them to determine the amount of energy
efficiency included as a resource in their Integrated
Resource Plans.
Q. Earlier, you stated you have some concerns with
the Company's CPA, analysis, findings, and five year savings
projections. Please explain your concerns.
A. I have two primary concerns with the CPA conducted
by Nexant for the Company: 1) the very limited number of
measures analyzed for savings potential; and 2) the
calculation used to estimate the portion of economic
potential that is achievable potential. These shortcomings
result in a very low first year achievable potential that
remains low in the five year projection of DSM savings.
Please elaborate. Q.
A. Sure. My first concern is that the Company's CPA
only analyzed the savings potential of seven residential
measures that the Company already planned to include in its
DSM portfolio. This is the opposite approach taken by most
other CPA analyses. Usually, a CPA analysis begins by
identifying and analyzing all available measures in order to
determine the amount of technical, economic, and achievable
energy efficiency potential in the service territory. For
electric utilities, the technical potential is calculated by
analyzing thousands of measures.
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natural gas DSM, but for comparison, Avista's 2014 Idaho
natural gas CPA included one hundred measures across the
residential, commercial, and industrial sectors.
Intermountain also opted not to analyze several
common residential measures often incented by other gas
utilities. Examples of some common residential measures
include replacing inefficient windows and showerheads,
adding attic and floor insulation, sealing HVAC ducting,
upgrading to programmable and/or smart thermostats,
conducting home energy evaluations and providing reports.
In addition to not analyzing these residential measures, the
Company decided not to analyze any commercial or industrial
energy efficiency measures.
The Company maintains that it did not conduct a
full CPA because it preferred to begin its DSM efforts with
a limited group of residential measures with which it has
direct experience. Beginning with a small subset of
measures that leads to a more robust portfolio is not an
unreasonable approach if there is a credible ramp-up in
subsequent years.
Q.
A.
Do you have any other concerns about the CPA?
Yes. A second concern I have with the Company's
CPA is the calculation used to get from economic potential
to achievable potential. After identifying the technical
potential, the second step in most CPAs is to calculate the
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economic potential by determining how much of the technical
potential is cost-effective after a utility's cost to incent
and administer the programs are included. The economic
potential is then further refined into the achievable
potential, which reflects the amount of cost-effective
energy efficiency that customers will acquire, often
referred to as market uptake.
During discussions with Staff, Intermountain
explained that three levels of achievable potential were
identified based on differing levels of incentives.
Including incentive costs at the achievable level is not
consistent with industry standards because those costs
should already have been included as part of the cost­
effectiveness screening at the economic level. However, the
bigger problem is that the Company's Response to Production
Request No. 192 indicated that the incentive costs, but not
administrative costs, were already included in the
calculation of economic potential. But the Company's
analysis showed a significant decrease between technical and
economic potential energy savings that does not appear to be
sufficiently explained if only administrative costs were
included, which could mean that incentive costs were counted
twice.
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Q. You also mentioned concerns about the level of
savings projected by the CPA. Please explain those
concerns.
A. Sure. Regardless of the details of the analysis,
the Company's CPA methodology produced savings targets that
are extremely low. In the first year, the Company only
found 97,825 therms of achievable savings, which is a 96%
reduction from the economic potential. According to the
Company, that is 0.04% of residential sales (Spector,
Exhibit 25) . Even after five years the achievable target
only amounts to 0.19% of residential sales.
To put that in context, Avista's 2016 Idaho gas
target is 230,000 therms of achievable savings from 70,500
residential customers. Avista's 2014 Washington gas CPA
found 275,980 therms of achievable first year savings from
141,000 residential customers. It would seem that
Intermountain Gas could produce more than 97,825 therms from
its 300,000 residential customers.
It's also important to note that the Company's
first year target is not based on the amount of achievable
energy savings identified in the CPA. The first year target
is actually based on a "programmatic" savings target of
65,000 therms, which means that savings as a percentage of
residential sales is lower than 0.04%.
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The Company has explained that the 65,000 therms
target is simply the minimum savings needed in order for the
portfolio to remain cost-effective. It further explains
that while it is committed to acquiring the achievable
target, it wanted to establish very realistic programmatic
targets to ensure portfolio viability in the early years.
I am not opposed to early, modest goals as the
Company learns how to implement a DSM portfolio, but it is
important for the Company to meaningfully accelerate its
acquisition into a more robust portfolio. In my discussions
with the Company personnel, they have stated that this
limited CPA was undertaken as a starting point that would
allow them to launch their DSM portfolio without undue
expense or complication. As such, they believe the 3 -5 year
potential estimates understate the savings they will
actually be able to acquire and have expressed a willingness
to conduct a more complete CPA in the future. I recommend
that the Commission order the Company to complete a CPA
developed according to industry best practices to inform and
be included with the Company's 2019 Integrated Resource
Plan.
Q. Should the Commission require the Company to
implement its DSM proposal even if the Commission does not
approve the Company's request for the FCCM?
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A. Yes. The Company's cost-effectiveness analysis
shows that its proposal is less expensive than the supply­
side alternative. Therefore, the Company should implement
it as a least cost resource.
Idaho Corcunission's Standard DSM Expectations
Q. Do you have any other recommendations regarding
the Company's proposal?
