20140429Petition for Reconsideration.pdf

3E'ffi*.
An IDACORP Company
DONOVAN E. WALKER
Lead Counsel
dwalker@idah opower. com
April 29, 2014
VIA HAND DELIVERY
Jean D. Jewell, Secretary
ldaho Public Utilities Commission
47 2 W est Washi ngton Street
Boise, ldaho 83702
Re: Case No. IPC-E-13-21
Capacity Deficiency Period Utilized in SAR Methodology - ldaho Power
Company's Petition for Reconsideration and Testimony
Dear Ms. Jewell:
Enclosed forfiling in the above matterare an originaland seven (7) copies of ldaho
Power Company's Petition for Reconsideration of Commission Order No. 33016.
Also enclosed for filing are an origina! and eight (8) copies of the Direct Testimony of
Tami White. One copy of the aforementioned testimony has been designated as the
"Reporte/s Copy." ln addition, a disk containing a Word version of Ms. White's testimony
is enclosed for the Reporter.
Veryaruly yours,&-(/(/ry
Donovan E. Walker
DEW:csb
Enclosures
1221 W. ldaho St. (83702)
PO. Box 70
Boise, lD 83707
DONOVAN E. WALKER (lSB No. 5921)
ldaho Power Company
1221West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
[e-mail]
Attorney for ldaho Power Company
IN THE MATTER OF IDAHO POWER )
COMPANY'S APPLICATION FOR )
APPROVAL OF rTS CAPACTTY )
DEFTC|ENCY PERTOD TO BE UTTLTZED rN )
THE COMPANY'S SAR METHODOLOGY. )
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-E-13-21
IDAHO POWER COMPANY'S
PETITION FOR
RECONS!DERAT!ON OF
COMMISSION ORDER NO. 33016
ldaho Power Company ("ldaho Powe/' or "Compof,y"), pursuant to ldaho Code
S 61-626, RP 33, and RP 331, ef seg., hereby respectfully petitions the ldaho Public
Utilities Commission ("Commission") for reconsideration of the Commission's Order No.
33016 issued on April 8, 2014, in the above-entitled case. The Commission's Order
directing the Company to utilize July 2013 as its first capacity deficit in the Company's
surrogate avoided resource ("SAR") methodology is arbitrary, capricious, unreasonable,
unlaMul, erroneous, and not in conformity with the facts and/or applicable law, resulting
in establishment of avoided cost projections, locked in for up to 20 years, that exceed
the Company's avoided costs and are harmful to ldaho Power's customers. This
Petition is based upon the following:
IDAHO POWER COMPANY'S PETITION FOR
RECONSIDERATION OF COMMISSION ORDER NO.33016 - 1
t.
LEGAL STANDARD
A party must seek reconsideration prior to initiating an appeal to the ldaho
Supreme Court. ldaho Code S 61-627. An issue not presented to the Commission on
reconsideration will not be considered on appeal. Key Transp. lnc. v. Trans Magic
Airlines Corp.,96 ldaho 110, 524 P.2d 1338 (1 974). "The purpose of an application for
rehearing is to afford an opportunity to the parties to bring to the attention of the
Commission in an orderly manner any question theretofore determined in the matter
and thereby afford the Commission an opportunity to rectify any mistake made by it
before presenting the same to this Court." Washington Water Power Co., v. Kootenai
Environmental Alliance, 99 Idaho 875, 879, 591 P.2d 122, 126 (1979)(citing ldaho
Underground Water Users Assh v. ldaho Power Co., 89 ldaho 147,404 P.2d 859
(1965); Consumers Co. v. Public Utilities Comm'n,40 ldaho 772,236 P.732 (1925)).
The Commission may grant reconsideration by conducting an evidentiary
hearing; by reviewing the existing record; or by the submission of briefs, memoranda,
written interrogatories, or written statements. RP 332; Order No. 32974, p. 11, Case
No. IPC-E-11-15.
il.
PROCEDURAL HISTORY AND BACKGROUND
ln December 2012, the Commission directed that this case be initiated outside of
the lntegrated Resource Plan ("lRP") filing for the establishment of the capacity
deficiency period to be utilized in the SAR avoided cost rate methodology:
[W]e find it reasonable and fair to subject each utility's
determination of capacity deficiency to further scrutiny.
