20221230Final_Order_No_35649.pdf

ORDER NO. 35649 1
Office of the Secretary
Service Date
December 30, 2022
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF THE APPLICATION
OF GREYLOCK ENERGY HOLDINGS, LLC
FOR APPROVAL OF ITS STOCK AND
OWNERSHIP INTERESTS PURCHASE
AGREEMENT WITH ISRAEL RAY FOR
THE ACQUISITION OF THE ATLANTA
POWER COMPANY

IN THE MATTER OF THE INVESTIGATION
OF ATLANTA POWER COMPANY
SERVICE AND CUSTOMER RELATION

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CASE NOS. ATL-E-22-02
ATL-E-22-01

ORDER NO. 35649

On October 14, 2022, Greylock Energy Holdings, LLC (“Greylock”), filed an application
with the Idaho Public Utilities Commission (“Commission”) for approval of a Stock and
Ownership Interests Purchase Agreement (“Agreement”) between Greylock and Israel Ray as the
majority, and only known, shareowner in the Atlanta Power Company (“Company”). The
Agreement provides for Greylock to purchase all of the assets of the Company including its
Certificate of Public Convenience and Necessity No. 300 (“CPCN”) for the provision of electric
service to the approximately seventy-five (75) individual customers in and around the community
of Atlanta, Idaho.
Greylock represents that it is an Idaho limited liability company formed for the purpose of
acquiring, owning, and operating the Company. Greylock has two owners each with a fifty percent
ownership interest who are comanagers. Both owners of Greylock represent they have significant,
relevant, and extensive experience running and operating electric utilities.
Greylock has filed for approval for the sale and purchase of Atlanta Power. The Agreement
provides for a purchase price of three hundred and sixty-five thousand ($365,000) dollars as well
as other terms and conditions. Greylock asserts that the proposed transaction is consistent with the
public interest and that Greylock has both the financial and technical ability as well as the bona
fide intent to operate and maintain the subject property in the public interest. Greylock represents
that upon acquisition of the Utility, Greylock will have, and will be able to maintain, the financial
ability to operate the Company consistent with good utility practices and Commission orders.
Further, Greylock does not propose any rate increase by reason of this transaction as its owners
ORDER NO. 35649 2
have personally assumed financial responsibility for all transaction costs associated with
Greylock’s acquisition of the Atlanta Power Company.
COMMISSION STAFF COMMENTS
Commission Staff (“Staff”) reviewed the Company’s PSA and accompanying documents,
Commission orders, customer complaints, responses to production requests, and the CPCN
transfer filing to determine if the sale of the Company and transfer of the CPCN complies with
statutory requirements. Additionally, Staff conducted an onsite assessment to determine the status
of the system and gauge any progress made in resolving system deficiencies identified earlier from
the 2018 Staff Report. Staff assessed and quantified the value of the assets contained within the
PSA.
Based upon its review, Staff recommended the Commission: (1) approve the sale of the
Company under the PSA with recommended modifications, and (2) approve the transfer of the
CPCN to the Company’s new owners. Staff believed the sale of the Company was supported by
the intent of Idaho Code § 61-328, and it was consistent with prior Commission orders.
A. Sale of the Company
1. Compliance with Commission Order No. 35465
In Order No. 35465, the Commission ordered the Company to:
• select an attorney to draft a contract and bill of sale.
• submit a first draft of the written PSA by August 5, 2022.
• submit a fully executed PSA by August 26, 2022.
• work with Staff to file a case with the Commission seeking approval of the transfer
of the Company’s CPCN by September 2, 2022.
Staff believed the Company complied with the first three items in the Order. However, the
Company did not file for the transfer of the CPCN until October 14, 2022.
2. Review of the PSA
Order No. 35465 required the PSA to contain a contingency plan in the event of default or
breach to protect the Company’s customers. However, Staff noted the PSA did not address or
contain the required contingency plan.
Order No. 35465 required the PSA to contain terms for the lease of Mr. Israel Ray’s land
where the diesel backup generator was located. However, Staff noted that the PSA did not contain
any such terms. A real estate property exchange or “land swap” was defined within Section 6.4 of
the PSA, which Staff believed might negate the need for a lease.
ORDER NO. 35649 3
Staff performed an analysis to quantify the system impact of the Payment Via Power Bill
Credit defined within Section 6.3 of the PSA. Staff explained that the credit provided up to a
maximum of 6,000 kilowatt hours (“kWhs”) per month for the Seller not to be billed for any future
use during his lifetime. Staff believed that if the 6,000 kWhs per month were fully used by the current
owner, it might constrain system capacity for remaining customers in the short term and the Buyers
might be required to add capacity to the system.
Staff reviewed the provided 2021 system billing data. Staff noted that the highest
residential monthly peak consumption across all residential customers was 4,015 kWhs, which
occurred in February of 2021. Staff believed that this amount provided a basis for an amount that
the Seller was not likely to exceed given the lack of metered data from his residence, and to ensure
the Seller was not billed for reasonable future use during his lifetime considering he maintained
normal residential consumption patterns.
3. Idaho Code § 61-328
The Application for the sale and purchase of assets must follow Idaho Code § 61-328 for
the sale of property by electric utilities. The statute requires that:
• the transaction is consistent with the public interest.
• the cost of and rates for supplying service will not be increased by reason of such
transaction.
• the applicant for such acquisition or transfer has the bona fide intent and financial
ability to operate and maintain said property in the public service.
i. Transaction Consistent with Public Interest
Staff believed that the sale of Atlanta Power to prospective owners, Nick Jones, and Gene
Haught,1 was consistent with the public interest. Staff’s conclusion was based on:
• the absence of system and operational improvements under the current owner.
• the System and Operational improvements likely to happen under new ownership.
a. Absence of System and Operation Improvements under
Current Owner
Staff determined that there have been minimal investments or improvements to the system
over the last four years to address system deficiencies under the current ownership. Staff performed
an assessment of the Company’s system and operations through an onsite visit in August of 2022
to identify any changes or improvements to address deficiencies identified in the 2018 on-site