A. Yes, I recommend that the Commission order the
Company to adopt standard Idaho Commission DSM requirements
established for the three large electric and gas utilities.
These are well-established practices, familiar to the
Commission, Staff, and intervenors, and include forming an
energy efficiency advisory group comprised of stakeholders,
trade allies, and customers to help guide the Company's
implementation of its DSM portfolio . The Company should
also file an annual DSM report to document program
performance, cost-effectiveness, program implementation
methods, and expenditures. The Company's programs should be
periodically reviewed by third-party evaluators to verify
savings and confirm that delivery strategies align with
industry best practices.
The energy efficiency advisory group should also
advise the Company on other standard expectations, including
support for enhanced residential building codes,
participation in market transformation efforts, the
CASE NO. INT-G-16-02
12 /16 /16
DONOHUE, S. (Di) 20
STAFF
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potential for a low income offering, and establishing a
tariff rider for funding all DSM programs, which the Company
discussed with Staff. The advisory group could also provide
input on a more complete CPA as well as program
implementation practices that would help the Company ramp up
to a more meaningful level of DSM acquisition in the corning
years.
Q. Please list all of your recommendations in this
case.
A. I recommend that the Commission approve the
Company's proposed DSM portfolio with some important
changes.
First, I recommend that the Company calculate the
cost-effectiveness of its portfolio using the real WACC as
the discount rate.
Second, I recommend the Commission direct the
Company to incent all measures at the Tier 1 level only,
with the exception of the Energy STAR Certified Hornes
measure, which should receive the Tier 2 incentive.
Third, I recommend the Commission direct the
Company to conduct a CPA that meets or exceeds industry
standards in the context of its 2019 IRP.
Fourth, I recommend the Commission direct the
Company to align with standard Idaho Commission DSM
expectations, which include convening an energy efficiency
CASE NO. INT-G-16-02
12/16/16
DONOHUE, S. (Di) 21
STAFF
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advisory group comprised of stakeholders. This advisory
group can help the Company consider a plan for delivering an
annual DSM report, independent third-party evaluations,
support for enhanced residential building codes,
participation in market transformation efforts, a low income
offering, and the aforementioned improved CPA.
Q. Does this conclude your testimony in this
proceeding?
A. Yes, it does.
CASE NO. INT-G-16-02
12/16/16
DONOHUE, S. (Di) 22
STAFF
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 16TH DAY OF DECEMBER 2016,
SERVED THE FOREGOING DIRECT TESTIMONY OF STACEY DONOHUE, IN
CASE NO. INT-G-16-02, BY MAILING A COPY THEREOF, POSTAGE PREPAID,
TO THE FOLLOWING:
MICHAEL P McGRATH
DIR -REGULA TORY AFFAIRS
INTERMOUNTAIN GAS CO
PO BOX 7608
BOISE ID 83707
E-MAIL: [e-mail]
BRADMPURDY
ATTORNEY AT LAW
2019 N 17TH STREET
BOISE ID 83702
E-MAIL: [e-mail]
CHAD M STOKES
TOMMY A BROOKS
CABLE HUSTON LLP
1001 SW 5TH AVE STE 2000
PORTLAND OR 97204-1136
E-MAIL: [e-mail]
[e-mail]
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
710 N 6TH STREET
BOISE ID 83702
E-MAIL: [e-mail]
PETER RICHARDSON
GREGORY M ADAMS
RICHARDSON ADAMS PLLC
515 N 27TH STREET
BOISE ID 83702
E-MAIL: [e-mail]
[e-mail]
RONALD L WILLIAMS
WILLIAMS BRADBURY
1015 W HAYS ST
BOISE ID 83702
E-MAIL: [e-mail]
EDWARD A FINKLEA
EXECUTIVE DIRECTOR
NW INDUSTRIAL GAS USERS
545 GRANDVIEW DR
ASHLAND OR 87520
E-MAIL: [e-mail]
ELECTRONIC ONLY
MICHAEL C CREAMER
GIVENS PURSLEY LLP
E-MAIL: [e-mail]
F DIEGO RIV AS
NW ENERGY COALITION
1101 8TH AVENUE
HELENA MT 59601
E-MAIL: [e-mail]
SCOTT DALE BLICKENSTAFF
AMALGAMATED SUGAR CO LLC
1951 S SATURN WAY
STE 100
BOISE ID 83702
E-MAIL: sblickenstaff@ amalsugar.com
CERTIFICATE OF SERVICE
KEN MILLER
SNAKE RIVER ALLIANCE
PO BOX 1731
BOISE ID 83701
E-MAIL: [e-mail]
LANNY L ZIEMAN
NATALIE A CEPAK
THOMAS A JERNIGAN
EBONY M PAYTON
AFLOA/JA-ULFSC
139 BARNES DR STE 1
TYNDALL AFB FL 32403
E-MAIL: lanny.zieman. [e-mail]
[e-mail]
[e-mail]
[e-mail]
ANDREW J UNSICKER MAJ USAF
AFLOA/JACE-ULFSC
139 BARNES DR STE 1
TYNDALL AFB FL 32403
E-MAIL: Andrew. unsicker(a),us.af.mil
CERTIFICATE OF SERVICE