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Gregg S. Kantor Senior Vice President Public & Regulatory Affairs Telephone: 503.220.2425 Toll Free: 800.422.4012 Facsimile: 503.220.2584 Email: [email protected] November 15, 2006 VIA ELECTRONIC FILING Public Utility Commission of Oregon 550 Capitol Street N.E., Suite 215 P.O. Box 2148 Salem, OR 97308-2148 Attention: Filing Center Re: Submission of Draft Private Letter Ruling Pursuant to Order No. 06-532 in AR 499 Northwest Natural Gas Company (“NW Natural”) hereby submits the attached draft private letter ruling (“PLR”) to the Oregon Public Utility Commission (the “Commission”) pursuant to the final rules promulgated under Order No. 06-532. NW Natural is also providing a copy of the PLR to Commission staff, the Northwest Industrial Gas Users (“NWIGU”) and the Citizens’ Utility Board (“CUB”). A copy of the PLR is available to the other participants on the service list to Docket No. AR 499 upon request. Sincerely, /s/ Gregg S. Kantor Gregg S. Kantor Attachment: Draft Private Letter Ruling cc: Ed Busch, OPUC Staff (w/attachment) Judy Johnson, OPUC Staff (w/attachment) Jason Jones, OPUC Staff (w/ attachment) Paula Pyron, NWIGU (w/ attachment) Jason Eisdorfer, CUB (w/ attachment) Remaining AR 499 Service List (w/o attachment)

VIA ELECTRONIC FILING · CERTIFICATE OF SERVICE I hereby certify that on the 15th day of November, 2006, I served the foregoing NORTHWEST NATURAL’S SUBMISSION OF DRAFT PRIVATE LETTER

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Page 1: VIA ELECTRONIC FILING · CERTIFICATE OF SERVICE I hereby certify that on the 15th day of November, 2006, I served the foregoing NORTHWEST NATURAL’S SUBMISSION OF DRAFT PRIVATE LETTER

Gregg S. Kantor Senior Vice President Public & Regulatory Affairs Telephone: 503.220.2425 Toll Free: 800.422.4012 Facsimile: 503.220.2584 Email: [email protected]

November 15, 2006 VIA ELECTRONIC FILING Public Utility Commission of Oregon 550 Capitol Street N.E., Suite 215 P.O. Box 2148 Salem, OR 97308-2148 Attention: Filing Center

Re: Submission of Draft Private Letter Ruling Pursuant to Order No. 06-532 in AR 499

Northwest Natural Gas Company (“NW Natural”) hereby submits the attached draft private letter ruling (“PLR”) to the Oregon Public Utility Commission (the “Commission”) pursuant to the final rules promulgated under Order No. 06-532. NW Natural is also providing a copy of the PLR to Commission staff, the Northwest Industrial Gas Users (“NWIGU”) and the Citizens’ Utility Board (“CUB”). A copy of the PLR is available to the other participants on the service list to Docket No. AR 499 upon request. Sincerely, /s/ Gregg S. Kantor Gregg S. Kantor Attachment: Draft Private Letter Ruling cc: Ed Busch, OPUC Staff (w/attachment)

Judy Johnson, OPUC Staff (w/attachment) Jason Jones, OPUC Staff (w/ attachment)

Paula Pyron, NWIGU (w/ attachment) Jason Eisdorfer, CUB (w/ attachment)

Remaining AR 499 Service List (w/o attachment)

mailto:[email protected]
Page 2: VIA ELECTRONIC FILING · CERTIFICATE OF SERVICE I hereby certify that on the 15th day of November, 2006, I served the foregoing NORTHWEST NATURAL’S SUBMISSION OF DRAFT PRIVATE LETTER

CERTIFICATE OF SERVICE

I hereby certify that on the 15th day of November, 2006, I served the foregoing NORTHWEST NATURAL’S SUBMISSION OF DRAFT PRIVATE LETTER RULING PURSUANT TO ORDER NO. 06-532 IN AR 499 – COVER LETTER ONLY upon each party listed below via electronic mail (“e-mail”) if provided or by U.S. Mail if e-mail was not provided. __Kelley C. Miller_________ Kelley C. Miller, Staff Assistant Rates & Regulatory Affairs NW NATURAL 220 NW Second Avenue Portland, Oregon 97209-3991 1.503.226.4211, extension 3589

OPUC DOCKET NO. AR 499 Official Service List

R TOM BUTLER [email protected]

