uwiw994.swrg.doc

SCOTT WOODBURY
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 1895

Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983

Attorney for the Commission Staff

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF THE SECOND JOINT APPLICATION OF UNITED WATER IDAHO INC. AND BARBER WATER CORPORATION FOR AN ORDER APPROVING THE PURCHASE BY UNITIED WATER IDAHO INC. OF WATER SERVICE PROPERTIES OWNED BY BARBER WATER CORPORATION; FOR AUTHORITY TO EXPAND UNITED WATER IDAHO'S CERTIFICATE OF PUBLIC CONVENIENCE AND NECESSITY NO. 143 AND FOR APPROVAL OF RATES AND CHARGES. )
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CASE NO. UWI-W-99-4

COMMENTS OF THE COMMISSION STAFF
COMES NOW the Staff of the Idaho Public Utilities Commission, by and through its Attorney of record, Scott Woodbury, Deputy Attorney General, and in response to the Notice of Application, Notice of Scheduling, Notice of Intervention Deadline, Notice of Hearing and Order No. 28136 issued on August 30, 1999, submits the following comments in the above referenced docket.

INTRODUCTION
A Joint Application was filed by United Water Idaho Inc. (UWI) and Barber Water Corporation (Barber Water) on August 18, 1999. In the Application the two companies request that the Commission approve the sale and transfer of the Barber Water domestic water system to UWI. The proposed purchase price is $58,000, with UWI estimating an additional $55,000 in capital expenditures to upgrade and repair the system.
UWI proposes to install master meters on the Barber Water wells at its earliest opportunity. The Company will monitor total system consumption and on a bimonthly basis prorate total water consumption equally to each residential customer. Each customer would pay for the average water consumption figure using the current UWI residential rates for a ¾ inch service connection.
In order to help mitigate the expected sudden increase in the customer bills due to the switch to consumption based billings and UWI rates, UWI has proposed to retain the current Barber Water residential customer rates for a period of six months. The six-month interim period would begin upon completion of the master meter installation. Furthermore, UWI proposes to concurrently provide each customer information regarding the expected payment that would occur based on UWI residential rates. The “for information-only bills” will allow Barber customers to modify consumption patterns to reduce water consumption as well as prepare for the increase in the billings. UWI proposes to set the Idaho Shakespeare Festival rates at current UWI tariffed meter rates.
The current Barber Water rates are $10.90 per month in the summer and $8.90 per month in the winter. Under the UWI residential rates, Staff estimates that the average bill may be as much as $28.00 per month in the summer and $15.90 per month in the winter (using Barber Water 1998 meter data).
Staff notes that this is the second application filed with the Commission concerning sale of the Barber Water system to UWI. The first application, Case No. UWI-W-99-2 dated April 5, 1999, was withdrawn by the companies on June 16, 1999. Reference Order No. 28076, June 18, 1999.

In summary, the two companies request the following in the Application:
1. Approval of the sale of Barber Water’s assets to UWI.
2. Confirmation of UWI’s request to include in rate base the $58,000 purchase price of the Barber Water system assets and up to $55,000 in capital improvements.
3. Confirmation of UWI’s right to provide water service to the area now served by Barber Water.
Amendment of UWI’s Certificate of Convenience and Necessity No. 143 to include the area presently served by Barber Water.
5. Cancellation of Barber Water’s Certificate of Convenience and Necessity No. 277.
6. A. Adoption and continuation of Barber Water’s current residential tariff rates
for water service for six months.
B. Change to UWI’s residential tariff rates and billing procedures after six
months.
7. Approval of immediate use of UWI tariff rates and billing procedures for the Idaho
Shakespeare Festival facility.