1 Staff’s Comments in places identify Nick Jones and Gene Haught as the prospective owners of the Company. Rather,
Greylock is the prospective owner of the Company. Nick Jones and Gene Haught are equal members of Greylock.
ORDER NO. 35649 4
assessment. As a result of the 2022 assessment, Staff found little evidence of any physical or
operational changes to improve system reliability and safety under the current owner since 2018.
Because of the failure of the existing owner to make any significant improvements to the system
over time and address the concerns identified in the 2018 Staff Report, Staff believed that new and
capable ownership was needed.
b. System and Operational Improvements likely to happen under
New Owners
Staff believed that the Public Interest would be best served by authorizing the sale of the
Company to buyers Mr. Jones and Mr. Haught. Staff believed that since their involvement, the
Company had experienced a reduction in the number of customer complaints filed with the
Commission since 2017 and both buyers had already made contributions to maintain the
Company’s operations, demonstrating their technical capabilities and motivation while acting on
their own initiative over the past several years. Staff believed those qualities would be necessary
to improve the system and the Company’s operations in the future.
In 2017, Staff received 13 informal complaints filed against Atlanta Power. Over the past
four years (2018 through 2021), Staff received a total of seven informal complaints, a significant
reduction when compared to 2017. Year-to-date (“YTD”) 2022, Staff has received only one
informal complaint. Staff noted that customers were being served significantly better since local
assistance was put in place. Table No. 1 shows the types of informal complaints received from
2017 to 2022 YTD.
Table No. 1: Informal Customer Complaints by Year
Year Complaints Filed Against Atlanta Power
2022 Power off in evening, back-up generator not working
2021 Leaning pole
Nothing has progressed with sale
Sale still not complete
2020 Leaning pole
2019 Note: no complaints filed against Atlanta Power
2018 Failing to provide adequate service
2017 Wants deposit returned
Generator out of fuel (3 complaints)
Fluctuation in service
Placed on another rate without notice
Power outage
Issue with service line to dwelling
Claims generator should be supplying more power
ORDER NO. 35649 5
Claims generator needs tune up
Turbine is down, and generator is running constantly
Power outages
Failure to purchase fuel for generator

