20160623Larkin DI.pdf

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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OE IDAHO POWER
COMPANY' S APPLICATION FOR
APPROVAL OE NEW TARIEE SCHEDULE
63, A COMMUNTTY SOIAR PrLOT )
PROGRAM.)
)
CASE NO. IPC-E-16-14
rDAHO POWER COMPANY
DTRECT TESTIMONY
OF
MATTHEV'I T. LARKIN
1 Q. Pl-ease state your name, business address, and
2 present position with Idaho Power Company ("fdaho Power" or
3 "Company").
4 A. My name is Matthew T. Larkin. My business
5 address is l22l West Idaho Street, Boise, Idaho 83702. I
6 am employed by Idaho Power as the Revenue Requirement
7 Manager in the Regulatory Affairs Department.
I Q. Please descri-be your educational- background.
9 A. I received a Bachelor of Business
10 Administration degree in Finance from the University of
11 Oregon j-n 2007. In 2008, I earned a Master of Business
72 Administration degree from the Unj-versity of Oregon. I
13 have also attended electrj-c utility ratemaking courses,
74 including the ELectric Rates Advanced Course, offered by
15 the Edison Electric Institute, and Estimation of
16 ELectricity MarginaL Costs and AppTication to Pricing,
71 presented by National Economic Research Associates, Inc.
18 0. Please describe your work experience with
19 Idaho Power.
20 A. I began my employment with Idaho Power as a
2L Regulatory Analyst I in January 2009. As a Regulatory
22 Analyst T, I provided support for the Company's regulatory
23 activities, including compliance reporting, financial
24 analysls, and the development of revenue forecasts for
25 regulatory filings.
LARKIN, DI ]-
Idaho Power Company
In January 20L2, T was promoted to Regulatory
2 Analyst II, and, in January 2014, I was promoted to Senior
3 Regulatory Analyst. As a Senior Regulatory Analyst, my
4 responsibilities expanded to include the development of
5 complex cost-related studies and the analysis of strateglc
6 regulatory j-ssues.
In March of 2076, I was promoted to my current
I position of Revenue Requirement Manager. As Revenue
9 Requirement Manager, I oversee the Company's reguJ-atory
10 activj-ties related to revenue requirement, such as power
11 supply expense modeling, jurisdictional separation studies,
72 and Idaho Power's Open Access Transmission Tariff Eormula
13 Rate.
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O What is the Company requesting in this case?
A. The Company is requesting that the Idaho
76 Public Utilities Commission ("Commissj-on") authorize the
Ll implementation of a voluntary Community Solar Pilot Program
18 ("Program").
t9 O. Please provide a summary of the proposed pilot
20 Program offering.
21 A. The Company is proposing to buil-d a 500
22 kilowatt (\\kW") single-axis tracking community solar array
23 that wil-1 exist to allow a limited number of Idaho Power's
24 Idaho customers the opportunity to voluntarily subscribe to
25 the generation output of the array. Participating
LARKIN, DI 2
Idaho Power Company
1 customers will be required to pay a one-time upfront
2 Subscription Eee ("Subscription Fee") and in return will
3 receive a monthly bill credit ("Solar Energy Credit") for
4 their designated share of the energy produced from the
5 array. The testimonies of David M. Angell and Peter
6 Pengilly will describe in greater detail- the community
7 solar array and the proposed Program design, respectively.
I Q. How is the Company's case organized?
9 A. My direct testimony wilt provide the
10 Commission with an understanding of the Company's
11 objectives for offerlng this pilot Program and the unique
72 regulatory considerations that guided its design. My
13 testimony will also summarize the total costs of the
L4 proposed Program, the determination of the Solar Energy
15 Credit, the proposed regulatory accounting treatment, and
16 an explanation of why the Program is in the public
L7 interest.
18 Mr. AngeJ-1 will provide testimony that wil-I describe
79 the Request for Bid ("REB") process for the selection of
20 the contractor and the resulting cost to build the array.
2L In addition, he will detail the operational aspects of
22 offering the Program.
23 Mr. Pengilly will- present testimony that will-
24 discuss the customer input that l-ed the Company to offer
25 this Program, as wel-l as the Program design. His testimony
LARKIN, DI 3
Idaho Power Company
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wiII further discuss the ongoing costs associated with
offering the Program.