BACKGROUND
Barber Water provides water service to approximately 241 residential customers located in the Barberton and Golden Dawn Estates subdivisions. The subdivisions are located east of Boise in Ada County along the old State Highway 21. Additionally, Barber Water provides water service to the Idaho Shakespeare Festival (Shakespeare) facility, which is a non-contiguous site, located across old State Highway 21 approximately 1/4 mile east of Barberton and Golden Dawn Estates. Pumping capacity of the Barber Water system is reported to be approximately 550,000 gallons per day, given two wells with pumping capacities of 180 gallons per minute and 200 gallons per minute. The Barber Water system includes a 200,000-gallon reservoir located on a hill above and to the north of the subdivisions. Staff notes that the water system (i.e., wells) is located in an area of limited groundwater; therefore, potential for development of groundwater wells is also limited.
The current owners of Barber Water have expressed a desire to retire from operation of the system and feel they can no longer provide sufficient service to the customers. They also feel they would not be able to obtain the necessary financing to initiate needed repairs to the system, perform system improvements, and meet government guidelines for certification and testing. Additionally, they cite the problem of dealing with customer complaints and late payments as reasons for retiring.
UWI provides water service to approximately 60,000 customers within Ada and Canyon Counties. Included in UWI’s service area are the Warm Springs Mesa and Surprise Valley subdivisions located to the northwest and south, respectively, of the Barber Water service area.
In addition, it is speculated that UWI will apply for certification to provide domestic water service to the proposed Harris Ranch development, which would be immediately adjacent to the Barber Water service area.
UWI has stated they have the technical and financial resources to implement the system repairs and modifications. UWI expects these repairs will ensure good, reliable and safe water service for the Barber Water customers. Furthermore, UWI will employ telemetering equipment and round-the-clock customer service contacts that will allow a quick response to water service problems.

STAFF ANALYSIS
Given the desire of the current owners to sell the system and uncertainty about their ability to finance system repairs and modifications, Staff believes acquisition by UWI would be in the public interest. This is a position not arrived at easily, as customers in the Barber Water service area will experience a significant increase in rates as a result of being absorbed into the higher cost UWI system. However, Staff notes that the Barber Water system is aging, as evidenced by the repairs to the reservoir and wells UWI intends to make, and that UWI is not only proposing to acquire the assets but the future liability to repair and replace the aging system. It is this future liability and UWI’s financial ability to meet these future needs that prompts Staff not to oppose the acquisition of the system by UWI. UWI is also expected to provide the Barber Water customers with a higher level of customer service, and the system assets are expected to be a benefit to UWI’s planned expansion of service into the area.
In the following sections the financial issues, purchase price, water system improvements, meter installation options, proposed customer rates, customer comments and agency status related to the proposed purchase are evaluated.

Barber Water Financial Evaluation
Barber Water Company carries on its books a net book value for plant in service of negative $52,742 at year-end 1998. For ratemaking purposes, the net book value would be restated to $11,035. The difference between the two book values is due to Barber Water’s continued over depreciation of its gross plant in service which includes $84,125 of contributions in aid of construction. This difference in recorded depreciation versus allowed depreciation produces a difference in the stockholders equity in Barber Water of $63,777. Equity shown on the Barber Water books is a negative $48,229. Equity restated for the over depreciation of contributions is a positive $15,548.
The ratemaking book value of $11,035 when compared to the proposed sale price of $58,000 indicates that the sale price includes a premium on the sale of regulated assets of $46,965.
Staff does not oppose the amount of the premium nor its inclusion in rate base in future cases.
Customers of Barber Water have paid rates that include recovery of appropriate depreciation expense. In that regard, the customers have in essence acquired an equitable interest in the assets of Barber Water. The Supreme Court of Idaho in Boise Water Corporation vs. Idaho Public Utilities Commission, 99 Idaho 158, 578 P.2d 1089 (1978) regarding the sale of Boise Water Company’s old general office building stated: “One way of looking at a depreciation allowance on a utility’s personal property is that the public buys that property from the utility as it is used up. In one sense, therefore, the company owns depreciable property and when the company sells depreciable property, the ratepayers are entitled to have the sale treated as if it were the sale of the ratepayers’ property.”
Customers also have, through the purchase of their residential lots, acquired an interest in the initial cost of installing the water system serving the Golden Dawn and Barberton subdivisions. Barber Water carries on its books contributions in aid of construction in the amount of $84,125. These contributions include all the real property of Barber Water including the reservoir and well sites. The Commission stated in Order No. 27798 (Case No. UWI-W-98-2, Acquisition of South County Water by United Water), “Contributed property was then and is still appropriately excluded from rate base. The requested addition to rate base was not a capital investment of South County stockholders.” (Page 7) Accordingly, it is the customers of Barber Water, not the company that has a vested interest in the real estate properties included in the contributions in aid of construction account.
The ratemaking accumulated depreciation amount of $57,386 together with the recorded contributions in aid of construction in the amount of $84,125 indicate that customers have acquired an interest in the Barber Water system in the amount of $141,511.
Although one could argue that customers are entitled to 93% ($141,511/$152,546) of the premium paid by UWI, Staff believes that the owners of Barber Water have, over the years, done a good job of managing the system. United Water’s proposal to retain the existing rates for a period of 6 months will flow over $17,000 (37% of the premium) of benefit back to the customers in effect providing a sharing of the premium with the customers.
Accounting for acquisitions of operating property by one utility from another is well established in regulatory utility accounting theory and practice. The Uniform System of Accounts for Class A Water Utilities (NARUC 1996) Accounting Instruction No. 21 B. (Pg. 25) sets forth the accounting procedures to be followed by the acquiring utility when an operating system is purchased. The premium paid by one utility for purchase of the assets of another utility is an “acquisition adjustment” as defined by the Uniform System of Accounts for Water Companies. “Accounting for Public Utilities” (© Mathew Bender & Co., 1995) by Robert L. Hahne and Gregory E. Aliff of Deloitte & Touche § 4.04[2] states: “…if a utility acquires major fixed assets (i.e., an operating unit or system) from another utility by purchase, merger, consolidation, liquidation, or otherwise at a price in excess of the seller’s original cost (net of accumulated depreciation), the addition to the acquiring utilities rate base reflecting the acquired assets may be limited to the undepreciated original price. The excess amount paid is referred to as an acquisition adjustment and is placed in a separate account to be treated as so authorized by the jurisdictional regulatory commission.”
Accounting theory dictates that United Water should record the acquisition as follows:

Debits Credits
Plant in Service $152,546
Acquisition Adjustment $ 46,965
Accumulated Depreciation $ 57,386
Contributions in Aid of Construction $ 84,125
Cash $ 58,000

The acquisition adjustment could be treated in one of several ways. Generally, acquisition adjustments are excluded from rate base and amortized below the line (charged to stockholders) unless the regulatory commission specifically authorizes some other ratemaking procedure. Some commissions have allowed amortization of the acquisition adjustment above the line (included in expenses recoverable from customers) while not allowing a return on the unamortized balance (excluded from rate base). In other cases, commissions have allowed both a return on the investment and recovery of the amortization expense in setting customer rates. Although it clearly stated an intent not to set precedent, the Idaho Commission in case specific rulings has allowed UWI’s recovery of acquisition adjustments related to purchase of the South County and Mesa Water systems.
UWI has requested that it be allowed to earn a return on the premium (acquisition adjustment) and to recover its depreciation/amortization costs in rates. UWI is not seeking any change in rates at this time but is seeking assurance from the Commission that it will receive such favorable treatment of its purchase costs in the future. Given the value of the excess water supply discussed later in these comments, Staff does not oppose this proposal in this case but believes the Commission must once again reiterate its position that approval should not be taken as precedent.
Staff proposes that under no circumstances should UWI’s total investment in the Barber Water system including purchase price, well and reservoir repair, telemetry equipment, and meter installation costs exceed what UWI’s rates will support (based on the Commission authorized rate of return). Maximum supportable cost is estimated to be $186,000 at this time.

Purchase Price Evaluation
The terms of the sale as stated in the Joint Application submitted by UWI and Barber Water are summarized as follows:

1. Sale of Barber Water’s assets to UWI for $58,000.
2. UWI will invest up to $55,000 in capital improvements (telemetering and automated control systems $15,000; repair storage reservoir $35,000; and, rehabilitate wells $5,000).
UWI would assume ownership of all equipment and property used in furnishing domestic water service to the area served by Barber Water.