REP TOM BUTLER H-289 STATE CAPITOL SALEM OR 97310 [email protected]

JIM DEASON ATTORNEY AT LAW 1 SW COLUMBIA ST, SUITE 1600 PORTLAND OR 97258-2014 [email protected]

KEN LEWIS PO BOX 29140 PORTLAND OR 97296

PORTLAND GENERAL ELECTRIC COMPANY RATES & REGULATORY AFFAIRS 121 SW SALMON ST 1WTC0702 PORTLAND OR 97204 [email protected]

ANN L FISHER ATTORNEY AT LAW PO BOX 25302 PORTLAND OR 97298-0302 [email protected]

JULIE BRANDIS ASSOCIATED OREGON INDUSTRIES 1149 COURT ST NE SALEM OR 97301-4030 [email protected]

LISA F RACKNER, ATTORNEY ATER WYNNE LLP 222 SW COLUMBIA ST STE 1800 PORTLAND OR 87201-6618 [email protected]

DAVID J MEYER VICE PRESIDENT & CHIEF COUNSEL AVISTA CORPORATION PO BOX 3727 SPOKANE WA 99220-3727 [email protected]

THOMAS R PAINE AVISTA CORPORATION 1411 EAST MISSION SPOKANE WA 99202 [email protected]

DON M FAULKER MANAGER REVENUE REQUIRMENTS AVISTA UTILITIES PO BOX 3727 SPOKANE WA 99220-3727 [email protected]

RON MCKENZIE MANAGER REGULATOR ACCOUNTING AVISTA UTILITIES PO BOX 3727 SPOKANE WA 99220-3727 [email protected]

KELLY O NORWOOD VICE PRESIDENT-STATE & FEDERAL REGULATION AVISTA UTILITIES PO BOX 3727 SPOKANE WA 99220-3727 [email protected]

EDWARD A FINKLEA CABLE HUSTON BENEDICT HAAGENSEN & LLOYD LLP 1001 SW 5TH – STE 2000 PORTLAND OR 97204 [email protected]

Certificate of Service, Page 1

Page 3: VIA ELECTRONIC FILING · CERTIFICATE OF SERVICE I hereby certify that on the 15th day of November, 2006, I served the foregoing NORTHWEST NATURAL’S SUBMISSION OF DRAFT PRIVATE LETTER

Certificate of Service, Page 2

LOWREY R BROWN CITIZENS' UTILITY BOARD OF OREGON 610 SW BROADWAY - STE 308 PORTLAND OR 97205 [email protected]

JASON EISDORFER CITIZENS' UTILITY BOARD OF OREGON 610 SW BROADWAY - STE 308 PORTLAND OR 97205 [email protected]

ROBERT JENKS CITIZENS' UTILITY BOARD OF OREGON 610 SW BROADWAY - STE 308 PORTLAND OR 97205 [email protected]

DAVE JUBB CITY OF PORTLAND [email protected]

DANIEL W MEEK ATTORNEY AT LAW 10949 SW 4TH AVE PORTLAND OR 97219 [email protected]

MELINDA J DAVISON DAVISON VAN CLEVE PC 333 SW TAYLOR STE 400 PORTLAND OR 97204 [email protected]

PAUL GRAHAM DEPARTMENT OF JUSTICE REGULATED UTILITY & BUSINESS SECTION 1162 COURT ST NE SALEM OR 97301-4096 [email protected]

JASON W JONES DEPARTMENT OF JUSTICE REGULATED UTILITY & BUSINESS SECTION 1162 COURT ST NE SALEM OR 97301-4096 [email protected]

DENNIS J MAURER DEPARTMENT OF REVENUE [email protected]

KELLY FRANCONE, CONSULTANT ENERGY STRATEGIES 215 SOUTH STATE ST STE 200 SALT LAKE CITY UT 84111 [email protected]

DAN PFEIFFER IDAHO PUBLIC UTILITY COMMISSION 472 WEST WASHINGTON ST BOISE ID 83720 [email protected]

MICHAEL EARLY INDUSTRIAL CUSTOMERS OF NORTHWEST UTILITIES 333 SW TAYLOR STE 400 PORTLAND OR 97204 [email protected]

JIM ANDERSON JD ANDERSON ASSOCIATES 910 SAHALEE CT SE SALEM OR 97306 [email protected]

LINDA K WILLIAMS KAFOURY & MCDOUGAL 10266 SW LANCASTER RD PORTLAND OR 97219-6305 [email protected]