O. Are you sponsoring any exhibits?
A. Yes. f am sponsoring the followlng exhibits:
Exhibit No. 1 - the proposed Solar Energy Credit by
rate schedule; and
Exhibit No. 2 Subscription Eee calculation.
I. COMMT'NITY SOI.AR PTLOT PROGRAM DESIG:N
OBi'ECTI\IES A}ID CONSIDERATIONS
O. What l-ed the Company to consi-der a Community
Sol-ar Pilot Program?
A. The Company is offering the Program based on
expressed interest from some customers who desire to have a
portion or all of their energy supplied from renewable
resources, specificalJ-y solar. Mr. Pengilly describes in
detail the interaction with customers and stakeholders that
led to the Company's proposal j-n this case.
O. What role does the proposed Community Solar
Pilot Program fill wit.h regard to customer preference for
sol-ar energy?
A.Eor many customers, dj-rect ownership and
operatj-on of sofar resources is not desirable or feasible.
Customer ownership and operation requires upfront capital-
costsr ds wel-I as long-term expenses and liabil-ities
associ-ated with system operation and maintenance. Beyond
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Idaho Power Company
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cost considerations, rooftop or ground-mounted solar
instal-Iations are feasible only for certain property
owners. Customers who reside in rental properties, multi-
unit dwellings, or townhomes are necessarily l-imited in
their optj-ons, dS well as customers that have aging
rooftops, shadi-ng, or unsuitabl-e rooftop orientation.
The Company's proposed Community Solar Pil-ot Program
is designed as an alternative to customers who fa1l into
the various categories mentioned above. Additionally, with
regard to cost, a 2075 study commissioned by First Sol-ar
and authored by The Brattle Group found that utility-scale
photovoltaic ("PV") systems are significantly more cost-
effective than residential-scale PV systems when considered
as a vehicle for achieving the economic and policy benefits
commonly associated with PV sol-ar.1
o.Does the Company currently have a load-serving
need for the proposed solar resource?
A.No. As indicated by the Company's 20L5
Integrated Resource Plan ("IRP"), the Company is resource
suf f icient until 2024.2 As dj-scussed above, the Company's
proposal in this case was driven by customer preference
rather than load-servj-ng need.
1 Comparative Generation Costs of Utility-Scale and Residential-
Scafe PV in Xcel Energy Colorado's Service Area, July 2015.
2 ldaho Power's 2015 IRP, page 119.
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Idaho Power Company
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0.Because there is no current need for the
proposed sol-ar resource from a l-oad-serving perspective,
how did the Company approach pricing and design for the
IT. COMMUNITY SOI.AR PILOT PROGRAM COSTS
O. What is lncluded in the Subscription Eee of
4 proposed Program?
A.The pricing methodology for the Subscription
6 Fee and the overall Program design is intended to result in
7 Program participants covering the full cost of the project
8 (Iess the shareholder subsidy detailed below) with nominal-
9 impact to non-participating customers assuming full-
10 subscriptlon. Because there is no existing load-serving
11 need to construct the solar array, the pricing and design
1,2 of the Program should ensure that the incremental costs of
13 the Program are borne by customers who choose to
74 participate j-n this optional pilot, while limiting the
15 potential for non-participating customers to be assigned
L6 Program-related costs.
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19 the proposed Program?
20 A.The Company is proposing a cost-based method
27 of pricing whereby the Company has set the Subscription Eee
22 for participants to reflect the cost to construct and
23 interconnect the sol-ar PV facility, less an TDACORP, lnc.,
24 sharehol-der contribution of 15 percent, dS well as ongoing
25 costs such as operatlons and maintenance expense (*O&M")
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and property tax. Estimated incremental costs associated
with marketing the Program have been incorporated into the
Subscription Eee as wel-l.
o.
the Program?
A.No. The proposed l-ocatlon at the Boise Bench
substation, described in more detail by Mr. Angel1, is l-and
that is currentl-y in the Company' s plant- j-n-service. The
Company bel-ieves that the construction of the array will
not affect the utllity use of the parcel.
0. How did the Company determine the costs to be
reflected in the Subscription Eee?
A.As described in the testimony of Mr. Angell,
the Company submitted a RFB to establish firm costs to
construct the proposed community solar array. The cost to
construct provided by the selected contractor is
$1,158,763. Mr. Ange1l's testimony also details additional
interconnection costs to connect the solar facility to
Idaho Power's grid of $81,000.