The assets to be purchased by UWI include two groundwater wells and associated property, transmission/distribution system, and storage reservoir and associated property. The $58,000 purchase price was determined based on a financial analysis by UWI and adjusted to meet Staff recommendations in Case No. UWI-W-99-2. The proposed purchase price, relative to the operating income may result in a return on investment of up to 20% which exceeds UWI’s authorized rate of return of 9.51%, based on UWI’s calculations. This indicates that the purchase of the Barber Water system will have a positive effect on existing UWI customers since it will bring in more money than it costs to serve.
Staff has performed a calculation of the “value” of the excess capacity of the Barber Water system. This excess capacity may be used in the future to serve other UWI customers, thereby deferring the development of other resources. Based on information provided by UWI in other cases, a source capacity of 1.2 gpm per customer is used in planning peak consumption. The Barber Water system with an estimated well capacity of 380 gpm (excluding storage reservoir capacity) thereby could support 317 customers. The Barber Water system currently has 241 customers plus the equivalent of 16 residential customers for the Idaho Shakespeare Festival site. This appears to indicate that the Barber Water system can accommodate an additional 60 customers (72 gpm). At an estimated value of $208 per gpm and an available capacity of 72 gpm, the source supply value of the wells is approximately $14,976. The excess source supply value could range up to $75,240 assuming an estimated $1,045 per gpm treated surface water source supply cost. Staff therefore has determined that the proposed net purchase premium of $46,965 paid by UWI to be received by Barber Water stockholders is a reasonable estimate of the premium value for the excess water source supply.
As previously indicated Staff will not oppose the inclusion of the proposed purchase price of $58,000 in rate base.

System Improvements Evaluation
UWI personnel have inspected the Barber Water equipment and determined that repairs and modifications are required to bring the system up to regulatory and UWI standards. Barber Water owners, who are aware that the system is in need of repair and modification, have stated they “… are not in a position to upgrade, handle repairs, respond to emergencies and provide service that a large corporation such as United Water can offer ...”
Installing a telemetering and automatic control system is planned by UWI. The telemetering system will be used by UWI to monitor system operation from a central location, including allowing the Company to determine if the pumps are not operating. In addition, UWI plans to install an automatic control system on the pumps and storage reservoir that will be used to maintain a preset level in the storage reservoir. UWI anticipates that these modifications will ensure reliable service to the Barber Water customers in the future.
The proposed repairs to the storage reservoir are necessary due to leakage. The reservoir is a subgrade concrete tank with a corrugated metal-wood frame cover. The concrete is reported to have cracked as a result of soil subsidence over the twenty- plus years since the tank was installed. The leaks, although unquantified to date, appear to be significant based on the visible pooling of water downslope from the reservoir. UWI is proposing to install a flexible membrane liner on the bottom of the reservoir. Staff believes UWI should be able to complete the repair prior to the end of the six-month rate freeze period. Staff therefore recommends the Commission require that the storage tank be fully repaired before customers are switched to UWI metered rates.
UWI also proposes to inspect and rehabilitate as necessary, the wells. A downhole camera inspection of each well will be performed to determine the condition of the well casing. In addition, UWI will install disinfection equipment (chlorine-based) on each well in accordance with internal UWI procedures. Maintaining a disinfection residual is conducted by UWI in order to ensure safe water supply. UWI reports that the disinfection system will be operated to meet State of Idaho, Division of Environmental Quality standards (DEQ).
No additional modifications or improvements to the Barber Water system are proposed by UWI at this time. If and when the Harris Ranch development is initiated, UWI may serve the first phases using the excess capacity of the Barber Water system. System modifications will be performed as needed at that time.
Therefore, Staff recommends approval of the $55,000 in proposed modifications and repairs to the Barber Water system, and, when completed that UWI be allowed to include this amount in rate base.

Metering Options Evaluation
Barber Water provides service to its residential customers through a water distribution system that is not currently metered. It is not unusual for water systems with adequate water supply to have a flat unmetered rate. However, Staff prefers metered service whenever possible because it is a more equitable and accurate way to determine consumption. It also encourages responsible water usage, it promotes conservation and it is consistent with service provided other customers of United Water.
Barber Water customers currently do not have meters installed on the service lines (with the exception of the Idaho Shakespeare Festival service line which has a 2-inch meter set in place). UWI has stated that it does not intend to install meters unless and until large-scale maintenance repairs are required on the distribution system. The costs for installing the meters at the onset of the purchase were deemed by UWI to not be justified due to the typical lower than average consumption patterns for mobile home parks.
Although Staff believes that use of individual metering may be more equitable than flat rates for Barber Water residents that have small yards or use gravel to reduce maintenance, Staff acknowledges that the cost of installing individual meters is expected to be excessive (i.e., result is a negative impact on existing UWI customers). Staff therefore recommends the use of master metering, which is expected to provide a balance between the use of flat rates and individual metering. The master metering allows billings to reflect actual system consumption, consequently giving customers a price indicator for periods of high consumption and lower payments during periods of low consumption.