IDAHO POWER COMPANY'S PETITION FOR
RECONSIDERATION OF COMMISSION ORDER NO. 33016 - 2
Therefore, when a utility submits its lntegrated Resource
Plan to the Commission, a case shall be initiated to
determine the capacity deficiency to be utilized in the SAR
Methodology. The capacity deficiency determined through
the IRP planning process will be the starting point, and will
be presumed to be correct subject to the outcome of the
proceeding.
Order No. 32697, p. 23. The Commission also directed in that Order that inputs into
avoided cost rate calculations from the Company's IRP will remain fixed between IRP
cycles, with the exception of the load forecast and the natural gas forecast-which is to
be updated annually by October 15 of each year. Order No. 32697, p. 22; Order No.
32802. The Commission also directed that Public Utility Regulatory Policies Act of 1978
("PURPA") contracts that have terminated or expired, as well as any new long-term
contracts that have been signed, be included in the utility's load and resource balance.
Order No. 32697, p.22.
ldaho Power filed its 2013 IRP on June 28, 2013, which was accepted by the
Commission on February 24, 2014. Order No. 32980. On October 15, 2013, the
Company filed its updates to the IRP's avoided cost rate inputs, including an updated
load forecast, updated natural gas forecast, and an updated list of new and terminated
PURPA contracts and long-term power purchase agreements. Commission Case No.
IPC-E-13-18. The Commission subsequently approved these updates in Order No.
32941 on December 5, 2013.
On October 2, 2013, ldaho Power filed a settlement agreement regarding the
continuation of its three demand response ("demand response" or "DR") programs with
the Commission seeking its approval ("DR Settlement Agreement"). Case No. IPC-E-
13-14. The Commission subsequently issued Order No. 32923 approving the DR
IDAHO POWER COMPANY'S PETITION FOR
RECONSIDERATION OF COMMISSION ORDER NO. 33016 - 3
Settlement Agreement on November 12, 2013, requiring ldaho Power to accept all
existing, and some new, demand response participants up to 2012 levels (which was
438 megawatts ('MW")).
ldaho Power filed its Application in this case on November 4,2013, seeking an
update to the capacity deficiencies identified in the 2013 IRP for purposes of avoided
cost rate determinations with a first deficit occurring in July 2021. On February 28,
2014, Staff filed Comments recommending inclusion of DR up to 170 MW with a first
deficit year of 2016. The ldaho lrrigation Pumpers Association, lnc., filed comments
supporting ldaho Power's requested inclusion of up lo 440 MW of DR with a first deficit
occurring in July of 2021. ldaho Power filed Reply Comments addressing Staff's
criticisms and assumptions and reiterating its request for establishment of a first
capacity deficit occurring in July 2021 for purposes of avoided cost rate determinations.
On April 8,2014, the Commission issued Order No. 33016 determining to include
0 MW of DR and establishing July 2013 as the Company's first capacity deficit to be
used in the SAR avoided cost methodology stating:
[W]e decline to arbitrarily choose a number to attach to
demand response for purposes of calculations within the
SAR methodology absent evidence of the restructured
programs' success. lt is simply too early in the
implementation process to be able to reasonably predict
participation. Therefore, at this time, we cannot find a
reasonable basis upon which to approve inclusion of any
demand response in a determination of when ldaho Power
becomes capacity deficient.
Order No.33016, p. 5.
IDAHO POWER COMPANY'S PETITION FOR
RECONSIDEMTION OF COMMISSION ORDER NO. 33016 - 4
ldaho Power now files this Petition for Reconsideration, along with the Direct
Testimony of Tami White, proffering the additional evidence that, to date, 403 MW of
DR has signed up to participate for the 2014 season.
III.