In his testimony, Mr. Pengilly describes the ongoing
expenses reflected in the total- project cost, including
incremental expected OeM for the life of the project,
property taxes, and $50,000 for incremental Program
marketing expenses.
LARKIN, DI 7
Idaho Power Company
Are land costs incl-uded in the total cost of
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o.Does the Company project to receive federal
Investment Tax Credj-ts (*ITC") for the Program?
A.Yes. Under current Iaw, the 30 percent ITC
for eligible facilities wil-l- be avail-able through 2079.
The ITC will be subject to normal-ization, ds required for
public utilities by the Internal Revenue Code.
o.Did the Company pass on the ITC benefits to
customers in this Program?
A. Yes. The calculation of the upfront
Subscription Fee recognizes the ITC benefits in the same
manner as the Company records them for income tax
accounting purposes.
a.
A.
Will the Company
No. AIl project
earn a return on the project?
costs are borne by the
and the Company wil-l notvol-untary participants upfront,
earn a return on this project.
O. Why is the Company proposing to j-nclude a
shareholder-funded subsldy of 15 percent of the solar
facility construction costs?
A.The Company is buiJ-ding a solar facility that
is smaller in sj-ze than what is consldered the industry
standard for "utility scal-e" solar. As detailed j-n Mr.
Pengilly's testi-mony, one of the learning objectives of the
Community Solar Pilot Program is to gauge customer
commj-tment toward participating in a communj-ty solar
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option, potentially to inform a larger scale offering in
the future. Because larger projects achieve economies of
scale in relation to the 500 kW system proposed in this
Program, the Company has committed to a contribution of 15
percent of the sol-ar facility costs to help facj-Iitate this
learning objective.
o.How did the Company determine that a 15
percent shareholder funding was appropriate?
A.The Company arrived at a 15 percent
contribution through the REB process. In the RFB process,
the Company requested that the bidders provide an alternate
bid f or the full buil-d-out of the sel-ected site. The
difference in price per kW between the proposed project
(500 kW) and the fuII build-out (approximately 1 megawatt
(*MW") ) was approximately 15 percent. The Company believes
that the 15 percent difference in price represents the
economies of scal-e that a larger project would experience
as compared to the pllot Program.
0. Please quantify the shareholder funding
contribution.
A.As discussed above, the shareholder
contribution is cal-culated as 15 percent of the cost to
construct the solar facility. Based on the cost provided
by the successful contractor of $1,158,769,15 percent is
approximately $173, 815.
LARKIN, DI 9
Idaho Power Company
O. What is the resulting Subscription Fee after
2 taking into account the costs described above?
A. Based on the costs described above, less the
4 shareholder contributj-on of 15 percent, the proposed
5 Subscription Fee is $740, the equivalent of a 320 watt
6 (*W") panel, ds shown in Exhibit No. 2. The Subscription
7 Eee is a one-time upfront payment that wil-l- result in a
8 Solar Energy Credit on the customer's monthly bill for the
9 25-year life of the Program.
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O. How many subscriptions will be avail-abl-e?
A. There will be approximately 1,563
12 subscriptions available. The Company determined that the
13 total- number of subscriptions available shoul-d be the
74 equivalent of the number of panels equal to the project's
15 expected capacity of 500 kW. As Mr. Ange11 details in his
76 testimony, the selected contractor will install 320 W
77 panels. Based on this information, the number of
18 subscriptions is cal-cul-ated as foll-ows: (a) 500kW x 1,000 :
L9 500,000W, (b) 500,000W + 320W : 1,563.
20 O. Did the Company consider other payment options
2L for the Program aside from the upfront Subscription Fee?
22 A. Yes. The Company also considered a monthly
23 payment option, but determined the upfront Subscription Fee
24 was the least risk in terms of potential- unrecovered costs
25 for both the Company and non-participating customers.
LARKTN, Dr 10
Idaho Power Company
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O.Why is the Company proposing the upfront
Subscription Eee rather than the monthly option?