Proposed Customer Rates
In the Application, UWI has proposed using master meters to determine total system consumption and then in turn using the data as the basis for estimating individual consumption. The total system consumption, less Idaho Shakespeare Festival consumption, would be averaged equally to each customer. The current UWI residential rates (3/4-inch service) would then be applied to this average consumption.
The anticipated impact of changing to a consumption based billing system and UWI metered rates is expected to be significant for Barber Water customers. At current rates, Barber Water customers pay $8.90 per month in the winter and $10.90 per month in the summer ($19.80 and $21.80 bimonthly, respectively). Staff has estimated average customer billings using average consumption of 1998 data and UWI residential rates. The billings may be as high as $28.00 per month in the summer and $15.90 per month in the winter, based on Barber Water 1998 meter data ($56.00 and $31.80 bimonthly, respectively). A comparison of current Barber Water rates and proposed UWI master metered rates is given in the table below.

Current Rates & Billings
Estimated Billings
Increase Winter $8.90 per month $15.90 per month $7.00 per month
79% Summer $10.90 per month $28.00 per month $17.10 per month
257% Annual ($/year) $118.80 per year $263.50 per year $144.70 per year
122%
Notes:
1. Estimated future Barber Water billings based on estimated 1998 consumption figures. Storage tank leakage has not been accounted for in the calculations and therefore the estimates are considered high-end estimates. Also assume a breakdown in consumption of 35%/65% for winter/summer per UWI experience.
2. Barber Water currently bills customers on a monthly basis where as UWI bills on a bimonthly basis. The bimonthly billings are expected to accentuate the apparent increase to customers.

The majority of the Barber Water customers reportedly are retired and on fixed incomes, and there are concerns about a large sudden increase in rates. In order to help mitigate the expected increase in customer bills due to the switch to consumption based billings and UWI rates, UWI has proposed to retain the current Barber water residential customer rates for a period of six months. The six-month interim period would begin upon completion of the master meter installation.
Furthermore, UWI has proposed to concurrently provide customers with information regarding the expected payment that would occur based on UWI residential rates. The “for information-only bills” will allow Barber customers to modify consumption patterns to reduce water consumption as well as prepare for the increase in the billings. Staff estimates that this rate freeze also provides a benefit to the customers of up to $17,438 over the six-month period.
Staff recommends a one time educational package, developed by UWI and approved by Staff, in lieu of the UWI’s proposed “for information-only bills.” This package should be sent during the six-month rate freeze period. The mailing should include a comparison between the winter/summer rate structure, a sample bi-monthly billing statement, an explanation of metered versus flat rates and the customer charge, and a summary of the customer rules (pamphlet). This information will help explain to the customer the changes that will occur under UWI management.
Staff recommends approval of UWI’s proposal to continue the current Barber Water residential rates of $8.90 per winter month and $10.90 per summer month for six months after the master meters are installed. Following the six-month period, the customers will be billed in accordance with UWI residential tariffs (3/4-inch service) using average consumption figures.
UWI proposes to use the existing UWI meter rates for the Idaho Shakespeare Festival service connection (customer charge $41.64 bimonthly and commodity charge $0.9113 per CCF winter rate, $1.1388 per CCF summer rate). Staff is in agreement with the proposal to apply existing UWI metered rates to the Idaho Shakespeare Festival site, given that a meter is already in place.

Customer Comments
Staff has noted a significant interest by Barber Water customers in this Application. In response to the earlier case, UWI-W-99-2, a petition with approximately 108 names of individuals reported to be served by Barber Water was submitted to the Commission. These customers requested that an open public hearing be held regarding the sale. UWI in anticipation of the significant interest by the customers held a public informational meeting on May 4, 1999 at the Idaho State Parks and Recreation building located adjacent to the Idaho Shakespeare Festival site. In this meeting Barber Water and UWI presented information on the proposed sale, background information on UWI, and answered questions from the approximately 75 individuals present at the meeting. The questions covered a broad range of areas including rate increases, billing changes, chlorination, historic customer contributions, metering, Harris Ranch development potential impacts, and system modifications, repairs and cleanup. The Commission has scheduled a formal public hearing for October 14, 1999.

