19910613.docx

Minutes of Decision Meeting
June 13, 1991 - 10:00 a.m.
In attendance:
Commissioners Joe Miller, Ralph Nelson and Marsha H. Smith and staff members Mike Gilmore, Don Howell, Bev Barker, Belinda Anderson, Syd Lansing, Tom Faull, Randy Lobb, Lynn Anderson, Tonya Clark and Myrna Walters.
Items from the June 13, 1991 Agenda were discussed as follows.
1.  Tonya Clark's June 10, 1991 Decision Memorandum re:  Petition for Reconsideration--Dick F. and Carol A. Kehoe dba Centennial Delivery Service, Boise, Idaho.  Case No. M-7276-9.
Commissioner Smith said apparently they believe that somehow they changed from permitted to private.
Tonya Clark said for some reason at the county they had only paid the private fee rather than common.  Our records did not reflect that they were a common carrier.  They were notified both years that we didn't have record.  It then went to hearing before they responded.  They have paid the additional for '90 and '91.  Have paid regulatory fees.
Commissioner Smith said if people were trying to comply with the law and if the county had part responsiblity, these people have to know, they thought they were getting by with $7.  Would prefer to reinstate the permit and tell them now we know that they know and if it happens again we will cancel.
Commissioner Nelson said it was fine with him.
Commissioner Miller asked if we would reconsider or reinstate?
Commissioner Nelson said he would reinstate.
Mike Gilmore said you can have reconsideration and reinstate as a result of that.
Decision was to do that.
2.  Regulated Carrier Division Agenda dated June 13, 1991.
Approved.
**Will hold Item 8.
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15. Don Howell's June 7, 1991 Decision Memorandum re:  Interplay of the Open Meeting and Public Record Laws.
Commissioner Miller asked Don Howell what his recommendation was on this?
Don Howell said on Page 3 - basically if the memo is going to be presented to the Commissioners by consumer staff that says it qualifies as investigatory record, that you convene an executive session.  What appears to be the easiest would be to add it to the meeting agenda and Commissioners take a vote, discuss the material and the procedure would be the same for any proprietary record, discuss it and reconvene and make your actual finding in the open meeting without making the name of the individual pursuing the appeal public, etc.  Say we have revisited the record and make your decision.
Commissioner Miller said he thought some people would like to comment on this topic.
Jack Vanvalkenburgh introduced himself.  Said he understood Don Howell's proposal and it is something ACLU would back in terms of the provision that people who desire privacy when going to the Commission in an appeal of line blocking ought to be permitted that, and that resulting in an executive session is fine.  However, there are some who have been denied that would not be interested in that privacy because they are convinced their reasons for demanding line block is that it should not be contingent upon fear for personal safety, etc. and they should be allowed chance to address the Commission.  If cross examination is permitted, cross examine U. S. West as to why they have been denied, have it recorded.  Caller ID is of national attention and Idaho is pioneering, and it should stay with the Idaho Commission.  U. S. West is pushing a technology that discloses name and number.  Would think this is an issue that when there is reason for wanting line block and they are not consistent, I want privacy, there are those who have applied and been denied who simply state on the form that we do have personal safety reason and we have some arguable ways to express this and we don't get assurance that this is conjunctive.  They should be allowed executive session.  Those are also the reasons that they were in the grey area as to whether the PUC is going to uphold the U. S. West decision.  To the extent they are interested, and want public involvement in these decisions, there would be no reason they should deny them and the media opportunity to address it in public session.  Would be interested in answering questions as to whether or not applicants would have occasion to cross examine witnesses and/or be represented by counsel at decision meetings on denial of line block.
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Mr. Keyes spoke from the audience.
Would like to in general agree with staff decision and support it.  Would like the option of executive session being available to the person, it does have national exposure and there are cases where it would not be public, but should be at the option of the person asking.
Another public witness spoke.
Supported staff's recommendation and ACLU.  Was also denied by the Commission the right for line blocking and feel she should have information as to why she was denied - why that decision was made and what was involved in that decision.  Feel they should be notified that they can appeal that decision through the PUC.  Did not receive that notification from them.  Found out the hard way.  Agree that legal counsel should be available to the applicant and media should be available to the applicant as they feel their reasons for line blocking are such.  Do not fear for personal safety but feel she has valid concerns.  Other than that, feel that the media is important in this and if they could be allowed to proceed in these sessions, it could make the public more aware of Caller ID.  If decisions are made previous to their knowledge they have no recourse because the standard has been set.
Commissioner Nelson said in regard to the notice that applicant gets from U. S. West, doesn't their letter say they can appeal?
Bev Barker responded - original letter didn't say that.  Had the company do a separate letter to those first people.  People are now getting a letter informing them of that opportunity.