A. In light of the fact that the pilot Program is
designed solely for the subscrlbers of the Program and in
recognition that the Company's need for additional
generation does not occur until 2024, the Company felt that
the financial risk for non-participants and the Company
would be too great under the monthly payment option if
panels went unsubscribed throughout the l-ife of the
Program. Under the monthJ-y payment option, if customers
were to drop out of the Program prematurely, the remaining
unpaid portion of the subscription would be borne by the
Company and/or non-participating customers. This risk does
not exist under the upfront Subscriptj-on Fee option.
O. Is the Company investigating a third-party
financing option that would effectively provide
participants with a monthly payment option?
A.Yes. The Company has reached out to several
lending institutions to see if there is interest j-n
offering a special rate for financing of a community solar
subscrlption. This option is stil-I currently in-process.
If there is interest by a third-party lender, the Company
will make this offering known to prospective subscrj-bers
during the recruitment period.
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Idaho Power Company
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production
A.
IIT.SOI,AR EIIERGY CREDIT ATiID BILL OFE'SETS
How will a participant's monthly energy
be calculated?
The total energy output of the array will be
The
of
their
measured on a monthly basis at a production meter connected
at the generation source. Line losses of 3.3 percent, as
described by Mr. Angel1, will be applied to the total
output to determine loss-adjusted actual production.
resulting energy will be divided by the total number
subscriptions, and participants will receive their
proportionate share of the energy conrmensurate with
level of subscriptj-on. The forecast annual energy per
subscrj-ption j-s approximately 638 kV,Ih.3
o.What is the credj-t that participants w111
recej-ve for their share of the sol-ar production?
A.The Company is proposing a per kilowatt-hour
("kVllh") Sol-ar Energy Credit for the solar production. The
Solar Energy Credit is based on the Company's embedded
energy-related costs as determj-ned by the most recently
reviewed cl-ass cost-of-service methodology filed in Case
No. IPC-E-11-08, adjusted to reflect revenue requirement
changes that were subsequently authorized by the Commission
which lmpact the authorized l-evel of energy-related cost
recovery.
3Estimated average annual- loss-adjusted energy of 996,977 kwh +
1,563 subscriptj-ons : 638 kwh/year per subscription.
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Idaho Power Company
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O. Please describe what kinds of costs are
classified as "energy-rel-ated" in the class cost-of-service
study.
A.Consi-stent with the cost-of-service
methodology in the Company's last general rate case,
energy-related costs are general-ly the varj-abl-e costs
associated with the operation of the generating pJ-ants,
such as fuel. However, due to the hydro production
capability of the Company, a portj-on of the hydro and
thermal generating plant investment has historically been
classified as energy related.
0. Why should the Sol-ar Energy Credit reflect
embedded energy-related costs?
A.Providing particlpants with a bil-I credit
based on embedded energy costs reflects the general concept
that participants are choosing to subscribe to the
community solar facility for a portion of their electricity
supply rather than recej-ving electricity generated from the
Company's overall system resources. By basing the bil-1
credit on embedded energy-related costs, the Solar Energy
Credlt allows for a transparent and repeatable methodology
that can be easily updated over time. Thi-s methodology
will ensure that participating customers are able to offset
the energy-related portion of base rates, while still
contributing to the recovery of fixed costs related to
LARKTN, Dr 13
Idaho Power Company
1 infrastructure needed to serve all customers, as well as
2 other non-variable costs, such as customer service and
3 billing. The Company believes this methodology is
4 consj-stent with the objective of limiting adverse rate
5 impacts to non-particlpating customers.
O. Will- the Sol-ar Energy Credit be fixed for the
7 life of the Program?
A. No. The Company proposes to update the Solar
9 Energy Credit as needed based on changes to its embedded
10 energy-related costs recovered through base rates.
11 O. Does the Company's proposed Solar Energy
72 Credit reflect the seasonal- production of the proposed
13 solar facility?
74 A. Yes. The Company is proposing a Sol-ar Energy
15 Credit that refl-ects the seasonal nature of solar
L6 production. The energy produced at a solar facility in
71 Idaho w1ll experi-ence peak production in the summer months
18 when energy costs are generally higher. By incorporating
79 this seasonality, the Solar Energy Credit will- be
20 reflecti-ve of the seasonal differences in the cost of
2t energy.
22 O. Is the Company proposing to reflect the
23 seasonal nature of the sol-ar production by offerj-ng
24 seasonal Sol-ar Energy Credit rates?