THE COMMISSION'S INCLUSION OF ZERO DEMAND RESPONSE IN THE
COMPANY'S CAPACITY DEFICIENCY DETERMINATION IS UNREASONABLE,
UNLAWFUL, ERRONEOUS, ARBITRARY, CAPRICIOUS, AND NOT IN
CONFORMITY WITH THE FACTS AND/OR APPLICABLE LAW WHERE THE
COMPANY IS REQUIRED TO ACCEPT UP TO 438 MW FROM EXISTING
PROGRAMS AND 403 MW HAVE ENROLLED FOR THE 2014 SEASON
The Commission's determination to not include any demand response in a
determination of when ldaho Power becomes capacity deficient is not supported by the
facts of the case. The Commission's determination is not consistent with the
requirements of the DR Settlement Agreement, is not consistent with the preferred and
alternative resource portfolios and analysis in the 2013 lRP, and is not consistent with
the actual participation levels that are now established lor 2014. lt is unreasonable to
include zero demand response for a determination of ldaho Power's capacity deficiency
based upon the record before the Commission, and the additional evidence proffered on
reconsideration.
A. The DR Settlement Agreement
The record establishes that the DR Settlement Agreement requires the Company
to take all demand response up to approximately 440 MW (up to 2012 levels of 438
MW) and to allow any additional A/C Cool Credit participants that wish to participate to
do so. Within each program description in the DR Settlement Agreement, the parties
described how existing, and in some cases new, participants would be included in the
programs going fonruard. The parties to the DR Settlement Agreement agreed early on
IDAHO POWER COMPANY'S PETITION FOR
RECONSIDERATION OF COMMISSION ORDER NO. 33016.5
that participation should not be unnecessarily limited and that the Company would
utilize its "participating demand response customers." DR Settlement Agreement, p. 3.
For the A/C Cool Credit program, the parties agreed that existing participants will be
allowed to remain in the program, new participants will be allowed to join, and, in certain
limited circumstances, the Company will contact customers to inquire about
participation. DR Settlement Agreement, p. 5. For the lrrigation Peak Rewards
program, participants are limited to past program participants with an active, working
load control device. DR Settlement Agreement, p. 6. For the FlexPeak Management
program, Idaho Power will not actively seek to expand the capacity. DR Settlement
Agreement, p. 7. ln no case does the DR Settlement Agreement allow ldaho Power to
turn away existing program participants. ln no event does the DR Settlement
Agreement intend or imply any limitation of DR capacity beyond that of existing
participants at 2012 levels up to 440 MW.
Because participation is not limited and because the Company must use existing
DR resources when possible, the Company is required to accept up to 2012
participation levels, which is approximately 440 MW of DR. However, the Commission
stated:
The terms and conditions of participation in these programs
is now different and will result in differing levels of
participation than what ldaho Power enjoyed prior to
suspension. No one can determine participation level with
any degree of certainty. As we stated in the settlement
proceedings, we continue to believe that "it is important for
the Company to continue its DR programs to ensure it has
sufficient, reliable DR resources to meet expected deficits."
Order No. 32923 at 7. However, we decline to arbitrarily
choose a number to attach to demand response for
purposes of calculations within the SAR methodology absent
evidence of the restructured programs' success. !t is simply
IDAHO POWER COMPANY'S PETITION FOR
RECONSIDERATION OF COMMISSION ORDER NO. 33016 - 6
too early in the implementation process to be able to
reasonably predict participation. Therefore, at this time, we
cannot find a reasonable basis upon which to approve
inclusion of any demand response in a determination of
when ldaho Power becomes capacity deficient.
Order No. 33016, p. 5.
Commission Staff ("Staff') alleged that attrition would substantially reduce the
program sizes and capacity that the Company may receive. However, under the terms
of the DR Settlement Agreement, ldaho Power must accept up to 440 MW of DR
capacity if program participants choose to participate or any new A/C Cool Credit
participants wish to sign up at the programs' current incentive amounts. Based solely
upon the existing record, even if one assumes some level of attrition to the participation
in the DR programs from past levels, the capacity deficits in early years are small
enough that they would be covered even with greatly decreased participation. The
peak-hour surplus/deficit determination from the 2013 lRP, updated with the required
load and gas forecasts, new and terminated PURPA contracts, and long-term power
purchase agreements identifies the following deficiencies: 87 MW in 2013, 30 MW in
2014,94 MW in2015,275 MW in 2017,320 MW in2018,365 MW in 2019,414 MW in
2020, and 476 MW in 2021. ldaho PowerApplication, p. 3. As the Company stated in
its Reply Comments, even assuming some attrition to participation in the programs, it is
reasonable to assume that near-term deficits will be met even with greatly reduced
participation. Idaho Power Reply Comments, pp. 8-9.
The Commission need not speculate as to participation in demand response.