ANDREA FOGUE LEAGUE OF OREGON CITIES PO BOX 928 1201 COURT ST NE STE 200 SALEM OR 97308 [email protected]

SARAH J ADAMS LIEN MCDOWELL & ASSOCIATES PC 520 SW SIXTH AVE STE 830 PORTLAND OR 97204 [email protected]

KATHERINE A MCDOWELL MCDOWELL & ASSOCIATES PC 520 SW SIXTH AVE STE 830 PORTLAND OR 97204 [email protected]

RICK TUNNING MIDAMERICAN ENERGY HOLDINGS COMPANY 666 GRAND AVENUE DES MOINES IA 50303 [email protected]

STEVE EVANS MIDAMERICAN ENERGY HOLDINGS COMPANY 666 GRAND AVENUE DES MOINES IA 50303 [email protected]

PAULA E PYRON NORTHWEST INDUSTRIAL GAS USERS 4113 WOLF BERRY COURT LAKE OSWEGO OR 97035-1827 [email protected]

LARRY O MARTIN PACIFIC POWER & LIGHT 825 NE MULTNOMAH STE 800 PORTLAND OR 97232 [email protected]

JAN MITCHELL PACIFIC POWER & LIGHT 825 NE MULTNOMAH STE 2000 PORTLAND OR 97232 [email protected]

Page 4: VIA ELECTRONIC FILING · CERTIFICATE OF SERVICE I hereby certify that on the 15th day of November, 2006, I served the foregoing NORTHWEST NATURAL’S SUBMISSION OF DRAFT PRIVATE LETTER

Certificate of Service, Page 3

PAUL M WRIGLEY PACIFIC POWER & LIGHT 825 NE MULTNOMAH STE 800 PORTLAND OR 97232 [email protected]

LAURA BEANE PACIFICORP 825 NE MULTNOMAH STE 2000 PORTLAND OR 97232 [email protected]

SCOTT BOLTON PACIFICORP 825 NE MULTNOMAH PORTLAND OR 97232 [email protected]

RICHARD PEACH PACIFICORP 825 NE MULTNOMAH PORTLAND OR 97232 [email protected]

AUSEY H ROBNETT III PAINE HAMBLEN COFFIN BROOKE & MILLER LLP PO BOX E COEUR D’ALENE ID 83816-0328 [email protected]

BENJAMIN WALTERS PORTLAND CITY OF – OFFICE OF CITY ATTORNEY 1221 SW 4TH AVE – RM 430 PORTLAND OR 97204 [email protected]

RANDALL DAHLGREN PORTLAND GENERAL ELECTRIC 121 SW SALMON ST 1WTC 0702 PORTLAND OR 97204 [email protected]

PAMELA G LESH PORTLAND GENERAL ELECTRIC 121 SW SALMON ST 1WTC 0703 PORTLAND OR 97204 [email protected]

RAUL MADARANG PORTLAND GENERAL ELECTRIC 121 SW SALMON ST PORTLAND OR 97204 [email protected]

DAVE ROBERTSON PORTLAND GENERAL ELECTRIC 121 SW SALMON ST PORTLAND OR 97204 [email protected]

INARA K SCOTT PORTLAND GENERAL ELECTRIC 121 SW SALMON ST PORTLAND OR 97204 [email protected]

BOB TAMLYN PORTLAND GENERAL ELECTRIC 121 SW SALMON ST PORTLAND OR 97204 [email protected]

DOUGLAS C TINGEY PORTLAND GENERAL ELECTRIC 121 SW SALMON ST 1WTC13 PORTLAND OR 97204 [email protected]

JAY TINKER PORTLAND GENERAL ELECTRIC 121 SW SALMON ST 1WTC 0702 PORTLAND OR 97204 [email protected]

MARK NELSON PUBLIC AFFAIRS COUNSEL PO BOX 12945 SALEM OR 97309 [email protected]

JUDY JOHNSON PUBLIC UTILITY COMMISSION PO BOX 2148 SALEM OR 97308-2148 [email protected]

ED BUSCH PUBLIC UTILITY COMMISSION PO BOX 2148 SALEM OR 97308-2148 [email protected]

STATE CAPITOL SENATOR RICK METSGER 900 COURT ST NE S-307 SALEM OR 97301 [email protected]

STATE CAPITOL SENATOR VICKI L WALKER 900 COURT ST NE S-210 SALEM OR 97301 [email protected]