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Idaho Power Company
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A.No. Eor billing simplicity and ease in
customer understanding, the Company is proposing a single
Solar Energy Credit rate for each class; however, these
year-round rates were appropriately adjusted to refl-ect the
summer/non-surnmer weighting of solar production.
O. How will the community solar bill credit be
calculated?
A.The community solar bill credit will- equal- the
product of (a) the proposed Solar Energy Credit rate
specified in tariff Schedule 63 and (b) the subscriber's
share of the total monthly production for that month. The
total dol1ar value of the Solar Energy Credit reflected on
a customer's biII wiII fluctuate monthly as productj-on from
the solar facility fluctuates.
0.Witt participation in the Program affect any
other components of a customer's bill?
A.Yes. The Company is proposing that the
participant's share of the monthly output will al-so be
applied as a kwh credit toward billed kwh subject to the
annual Power Cost Adjustment ("PCA") rate. As detailed
above, participation in the Community Solar Pilot Program
is effectively replacing energy supplied from the Company's
existing resources and recognizi-nq that the energy produced
from the sol-ar facility has no varj-abIe fuel cost
component. Because the Sol-ar Energy Credit reflects the
LARKIN, DI 15
Idaho Power Company
1 embedded energy-related cost in base rates, the partj-cipant
2 should also be able to offset year-over-year variations in
3 these energy-related costs tracked through the PCA.
a. Has the Company provided an example of a
5 residential- participant's bill?
A. Yes. Company witness Mr. Pengilly provides a
7 billing exampJ-e for the average residential customer as
8 Exhibit No. 4 to his testimony.
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IV. REGT'I,ATORY ACCOT'NTING TREATL{ENT
O. Pl-ease describe the objective of the proposed
11 regulatory accounting treatment for the Program.
72 A. The key regulatory accounting objective of the
13 Program is that non-participants will not bear any
t4 incremental costs of the Program.
15 a. Please describe the Company's proposed
76 accounting for the project.
l7 A. The project will be considered utility plant
18 and will- close to el-ectric plant-in-service, Federal Energy
19 Regulatory Commj-ssion ("EERC") Account 101, in the same
20 manner as any other Company-owned asset. The shareholder
2L contribution of 15 percent of the plant-related costs wil-I
22 be written off of the plant-in-service account and the
23 Company wil-l- record a Contribution in Aid of Construction
24 (CIAC) for the remaining balance assuming a 100 percent
25 subscription rate. The combination of the two entries will
LARKIN, DI L6
Idaho Power Company
l- ef fecti-veIy zero out the plant bal-ance on the Company's
2 books. The portion of the upfront Subscription Fees
3 related to ongoing costs such as incremental O&M,
4 marketing, and property tax wj-]1 be recorded a deferred
5 revenue account. The balance of the deferred revenue
6 account will be amortized over the life of the project.
7 Q. How will the Company ensure that the Program
8 is neutral for non-participants?
9 A. The community solar plant-related costs will
10 be zero on the Company's books based on the accounting
1l- entri-es described above; therefore, any future change in
72 base rates will excJ-ude any communj-ty solar plant-related
13 costs. With regard to incremental Program expenses
L4 (marketing, ongoing O&M, property taxes), during future
15 ratemaking proceedings, a test year adjustment wil-1 be made
1,6 based on the annual amortization of the deferred revenue
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18 offset the ongoing incremental costs of the Program in the
19 Company's revenue requirement determinatj-on in future rate
20 cases.
2L However, it should be noted that because the annual
22 amortization amount w11l- be based on estimated costs,
23 actual costs may differ from that estimate. The Company
24 does not believe these differences will- result in material
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costs or benefits being assigned to non-participating
customers in the future.
O. Is the Company planning to track differences
between estimated and actual costs through the life of the
Program?
A.No. While the deferred revenue account wil-1
be amortized over the life of the Program, the Company does
not intend to track differences between estimated costs
embedded in the upfront Subscription Eee and actual costs
incurred throughout the life of the Program.
V. PI'BLIC INTEREST
0.Why does the Company believe offering the
Community Solar Pilot Program is in the public interest?
A.The Company bel-ieves the pilot Program is in
the public interest because the Program is the direct
resul-t of customers expressing their desire for additional
choices when it comes to renewable energy. By offering
access to community solar on a pilot basis, the Company is
hoping to expand the renewable energy options avai1able to
customers who are interested in supporting sol-ar energy.