Actual 2014 DR subscription has demonstrated the unreasonableness of assuming no
demand response will be available. ldaho Power has received over 400 MW of DR
IDAHO POWER COMPANY'S PETTTION FOR
RECONSIDERATION OF COMMISSION ORDER NO. 33016 - 7
subscriptions for the 2014 season. White Direct, p. 7. As of April 24, 2014, ldaho
Power has DR program participants enrolled to provide a maximum load reduction at
generation level of approximately 403 MW. ld. This includes 34 MW from A/C Cool
Credit, 40 MW from FlexPeak Management, and 329 MW from lrrigation Peak Rewards.
/d. The enrollment period for the lrrigation Peak Rewards program began in March and
the participants were asked to respond by April 4,2014. ld. ldaho Power has received
the majority of the enrollments from eligible irrigation participants and the Company
does not expect the enrollments to change significantly from the 329 MW. ld. The
current enrolled capacity of 403 MW is a result of current incentives; however, as
Company load continues to grow and additional demand response is needed, the
Company anticipates incentive payments may need to be adjusted to attain 440 MW or
higher. ldaho Power Reply Comments, p. 9.
The enrollment in the A/C Cool Credit program could increase based on the
complete replacement of the radio-controlled cycling switches, the number of customers
that move into a house with an existing load control switch that enroll, the number of
former participants that moved and wish to re-enroll, and the number of customers that
contact ldaho Power wishing to enroll in the program. ld., pp.7-8. The load reduction
from the FlexPeak Management program (which is contingent upon Commission
approval of the extension of the contract with EnerNOC, lnc., Case No. IPC-E-14-02) is
expected to be 40 MW at generation leve!, as provided in the contract with EnerNOC,
lnc. /d., p. 8. Based on past performance and the current proposed contract extension,
Case No. IPC-E-14-O2, with EnerNOC, lnc., ldaho Power expects the performance to
be fairly stable throughout the program season. ld. EnerNOC, lnc., has a good
IDAHO POWER COMPANY'S PETITION FOR
RECONSIDERATION OF COMMISSION ORDER NO. 33016 - 8
performance record for the past five years and has a financial incentive to continue
providing the 40 MW of load reduction agreed upon. /d.
Consequently, not only is ldaho Power required to accept up to 440 MW of DR
by the DR Settlement Agreement, but over 400 MW has all ready subscribed for the
2014 season. !t is unreasonable, unlawful, erroneous, arbitrary, capricious, and not in
conformity with the fact and/or applicable law to assume 0 MW of DR capacity for
avoided cost pricing purposes.
B. The 2013 IRP
The Commission's determination is not consistent with the preferred and
alternative resource portfolios and analysis in the 2013 lRP. The Commission stated,
"ldaho Power made a business decision to suspend its demand response programs. As
a consequence, demand response was not included as an existing resource in the
Company's 2013 lRP.' Order No. 33016, p. 5. Demand response was analyzed and
included as a committed resource in all nine resource portfolios contained in the 2013
lRP, and was used "throughout the planning period to meet resource needs." 2013 lRP
pp.8,37-38, 40-41, and 90-92.
Demand response was specifically not included in the load and resource balance
as an existing resource because of the flexibility the programs provide in being able to
be ramped up and down as needed, but DR was definitely included in the analysis of
the 2013 IRP. While the DR programs were not treated as an "existing" resource under
the typical IRP definition, they were certainly treated as a "committed" resource, as
evidenced by the fact that all nine resource portfolios analyzed in the IRP contain
IDAHO POWER COMPANY'S PETITION FOR
RECONSIDERATION OF COMMISSION ORDER NO. 33016 - 9
varying amounts of DR depending on other resources in each portfolio in each year of
the 2O-year planning horizon.
The "business decision" to suspend two of the three DR programs in 2013 was
the subject of Case No. IPC-E-12-29 filed by ldaho Power seeking authority to do so,
based upon the avoidable cost to customers for unneeded DR programs when
adequate system capacity would exist to serve anticipated peak loads. White Direct,
p. 4. Ultimately, it was the filing in Case No. IPC-E-12-29, and subsequently in Case
No. IPC-E-13-14, that resulted in the DR Settlement Agreement that provided for the
continuation of the DR programs and requirement for ldaho Power to accept up to 440
MW of DR participation in 2014 and beyond. The suspension of the two programs in
2013 came at an expense to customers of less than $10,000, and saved customers
more than $10 million. Tatum Direct, pp. 17-18, Case No. IPC-E-14-05. However, the
fact that the programs were suspended in 2013 does not mean that they were not
considered as committed resources in the 2013|RP.