MARCUS A WOOD STOEL RIVES LLP 900 SW FIFTH AVE – STE 2600 PORTLAND OR 97204 [email protected]

MATTHEW W PERKINS DAVISON VAN CLEVE PC 333 SW TAYLOR STE 400 PORTLAND OR 97204 [email protected]

Page 5: VIA ELECTRONIC FILING · CERTIFICATE OF SERVICE I hereby certify that on the 15th day of November, 2006, I served the foregoing NORTHWEST NATURAL’S SUBMISSION OF DRAFT PRIVATE LETTER
Page 6: VIA ELECTRONIC FILING · CERTIFICATE OF SERVICE I hereby certify that on the 15th day of November, 2006, I served the foregoing NORTHWEST NATURAL’S SUBMISSION OF DRAFT PRIVATE LETTER
Page 7: VIA ELECTRONIC FILING · CERTIFICATE OF SERVICE I hereby certify that on the 15th day of November, 2006, I served the foregoing NORTHWEST NATURAL’S SUBMISSION OF DRAFT PRIVATE LETTER
Page 8: VIA ELECTRONIC FILING · CERTIFICATE OF SERVICE I hereby certify that on the 15th day of November, 2006, I served the foregoing NORTHWEST NATURAL’S SUBMISSION OF DRAFT PRIVATE LETTER
Page 9: VIA ELECTRONIC FILING · CERTIFICATE OF SERVICE I hereby certify that on the 15th day of November, 2006, I served the foregoing NORTHWEST NATURAL’S SUBMISSION OF DRAFT PRIVATE LETTER
Page 10: VIA ELECTRONIC FILING · CERTIFICATE OF SERVICE I hereby certify that on the 15th day of November, 2006, I served the foregoing NORTHWEST NATURAL’S SUBMISSION OF DRAFT PRIVATE LETTER
Page 11: VIA ELECTRONIC FILING · CERTIFICATE OF SERVICE I hereby certify that on the 15th day of November, 2006, I served the foregoing NORTHWEST NATURAL’S SUBMISSION OF DRAFT PRIVATE LETTER
Page 12: VIA ELECTRONIC FILING · CERTIFICATE OF SERVICE I hereby certify that on the 15th day of November, 2006, I served the foregoing NORTHWEST NATURAL’S SUBMISSION OF DRAFT PRIVATE LETTER
Page 13: VIA ELECTRONIC FILING · CERTIFICATE OF SERVICE I hereby certify that on the 15th day of November, 2006, I served the foregoing NORTHWEST NATURAL’S SUBMISSION OF DRAFT PRIVATE LETTER
Page 14: VIA ELECTRONIC FILING · CERTIFICATE OF SERVICE I hereby certify that on the 15th day of November, 2006, I served the foregoing NORTHWEST NATURAL’S SUBMISSION OF DRAFT PRIVATE LETTER
Page 15: VIA ELECTRONIC FILING · CERTIFICATE OF SERVICE I hereby certify that on the 15th day of November, 2006, I served the foregoing NORTHWEST NATURAL’S SUBMISSION OF DRAFT PRIVATE LETTER
Page 16: VIA ELECTRONIC FILING · CERTIFICATE OF SERVICE I hereby certify that on the 15th day of November, 2006, I served the foregoing NORTHWEST NATURAL’S SUBMISSION OF DRAFT PRIVATE LETTER
Page 17: VIA ELECTRONIC FILING · CERTIFICATE OF SERVICE I hereby certify that on the 15th day of November, 2006, I served the foregoing NORTHWEST NATURAL’S SUBMISSION OF DRAFT PRIVATE LETTER
Page 18: VIA ELECTRONIC FILING · CERTIFICATE OF SERVICE I hereby certify that on the 15th day of November, 2006, I served the foregoing NORTHWEST NATURAL’S SUBMISSION OF DRAFT PRIVATE LETTER
Page 19: VIA ELECTRONIC FILING · CERTIFICATE OF SERVICE I hereby certify that on the 15th day of November, 2006, I served the foregoing NORTHWEST NATURAL’S SUBMISSION OF DRAFT PRIVATE LETTER
Page 20: VIA ELECTRONIC FILING · CERTIFICATE OF SERVICE I hereby certify that on the 15th day of November, 2006, I served the foregoing NORTHWEST NATURAL’S SUBMISSION OF DRAFT PRIVATE LETTER
Page 21: VIA ELECTRONIC FILING · CERTIFICATE OF SERVICE I hereby certify that on the 15th day of November, 2006, I served the foregoing NORTHWEST NATURAL’S SUBMISSION OF DRAFT PRIVATE LETTER