ii. Costs and Rates
Staff believed that Customer rates would not increase because of the sale and CPCN
transfer. Greylock did not propose any changes or increases to rates due to this transaction.
Greylock stated that it “does not propose any rate increase by reason of this transaction as its
owners have personally assumed financial responsibility for all transaction costs associated with
Greylock's acquisition of the Atlanta Power Company.” Application at 2.
iii. Bona Fide Intent and Financial Ability
Staff believed new ownership of the Company through this sale would result in ongoing
and meaningful improvement to the system’s reliability and its operation. Staff believed that the
new potential owners had shown their technical capabilities to operate, maintain, and repair the
system and had demonstrated their intention and motivation to make the necessary changes to
upgrade the system and improve its reliability, and had demonstrated financial ability to operate
the Company’s system by obtaining the necessary capital to purchase it and demonstrated
willingness to invest in it.
a. Technical Capabilities and Motivation of the New Owners
Staff believed that improvements to the system and the Company’s operation were likely
to improve under the new owners because of the buyer’s technical expertise and motivation to
improve the system. Staff noted that Mr. Haught has operated the system over the past three years
to reasonably ensure continued generation from the system, while also serving in a customer
service role. Since 2018, Company availability, responsiveness, system reliability, and dispute
resolution have greatly improved due to his involvement. Mr. Jones has also worked to improve
customer relations for the Company. Mr. Jones has demonstrated his technical skills and
capabilities and his understanding of power delivery necessary to repair the distribution system.
Mr. Jones has prior experience as a lineman and is technically credentialed as an instructor at a
lineman school. Staff believed those skills will be necessary for future improvement to the
Company’s system.
b. Financial Ability
Staff noted that in its Application, Greylock asserted it “will have, and will be able to
maintain, the financial ability to operate the Utility consistent with good utility practices and this
ORDER NO. 35649 6
Commission’s orders.” Id. Additionally, Greylock stated in its Application that its owners
personally assumed financial responsibility for all transaction costs associated with Greylock's
acquisition of the Atlanta Power Company.
4. Value of the Company’s Assets
Staff explained that due to the Company’s inability to provide adequate records of its Plant-
in-Service, Staff developed the basis for valuing it. Staff estimated Atlanta Power’s Plant-in-Service
and inventory valuation to be $292,580. The value of the Company’s assets in service were derived
from current benchmark prices for both material and installation costs sourced from other electric
utilities regulated by the Commission. Those values were adjusted to account for the year of
installation, escalation, and depreciation from the assets expected life. Any assets placed into
service prior to the last General Rate Case in 2008, Case No. ATL-E-08-02, were considered fully
depreciated consistent with the approved depreciation rates established in Case No. ATL-E-08-01.
Table No. 2 below provides the summary of Staff’s estimated net value of the Company’s assets.
Table No. 2: Net Asset Valuation
Description Amount
Utility Poles $116,886
Power Transformers $ 14,825
Wire Conductor $112,348
Air Compressor $ 4,957
Frequency Controller $ 8,750
Net Plant-in-Service $257,766
Materials & Supplies/Inventory $ 34,814
Total Assets $292,580

The total Plant-in-Service for the Company was $257,766. Most of the Company’s
valuation was attributed to the distribution plant, which included utility poles valued at $116,886,
power transformers valued at $14,825, and wire conductor valued at $112,348. Other equipment
used to operate and maintain the hydro plant was valued at $13,707. The Company also owns 5
utility poles, 3 power transformers, and 1 roll of wire conductor valued at $34,814, which are held
in inventory but not included in Plant-in-Service.
ORDER NO. 35649 7
Because Atlanta Power had no documentation on plant material or installation costs, Staff
considered plant asset valuation based on a like-kind approach. That is, if an asset was installed in
Atlanta Power’s system and pricing was available to a comparable asset from one of the other
regulated electric utilities, then this cost was used to estimate the Company’s installed cost.
Under the PSA, the buyers would purchase the Company and its assets from the current
owner to serve existing customers. There were additional assets that the buyers would be
purchasing. The Company had fuel in the tank for the generator, accounts receivable, and funds in
a current bank account. All of those were included in the total assets of the Company. The accounts
receivable had been confirmed from documentation provided by Atlanta Power’s billing clerk. The
quality of the accounts receivable might be compromised as some of the accounts were
significantly delinquent. Staff stated that the amount in the bank account included in the PSA could
not be determined. Staff requested copies of the bank statements in Production Request No. 21
(Case No. ATL-E-22-01) on September 2, 2022. The Company replied on November 18, 2022,
stating that “[t]he undersigned did not draft the Purchase Sale Agreement but, nonetheless, will
respond to this Request as quickly as possible.”
Table No. 3: Company Assets
Components Totals
Net Plant in Service $257,766
Materials & Supplies/Inventory $ 34,814
Fuel $ 1,821
Accounts Receivable $ 67,323
Cash (Bank Account Balance) $ ???
Total Company Assets $361,724