The Company's 2013 IRP identifies DR resources up to 400 MW to meet all
identified capacity deficits up to July 2021. As stated above, the DR Settlement
Agreement requires the Company to accept all DR up to 2012 levels. Historical DR
peak reduction capacity levels reported in the 2013lRP are 336 MW for 2010, 403 MW
for 2011, and 438 MW tor 2012. 2013 lRP, p. 40. The preferred resource portfolio from
the 2013 lRP relies primarily upon the Boardman to Hemingway ("82H") transmission
line with associated market purchases as the major resource acquisition to cost-
effectively meet the Company's service obligations. 2013 lRP, p. 8. The preferred
resource portfolio assumes an expected operational date of B2H as 2018. ld.
IDAHO POWER COMPANY'S PETITION FOR
RECONSIDERATION OF COMMISSION ORDER NO. 33016 - 1O
Because of delays in the ongoing required state and federal permitting processes
for the B2H line, the Company recently announced that the operational date for B2H will
be no sooner than 2020. Attachment 1 to ldaho Powe/s Reply Comments filed in this
case contains the updated load and resource balance that was the basis for Table 3 in
ldaho Power's Application in this proceeding and shows the inclusion of 440 MW of DR,
which eliminates summer deficits through July 2020. The amount of DR begins at 30
MW in the summer of 2014 and gradually increases to 440 MW in the summer of 2021,
which is the first summer the DR programs are not able to eliminate the entire deficit;
i.e., the first deficit year. Just as the preferred resource portfolio relied upon
contributions from DR to meet peak capacity deficiencies prior to B2H becoming
operational, the first resource portfolio that considers resource options without the
addition of B2H meets all near-term, peak-hour capacity deficiencies with DR, up to 400
MW. 2013 lRP, p. 91, Resource Portfolio 3. Resource Portfolio 3 considers the
Company's resource portfolio without the addition of the B2H Iine, and includes DR up
to 400 MW. This resource portfolio meets all identified capacity deficits to July 2021. lf
DR were limited to the 170 MW suggested by Staff, resulting in a first deficit year of
2016, or if the Company's first deficit was in July of 2013, as directed by the
Commission in Order No. 33016, the Company would have to presently be developing
the next combined- or simple-cycle combustion turbine in order to have it operational to
meet the purported capacity deficits. However, the Company's lRP considered the
alternative that B2H would not be on-line when anticipated and, in those alternatives,
the Company's IRP calls for meeting those deficiencies with DR. From the perspective
of ldaho Powe/s lRP planning process, ldaho Power's customers have borne the costs
IDAHO POWER COMPANY'S PETITION FOR
RECONSIDERATION OF COMMISSION ORDER NO. 33016 - 11
associated with developing the Company's DR programs and to ignore the past proven
capabilities of these programs would be incorrect.
Based upon the additional evidence that over 400 MW of DR has subscribed for
the 2014 season, the IRP's reliance upon meeting various capacity deficits through
2020 with up to 400 MW of DR continues to be reasonable and well founded.
C. Avoided Cost Rates
The purpose of this docket is to establish, outside of the lRP, the capacity
deficiency utilized for avoided cost PURPA pricing. As recognized by the Commission
when addressing separate capacity and energy payments to qualifying facilities ("QF")
in the final Order for Case No. IPC-E-11-03:
The legal standard for an appropriate determination of
avoided cost rates is clearly defined by PURPA. Rates for
purchases from a QF shall "(i) be just and reasonable to the
electric consumer of the electric utility and in the public
interest; and (ii) not discriminate against qualifying
cogeneration and small power production facilities." 18
C.F.R. S 292.304(aX1). "Nothing in this subpart requires any
electric utility to pay more than the avoided costs for
purchases." ld. at $ 292.304(a)(2). Avoided costs are those
costs which a public utility would otherwise incur for electric
power, whether that power was purchased from another
source or generated by the utility itself. 18 C.F.R. S
292.101(bXO). PURPA allows QFs to obtain a rate
equivalent to the utility's avoided cost, a rate that holds the
utility customers harmless . . . .