Page 22: VIA ELECTRONIC FILING · CERTIFICATE OF SERVICE I hereby certify that on the 15th day of November, 2006, I served the foregoing NORTHWEST NATURAL’S SUBMISSION OF DRAFT PRIVATE LETTER
Page 23: VIA ELECTRONIC FILING · CERTIFICATE OF SERVICE I hereby certify that on the 15th day of November, 2006, I served the foregoing NORTHWEST NATURAL’S SUBMISSION OF DRAFT PRIVATE LETTER
Page 24: VIA ELECTRONIC FILING · CERTIFICATE OF SERVICE I hereby certify that on the 15th day of November, 2006, I served the foregoing NORTHWEST NATURAL’S SUBMISSION OF DRAFT PRIVATE LETTER
Page 25: VIA ELECTRONIC FILING · CERTIFICATE OF SERVICE I hereby certify that on the 15th day of November, 2006, I served the foregoing NORTHWEST NATURAL’S SUBMISSION OF DRAFT PRIVATE LETTER
Page 26: VIA ELECTRONIC FILING · CERTIFICATE OF SERVICE I hereby certify that on the 15th day of November, 2006, I served the foregoing NORTHWEST NATURAL’S SUBMISSION OF DRAFT PRIVATE LETTER
Page 27: VIA ELECTRONIC FILING · CERTIFICATE OF SERVICE I hereby certify that on the 15th day of November, 2006, I served the foregoing NORTHWEST NATURAL’S SUBMISSION OF DRAFT PRIVATE LETTER
Page 28: VIA ELECTRONIC FILING · CERTIFICATE OF SERVICE I hereby certify that on the 15th day of November, 2006, I served the foregoing NORTHWEST NATURAL’S SUBMISSION OF DRAFT PRIVATE LETTER
Page 29: VIA ELECTRONIC FILING · CERTIFICATE OF SERVICE I hereby certify that on the 15th day of November, 2006, I served the foregoing NORTHWEST NATURAL’S SUBMISSION OF DRAFT PRIVATE LETTER
Page 30: VIA ELECTRONIC FILING · CERTIFICATE OF SERVICE I hereby certify that on the 15th day of November, 2006, I served the foregoing NORTHWEST NATURAL’S SUBMISSION OF DRAFT PRIVATE LETTER
Page 31: VIA ELECTRONIC FILING · CERTIFICATE OF SERVICE I hereby certify that on the 15th day of November, 2006, I served the foregoing NORTHWEST NATURAL’S SUBMISSION OF DRAFT PRIVATE LETTER
Page 32: VIA ELECTRONIC FILING · CERTIFICATE OF SERVICE I hereby certify that on the 15th day of November, 2006, I served the foregoing NORTHWEST NATURAL’S SUBMISSION OF DRAFT PRIVATE LETTER
Page 33: VIA ELECTRONIC FILING · CERTIFICATE OF SERVICE I hereby certify that on the 15th day of November, 2006, I served the foregoing NORTHWEST NATURAL’S SUBMISSION OF DRAFT PRIVATE LETTER
Page 34: VIA ELECTRONIC FILING · CERTIFICATE OF SERVICE I hereby certify that on the 15th day of November, 2006, I served the foregoing NORTHWEST NATURAL’S SUBMISSION OF DRAFT PRIVATE LETTER
Page 35: VIA ELECTRONIC FILING · CERTIFICATE OF SERVICE I hereby certify that on the 15th day of November, 2006, I served the foregoing NORTHWEST NATURAL’S SUBMISSION OF DRAFT PRIVATE LETTER
Page 36: VIA ELECTRONIC FILING · CERTIFICATE OF SERVICE I hereby certify that on the 15th day of November, 2006, I served the foregoing NORTHWEST NATURAL’S SUBMISSION OF DRAFT PRIVATE LETTER
Page 37: VIA ELECTRONIC FILING · CERTIFICATE OF SERVICE I hereby certify that on the 15th day of November, 2006, I served the foregoing NORTHWEST NATURAL’S SUBMISSION OF DRAFT PRIVATE LETTER
Page 38: VIA ELECTRONIC FILING · CERTIFICATE OF SERVICE I hereby certify that on the 15th day of November, 2006, I served the foregoing NORTHWEST NATURAL’S SUBMISSION OF DRAFT PRIVATE LETTER