B. CPCN Transfer
Staff recommends the Commission transfer CPCN Certificate No. 300 to the new owners
of the Company upon approval of the sale of Atlanta Power to Greylock Energy Holdings, LLC.
Through Commission Order No. 21261, the Company currently holds CPCN Certificate No. 300
which identifies the boundaries of the Company’s service area. The Commission order specifically
delimits the certificated area in the following manner:
Begin at NW Corner Section 19, Township 6 North, Range 11
E.B.M. thence eastward to NE corner of Section 22; thence
ORDER NO. 35649 8
southward to NE corner Section 34; thence eastward to NE corner
Section 31, Township 6 N, Range 12 E.B.M.; thence southward to
SE corner Section 19, Township 5 N, Range 12 E.B.M.; thence
westward to SW corner Section 24, Township 5 N, Range 10
E.B.M.; thence northward to NW corner Section 1; thence eastward
to SW corner Section 31, Township 6 N, Range 11 E.B.M.; thence
northward to NW corner Section 19, Township 6 N, Range 11
E.B.M., the POINT OF BEGINNING
Staff reviewed the stated service area based on the description and attached map within Order No.
21261. Staff believed that the certificated area as described within the order was consistent with
the area in and around Atlanta, Idaho. Staff believed it was consistent with the current service area
provided by Atlanta Power. Given the remote location of Atlanta, Idaho, and it being surrounded
by Federal land, Staff believed it was unlikely the service territory would expand to overlap with
any other electric utility.
C. Customer Comments, Notice, Press Release, And Public Workshop
1. Customer Comments
Staff noted that the Commission received five customer comments in Case No. ATL-E-22-
01, Order No. 35302. One comment was submitted by Ms. Drake. Ms. Drake indicated that several
of the issues in her initial formal complaint had been resolved. She stated that Mr. Ray enlisted the
services of Mr. Haught, who was a fulltime resident of Atlanta, and that Mr. Haught assisted with
power outages, provided excellent customer service, and recruited assistants, which included Mr.
Jones, who was a training specialist at Northwestern Lineman College in Meridian, Idaho.
Other comments included one customer stating steady improvement in the electrical system
since Mr. Haught and Mr. Jones started working together and supported them purchasing Atlanta
Power. Another customer stated that Mr. Haught had been making improvement where he could,
and that Mr. Jones had the experience to improve the system. A fourth customer said that they are
now receiving the “best and most reliable power” they have experienced in forty-seven years.
Recently, Staff learned that the Company was unaware of several rules within Utility
Customer Relations Rules, IDAPA 31.21.01. Specifically, the Company was unaware of the
required customer notification process prior to disconnection of service. Staff recommended that
the Consumer Staff informally work with the Company, ensuring it gained an understanding of
Utility Customer Relations Rules, IDAPA 31.21.01. In addition to reviewing these rules, Staff
recommended that Consumer Staff work informally with the Company to review its notices and
other documents to ensure compliance.
ORDER NO. 35649 9
2. Customer Notice and Press Release
Staff noted that the Company did not issue a press release and customer notice. Customer
notification was done verbally. In February 2022, Mr. Haught began informing customers of the
proposed sale in person. When Mr. Haught saw a customer, he informed the customer of his and
Mr. Jones intent to purchase Atlanta Power. Mr. Haught indicated that all customers were aware
of the proposed sale and often contact him for updates.
3. Public Workshop
On Tuesday, November 29, 2022, the Commission hosted a virtual public workshop to
share information on the Application and answer questions. The workshop was held from 6:00
p.m. to 9:00 p.m. (MST). The public had multiple options to participate either in person, online
using Webex, or over the phone. One individual called in, two individuals used Webex, four
individuals participated in person, and four members of Commission Staff participated in person.
Staff’s presentation was approximately thirty minutes in duration followed by a brief question and
answer period. Staff continued to monitor both the call-in phone number and Webex for the
duration of the workshop.
D. Staff Recommendation
Staff recommended that the Commission approve the Purchase Sales Agreement and
authorize the transfer of CPCN Certificate Number 300 to the new owners and require the
following:
1. Order the seller to amend the PSA to include the contingency plan described in
Order No. 35465.
2. Order the seller to amend the PSA to provide complete legal descriptions of the
land swap described in Section 6.4 of the PSA, indicating clear ownership of the
seller and buyers.
3. Order the seller to amend the PSA to limit the monthly maximum consumption to
4,015 kWh at the seller’s residence.
4. Order the buyers to meet with Commission Staff to learn the requirements
associated with being a regulated utility including but not limited to filing
requirements, regulatory accounting, reporting, customer relations rules, and the
Utility Customer Relations Rules IDAPA 31.21.01. within 30 days of a Final Order.
5. Order the buyers to develop a backup process for meter reading, billing, and
accounting functions.
6. Order the buyers to provide updates on the 5-year Improvement Plan as a
supplement to the Commission required Annual Report.