In addition, participation through a Company-sponsored
renewable energy program provJ-des for better consumer
protectj-on through Idaho Power's regulated business
practices as compared to third-party install-ations or
leas j-ng of roof top sol-ar installations.
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Idaho Power Company
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A.The Program is structured to minimize the
impacts to non-participating customers while offering a
community solar project in the most cost-effective way
possible. The Company's proposal is designed such that the
costs associated with this customer option are borne by
those customers who choose to pursue the option.
a.What benefits will the Community So1ar Pilot
Program bring to the Company?
A.As discussed in the testimonies of Mr.
Pengilly and Mr. Ange11, the Company will use the Community
Sol-ar Pilot Program as a learning opportunity. The Company
wiII evaluate each aspect of the Program to determine what
areas could be improved upon and identify best practices in
the event the Company proposes additional community solar
projects in the future.
vr. coNcLusroN
0.
interest?
o.
A.
How is the Program design in the public
Please summarize your testimony.
The Company is requesting that the Commission
approve the proposed vol-untary Community Solar Pilot
Program. The proposed Program is the dj-rect result of
customers who have expressed a desire to have a portion or
al-l- of their energy supplled from renewable resources.
Because the Program is the result of customer interest and
LARKTN, Dr 19
Idaho Power Company
1 there is no l-oad-serving need to construct the proposed
2 solar facility, the Program has been designed such that the
3 costs of offering the Program are borne by the
4 participants. fn return for their participation, Program
5 participants wil-l receive a monthly bilt credit for the 25-
6 year term of the Program. The proposed Solar Energy Credit
7 rate reflects the Company's embedded energy-related costs.
8 Additionally, the Company is proposing the participant's
9 share of the monthly output a.l-so be applied as a kvflh credit
10 toward billed kwh subject to the annual PCA rate. Offering
11 the Program as a pilot will provide a learning opportunity
12 that may inform additj-onal- community solar projects in the
13 future. The Company believes that the Program, as
74 proposed, is in the public interest and shoul-d be approved.
15 O. Does this complete your testimony?
16 A. Yes, it does.
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STATE OF IDAHO
County of Ada
ATIESTATIOII OF TESTIIONI
QQ
l, Matthew T. Larkin, having been duly sworn to
testify truthfully, and based upon my personal knowledge,
state the following:
I am employed by fdaho Power Company as the Revenue
Requirement Manager J-n the Regulatory Affairs Department
and am competent to be a witness in this proceeding.
f declare under penalty of perjury of the laws of
the state of fdaho that the foregoing pre-filed testimony
and exhibits are true and correct to the best of my
information and belief .
DATED this 22"d d.ay of June , 20\6.
June,
Matthew T. Larkin
SUBSCRIBED AND SV{ORN to before me this 22"d d.ay of
20]-6
f,i{*^Y f i
LARKTN, DI 21.
fdaho Power Company
Notdry or Idaho
Residing at:
expares:My commissionfrl*".'2,u!":
BEFORE THE
IDAHO PUBLIG UTILITIES COMMISSION
cAsE NO. IPC-E-16-14
IDAHO POWER COMPANY
LARKIN, DI
TESTIMONY
EXHIBIT NO. 1
ldaho Power Company
Gommunity Solar Pilot Program
Solar Energy Gredit by Rate Schedule
Schedule
1and5
7
9S
9P and 9T
19
24
26
29
30
Description
Residential Service
Small General Service
Large GeneralService
Large General Service
Large Power Service
lrrigation Service
Micron Special Contract
Simplot Special Contract
DOE SpecialContract
Solar Enerov Credit
G oer kWtr
3.0246
3.0209
2.9936
2.7352
2.7735
2.6559
2.5167
2.5371
2.4915
Exhibit No. 1
Case No. IPC-E-16-14
M. Larkin, IPC
Page 1 of 1
BEFORE THE
IDAHO PUBLIG UTILITIES COMMISSION
GASE NO. IPC-E-16-14
IDAHO POWER GOMPANY
LARKIN, DI
TESTIMONY
EXHIBIT NO.2
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Exhibit No. 2
Case No. IPC-E-16-14
M. Larkin, IPC
Page 1 of2
Exhibit No. 2
Case No. IPC-E-16-14
M. Larkin, IPC
Page2of 2
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