Order No. 32697, p. 16.
With the purpose of this docket to establish the capacity deficiency utilized for
avoided cost PURPA pricing in mind, any PURPA contracts entered into will lock this
capacity deficiency into the avoided cost rates for the next 20 years, and cannot
subsequently be changed. The effect of arbitrarily ignoring DR potential is to increase
IDAHO POWER COMPANY'S PETITION FOR
RECONSIDEMTION OF COMMISSION ORDER NO.33016 - 12
the avoided cost of capacity payments made in any PURPA contracts, and to lock that
higher payment in for the next 20 years with no ability to change it, resulting in
customers paying more than they should for these contracts<r, in other words,
inflating the avoided cost price and harming customers by requiring Idaho Power to pay
more than its avoided cost. Customers are harmed in that they must pay for capacity
provided by the DR programs, and then pay again for a capacity contribution in the
PURPA contracts, when those capacity deficits will have all ready been met by the DR
programs. Even if the next IRP analysis, or the continued operation of the DR
programs, shows that all capacity deficits are met through 2021 or beyond, the PURPA
contracts entered into in the interim period will have locked in capacity payments for 20
years based upon the assumption of 0 MW of DR and a resulting capacity deficit that
occurs at least eight years sooner than the reasonable analysis and requirements of the
DR Settlement Agreement, the 2013 lRP, and the actual participation for 2014 would
indicate.
tv.
CONCLUSION
ldaho Power respectfully requests that the Commission issue an order on
reconsideration approving the capacity deficiency period shown in Table 3 of ldaho
Power's Application, with a first deficit occurring in July 2021.
As discussed above, the Commission's assumption of DR capacity to 0 MW is
not supported by the Commission-approved DR Settlement Agreement, the
Commission-accepted 2013 IRP, the actual 2014 DR subscriptions, or any other
analysis. ldaho Powe/s inclusion of up to 440 MW of DR is consistent with the DR
IDAHO POWER COMPANY'S PETITION FOR
RECONSIDERATION OF COMMISSION ORDER NO. 33016 - 13
Settlement Agreement's requirement that ldaho Power accept all existing, and some
new, demand response participants up to 2Ol2levels (which was 438 MW). lt is also
consistent with the preferred and alternative resource portfolios in the 2013 !RP, which
utilizes DR to meet all identified capacity deficiencies until the B2H transmission line is
completed. lt is also validated by the additional evidence that over 400 MW of DR has
signed up to participate for the current 2014 season, with the potential for additional
participation.
ldaho Power respectfully requests that the Commission issue an order on
reconsideration approving the capacity deficiency period shown in Table 3 of ldaho
Power's Application, with a first deficit occurring in July 2021.
Respectfully submitted this 29h day of Apri! 2014.
IDAHO POWER COMPANY'S PETITION FOR
RECONSIDEMTION OF COMMISSION ORDER NO.33016 - 14
DONOVAN E. WALKER
Attorney for ldaho Power Company
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 29fr day of April 2014 I served a true and conect
copy of IDAHO POWER COMPANY'S PETITION FOR RECONSIDERATION OF
COMMISSION ORDER NO. 33016 upon the following named parties by the method
indicated below, and addressed to the following:
Commission Staff
Kristine A. Sasser
Deputy Attomey General
ldaho Public Utilities Commission
472 West Washington (83702)
P.O. Box 83720
Boise, ldaho 83720-007 4
J. R. Simplot Company
Peter J. Richardson
Gregory M. Adams
RICHARDSON ADAMS, PLLC
515 North 27th Street
Boise, ldaho 83702
Dr. Don Reading
6070 Hill Road
Boise, ldaho 83703
ldaho lrrigation Pumpers Association
Eric L. Olsen
RACINE, OLSON, NYE, BUDGE, &
BA!LEY, CHARTERED
201 East Center
P.O. Box 1391
Pocatello, ldaho 83204-1391
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q reo @ richardsonadams. com
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IDAHO POWER COMPANY'S PETITION FOR
RECONSIDERATION OF COMMISSION ORDER NO. 33016 - 15
rista Bearry, Legal Assistant