Page 39: VIA ELECTRONIC FILING · CERTIFICATE OF SERVICE I hereby certify that on the 15th day of November, 2006, I served the foregoing NORTHWEST NATURAL’S SUBMISSION OF DRAFT PRIVATE LETTER
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Page 42: VIA ELECTRONIC FILING · CERTIFICATE OF SERVICE I hereby certify that on the 15th day of November, 2006, I served the foregoing NORTHWEST NATURAL’S SUBMISSION OF DRAFT PRIVATE LETTER
Page 43: VIA ELECTRONIC FILING · CERTIFICATE OF SERVICE I hereby certify that on the 15th day of November, 2006, I served the foregoing NORTHWEST NATURAL’S SUBMISSION OF DRAFT PRIVATE LETTER
Page 44: VIA ELECTRONIC FILING · CERTIFICATE OF SERVICE I hereby certify that on the 15th day of November, 2006, I served the foregoing NORTHWEST NATURAL’S SUBMISSION OF DRAFT PRIVATE LETTER
Page 45: VIA ELECTRONIC FILING · CERTIFICATE OF SERVICE I hereby certify that on the 15th day of November, 2006, I served the foregoing NORTHWEST NATURAL’S SUBMISSION OF DRAFT PRIVATE LETTER
Page 46: VIA ELECTRONIC FILING · CERTIFICATE OF SERVICE I hereby certify that on the 15th day of November, 2006, I served the foregoing NORTHWEST NATURAL’S SUBMISSION OF DRAFT PRIVATE LETTER
Page 47: VIA ELECTRONIC FILING · CERTIFICATE OF SERVICE I hereby certify that on the 15th day of November, 2006, I served the foregoing NORTHWEST NATURAL’S SUBMISSION OF DRAFT PRIVATE LETTER
Page 48: VIA ELECTRONIC FILING · CERTIFICATE OF SERVICE I hereby certify that on the 15th day of November, 2006, I served the foregoing NORTHWEST NATURAL’S SUBMISSION OF DRAFT PRIVATE LETTER
Page 49: VIA ELECTRONIC FILING · CERTIFICATE OF SERVICE I hereby certify that on the 15th day of November, 2006, I served the foregoing NORTHWEST NATURAL’S SUBMISSION OF DRAFT PRIVATE LETTER
Page 50: VIA ELECTRONIC FILING · CERTIFICATE OF SERVICE I hereby certify that on the 15th day of November, 2006, I served the foregoing NORTHWEST NATURAL’S SUBMISSION OF DRAFT PRIVATE LETTER
Page 51: VIA ELECTRONIC FILING · CERTIFICATE OF SERVICE I hereby certify that on the 15th day of November, 2006, I served the foregoing NORTHWEST NATURAL’S SUBMISSION OF DRAFT PRIVATE LETTER
Page 52: VIA ELECTRONIC FILING · CERTIFICATE OF SERVICE I hereby certify that on the 15th day of November, 2006, I served the foregoing NORTHWEST NATURAL’S SUBMISSION OF DRAFT PRIVATE LETTER
Page 53: VIA ELECTRONIC FILING · CERTIFICATE OF SERVICE I hereby certify that on the 15th day of November, 2006, I served the foregoing NORTHWEST NATURAL’S SUBMISSION OF DRAFT PRIVATE LETTER
Page 54: VIA ELECTRONIC FILING · CERTIFICATE OF SERVICE I hereby certify that on the 15th day of November, 2006, I served the foregoing NORTHWEST NATURAL’S SUBMISSION OF DRAFT PRIVATE LETTER
Page 55: VIA ELECTRONIC FILING · CERTIFICATE OF SERVICE I hereby certify that on the 15th day of November, 2006, I served the foregoing NORTHWEST NATURAL’S SUBMISSION OF DRAFT PRIVATE LETTER
Page 56: VIA ELECTRONIC FILING · CERTIFICATE OF SERVICE I hereby certify that on the 15th day of November, 2006, I served the foregoing NORTHWEST NATURAL’S SUBMISSION OF DRAFT PRIVATE LETTER

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bank/Briefs/Harvell, Montice Terrill.d…  · Web view(ROA p . 57) The settled ... 427, 516 S.E.2d 106, 118 (1999) ... I certify that the foregoing Defendant-Appellant’s Brief

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