ORDER NO. 35649 10
COMPANY COMMENTS
With respect to the contingency plan required by Order No. 36465, the Company stated
that it was unclear as to the precise expectations the Commission had in this regard and would
greatly appreciate clarification of what the Contingency Plan should entail, whose responsibility
it was to implement the plan, especially if the proposed sale was approved, and any other guidance
that the Commission was willing to provide.
With respect to obtaining a legal description of the land swap, the Company indicated it
was awaiting a further response from Elmore County regarding those possibilities. It was the
Company’s desire to ensure that buyers have access to the land they need to continue running the
electric system as soon as approval of the sale was received.
With respect to any reduction in the 6,000 kWhs usage, the Company stated it would
appreciate the opportunity to communicate with Staff regarding an analysis to better determine
what Mr. Ray’s likely consumption would be per month.
GREYLOCK COMMENTS
Greylock appreciated Staff’s comments. Greylock was uncertain of Staff’s
recommendation relative to a “contingency plan” as required by prior order. Greylock believed
that while a failsafe backup plan may be possible in a perfect world, it would have to be further
defined and quantified before Greylock could opine either as to its reasonableness or, equally
importantly, as to its possible impact on Greylock’s ability to consummate the transaction
contemplated under the current PSA.
COMMISSION DISCUSSION AND FINDINGS
The Commission has jurisdiction over this matter under Idaho Codes §§ 61-119, -129, -
101, -302, -406, -501, -515, and -701. The Company is an electrical corporation as defined in Idaho
Code § 61-119, and a public utility as defined in Idaho Code § 61-129. The Commission has
authority to supervise and regulate every public utility within the State of Idaho and do all things
necessary to carry out the spirit and intent of the Public Utility Law. Idaho Code § 61-501. The
Commission has the authority to enforce Public Utility Laws and impose penalties upon utilities
for failing to act in accordance with those laws. Idaho Code §§ 61-406 and -701. As a public utility
furnishing electric power to customers within the State of Idaho, the Company must furnish,
provide, and maintain such service, instrumentalities, equipment, and facilities that are adequate,
efficient, just, and reasonable and promote the safety, health, comfort, and convenience of its
patrons, employees, and the public. Idaho Code § 61-302.
ORDER NO. 35649 11
Pursuant to Idaho Code § 61-328, before authorizing the transaction, the Commission shall
find: (1) that the transaction is consistent with the public interest; (2) that the cost of and rates for
supplying service will not be increased by reason of such transaction; and, (3) that the applicant
for such acquisition or transfer has the bona fide intent and financial ability to operate and maintain
said property in the public service. Idaho Code § 61-328. Having reviewed the record, all submitted
materials, and the comments of the parties, the Commission finds that the requirements of Idaho
Code § 61-328 have been met.
The Commission finds that the sale of the Company to Greylock is consistent with the
public interest. The record shows that the Company has experienced a reduction in the number of
customer complaints filed with the Commission since 2017. This reduction may be attributed to
the involvement of Greylock’s members, Mr. Haught and Mr. Jones in the operation of the
Company. Similarly, the record shows that Mr. Haught and Mr. Jones have made contributions to
maintain the Company’s operations, and the Commission believes that transfer of ownership in
this case will facilitate even further improvement to the Company’s system and operations in the
future.
The Commission finds that the cost of and rates for supplying service will not be increased
by this transaction. The record shows that Greylock has not proposed nor requested any changes
or increases to rates due to this transaction.
The Commission finds that the applicant in this case has the bona fide intent and financial
ability to operate and maintain said property in the public service. The record shows that Greylock
through its members Mr. Haught and Mr. Jones, has the technical capabilities to operate, maintain,
and repair the system, and have demonstrated its intention and motivation to make the necessary
changes to upgrade the system and improve its reliability. Further, Mr. Haught and Mr. Jones have