Customer Liaison Team
United Water proposes and Staff supports the formation of a customer liaison team during the ownership transitional period (approximately one-year). The team members decide the procedure and how often to meet. A staff person from the Commission has served on these teams in the past and found it very successful in addressing customer issues and questions. The customer liaison team would address specific customer concerns including but not limited to system repairs and upgrades to be performed by UWI, the six month rate freeze, UWI residential rates and billing procedures, and issues regarding the installation of individual customer meters.

IDWR and DEQ Status
The Idaho Department of Water Resources (IDWR) was contacted regarding several issues. In conversations with Gary Spackman, IDWR, it was learned that Barber Water was issued an amended water rights permit. A copy of the amended permit was provided to Staff by Barber Water.
In addition, Staff contacted DEQ personnel regarding their findings from inspections of the Barber Water system. DEQ employee Steve Ray conducted a brief site investigation in the fall of 1998. He indicated that no formal report was issued because of the reported pending sale of the company; rather he would wait until UWI had repaired and modified the system and then conduct a complete system audit. Specific issues of concern he did note in the brief audit are: repair storage reservoir basin; repair or replace storage reservoir roof; install storage reservoir level controls; install check valve on small well pump; and isolate Harris Ranch well connection. In addition, Mr. Ray expressed concern regarding the proper disinfection of the service line running to the Idaho Shakespeare Festival site.

Summary
Staff has reviewed the Application and production request information provided by Barber Water and UWI. Based on an analysis of the information presented, Staff’s positions are summarized as follows:

( Staff agrees to the purchase of the Barber Water system by UWI. The improvements in the storage reservoir, wells and control systems are expected to improve customer service. Additionally, the UWI’s customer services are expected to be a benefit to Barber Water customers.

( Staff recommends that the proposed purchase price of $58,000 be accepted and allowed in rate base.

( Staff recommends that UWI initiate the system repairs and modifications at its earliest convenience. Storage tank repairs are to be completed before implementation of UWI residential rates.

( Staff recommends that UWI be required to open a separate work order to accumulate all of the costs of this acquisition. UWI should record all costs of purchase, repairs to wells and reservoirs, installation of telemetry equipment, premiums and master meter installation costs to the work order. The costs for these improvement activities are not to exceed $55,000. To the extent these costs together with the $58,000 purchase price exceed the maximum cost UWI’s rates will support, the excess cost should be recorded below the line or written off and excluded from rate base in future cases. Staff initially estimated the maximum cost (including the final purchase price) that can be supported to be $186,000.

( Within 30 days of PUC approval of the sale, Staff recommends that UWI be required to inform customers of the changes in system management, billing procedures and rates through the preparation and mailing of a customer educational package accepted by Staff.

( Within 30 days of PUC approval of the sale, Staff recommends the formation of a customer liaison team to address specific customer concerns including the system repairs, rate freeze, UWI residential rates and billing procedures, and the installation of individual customer meters.

( Staff recommends that current Barber Water residential customer rates, $8.90 per winter month and $10.90 per summer month, be continued for no more than six months after master meter installation and operation. After this period, the applicable UWI ¾ inch residential metered rates should be applied, based on total system consumption averaged equally on a per customer basis.

( Staff recommends the Idaho Shakespeare Festival rates be set using the existing UWI tariff rates effective immediately. Idaho Shakespeare Festival consumption shall be deducted from the total system consumption before determining the average residential customer consumption.

( Staff proposes approval of UWI’s right to provide water service to the area now served by Barber Water and to the amendment to UWI’s Certificate of Convenience and Necessity No. 143, as filed.

( Staff proposes that the cancellation of Barber Water’s Certificate of Convenience and Necessity No. 277 and Barber Water’s current tariffs for water service be approved as filed.

Dated at Boise, Idaho, this day of September 1999.

________________________
Scott Woodbury
Deputy Attorney General

Technical Staff: George Fink
Robert Smith

Consumer Staff: Judy Stokes

SW:GF:gdk:i:umisc/comments/uwiw994.swrg

STAFF COMMENTS 1 SEPTEMBER 29, 1999