demonstrated the financial ability to operate the Company’s system by obtaining the necessary
capital to purchase the Company and have demonstrated willingness to invest in the Company to
provide safe and reliable service to Atlanta Power customers.
Having found that Idaho Code § 61-328 has been satisfied, the Commission approves
Greylock’s Application with the following conditions. The primary goal of the Commission is to
ensure that Atlanta customers receive safe and reliable service; to that end, in the event of any
alleged breach of the PSA by either party, such that the provision of the PSA and ownership of
Atlanta Power comes into question, the parties shall file an application and present the Commission
with a plan for the continued operation of Atlanta Power during the pendency of any litigation.
ORDER NO. 35649 12
Further, no later than August 1, 2023, the parties shall submit updated and complete legal
descriptions of the land swap described in Section 6.4 of the PSA, indicating clear ownership of
the land in question, and clearly delineating Greylock’s access to all equipment and land necessary
for the continued operation of Atlanta Power.
Finally, Greylock shall meet with Commission Staff within thirty (30) days of this Final
Order to learn the requirements associated with being a regulated utility including but not limited
to filing requirements, regulatory accounting, reporting, customer relations rules, and the Utility
Customer Relations Rules IDAPA 31.21.01. Greylock shall also work with Staff to develop a
backup process for meter reading, billing, and accounting functions; and Greylock shall provide
updates on its 5-year Improvement Plan as supplements to its required Annual Reports.
As an additional matter, in companion case ATL-E-22-01, Order No. 35465, the Company
was assessed present and ongoing civil monetary penalties pursuant to Idaho Code §§ 61-706 and
61-707. The Commission suspended those penalties subject to certain conditions concerning the
potential sale of the Company. The Commission finds that under the specific facts and
circumstances in this case, the Company has substantially complied with the requirements of Order
No. 35465.
ORDER
IT IS HEREBY ORDERED that Greylock’s Application for the purchase of Atlanta Power
and the transfer of Certificate of Public Convenience and Necessity No. 300 is approved.
IT IS FURTHER ORDERED that in the event of any alleged breach of the PSA by either
party, such that the provision of the PSA and ownership of Atlanta Power comes into question, the
parties shall file an application and present the Commission with a plan for the continued operation
of Atlanta Power during the pendency of any litigation, so that Atlanta Power customers continue
to receive safe and reliable service.
IT IS FURTHER ORDERED that no later than August 1, 2023, the parties shall submit
updated and complete legal descriptions of the land swap described in Section 6.4 of the PSA,
indicating clear ownership of the land in question, and clearly delineating Greylock’s access to all
equipment and land necessary for the continued operation of Atlanta Power.
IT IS FURTHER ORDERED that Greylock shall meet with Commission Staff within thirty
(30) days of this Final Order to learn the requirements associated with being a regulated utility
including but not limited to filing requirements, regulatory accounting, reporting, customer
relations rules, and the Utility Customer Relations Rules IDAPA 31.21.01.
ORDER NO. 35649 13
IT IS FURTHER ORDERED that Greylock shall work with Staff to develop a backup
process for meter reading, billing, and accounting functions.
IT IS FURTHER ORDERED that Greylock shall provide updates on its 5-year
Improvement Plan as supplements to its required Annual Reports.
IT IS FURTHER ORDERED that the penalties outlined in Case No. ATL-E-22-01, Order
No. 35465, are vacated.
THIS IS A FINAL ORDER. Any person interested in this Order may petition for
reconsideration within twenty-one (21) days of the service date of this Order. Within seven (7)
days after any person has petitioned for reconsideration, any other person may cross-petition for
reconsideration. Idaho Code § 61-626.
DONE by Order of the Idaho Public Utilities Commission at Boise, Idaho this 30th day of
December 2022.

ERIC ANDERSON, PRESIDENT

JOHN CHATBURN, COMMISSIONER

__________________________________________
JOHN R. HAMMOND JR., COMMISSIONER

ATTEST:

Jan Noriyuki
Commission Secretary
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