Commissioner Nelson asked - are you now satisfied that the letters say they can appeal?
Bev Barker replied - yes.  It was a problem originally.  
Commissioner Miller asked Don Howell about the applicant's option, there should be hearing also and hearing should be public?  Could we work out a procedure along those lines?
Don Howell responded - think it is something we can do.  We were only looking at at some point of keeping it confidential.  If they want to file a formal case, it has a public trust to it.  That is at the option of the customer if they want to do that.  Maybe we need to interpret that in our notice.
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Mike Gilmore said we have offered people informal or formal procedures in the past and you don't get two bites of the apple.  Think it is important that people realize that if they get to the staff level and they do not like it, they should have option to go informal or formal.  If you stay with the informal option, under investigator, both parties have the right to privacy.  If they want to just talk to you, both would be involved.
Commissioner Nelson said need to treat the consumer information on consistent basis, if the applicant wants to make that public, that person can do that.  If we start treating consumer information inconsistently, we will see problems.
Mike Gilmore said any time they want to go formal, it is public.
Bev Barker said originally we thought people appealing would be those concerned about safety and privacy.  All the attention was focused on keeping that confidential.  That was the motivation for establishing that procedure.  Even going into executive session won't meet those concerns, next step would be filing formal complaint.  Don't know that the Commission's letters denying appeals expressed the pursuit of formal complaint.  If Commission has informally decided it, it is unlikely that Commission would change their mind.  Have not formally notified people that they had option to file formal complaint.  We could do that.  Other thing would be to say you have a choice right up front, to go formal or informal.
Commissioner Smith said she thought that decision should be made at the point where they tell them what staff is going to do.  Tell them what their choices are.  You can go home or file formal complaint.  (1)  Formal, (2) Executive session that will be private.  Whatever our lawyers tell us to do on this we will do, to abide by the open meeting law.
Mike Gilmore said he thought it is open.  An analogy is if you are discussing employee matters, that employee could be there.  You could also discuss it without them.
Commissioner Miller said is seemed to him that from here on we should do as Commissioner Smith suggested.  Customer would be told of the formal option and informal option.  If they choose formal we would follow complaint procedures, that is in place.  Don't need to reinvent it.  If customer chooses formal, has all the rights and opportunities associated with that.  Would be appropriate for staff to prepare an informal letter or document to be given to the customer at that time.  Customer will have opportunity to
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read it and make decision and to eliminate any possibility of later problems because customer didn't understand the options.
So, would everybody agreed that that would be for the block of people who choose to have their appeal in a public forum, that that would be the way to do it?
That takes care of that block of people prospectively.
Then the block of people that choose private determination, we would follow the staff proposal in Don Howell's decision memo complying with public meeting law?  Do need to decide whether we would want to meet informally, privately with the applicant or we would like to consider it based on the documents developed.  Mike Gilmore seems to think that choice is open to the Commission.
Mike Gilmore repeated - yes.  You have a lot of freedom as to who is and is not in executive session.  
Commissioner Miller said if a person chooses the private route, then we ought to do it based on the documents, simply because it would be cumbersome and could envision those meetings being difficult, if we have private informal meetings.  If a person wants more than us to decide on the documents, then think that becomes a public thing and we should do our work in public and even the phone company could participate in it and give the reasons why it shouldn't be granted and that should be public on the record.  If person opts for informal review, that would occur on review of documents generated.
Commissioner Smith said in her mind the executive session is this meeting closed to the public.  We don't take evidence, don't take record, don't present evidence or have attorney.  So in her mind, it wouldn't matter whether or not they are there.  That is for Commission deliberation.  If they want to sit and listen and they don't meet the standard, don't care.  It is not an opportunity to argue, bring in evidence or to persuade commissioners.
Commissioner Miller said he agreed.  He was confusing presentation with right to speak.  If commission does it in executive session, sees it being Commission and applicant.
Commissioner Nelson asked what is the purpose of deliberating in private if it is not private.  If it is the applicant's choice to be there, why go into executive sesion?
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Commissioner Miller said there wouldn't be a public record of it.  It would just be denied or reversed.
Commissioner Nelson said he would hate to make the decision today that the applicant has a right to be in executive session.  One of the reasons for private session is you might take a position that is not final and could change.  Think allowing the applicant to be in there is fine but if we give them the right we are missing the point.
Commissioner Smith said if they want to be there is it fine with her.  Do want to clarify one thing.  People should understand that the standard for obtaining line blocking is set, that the process for individuals to call thru and talk about whether they met the standards only puts at issue if they met the standard.  If they are unhappy with the standard, that is waiting for the end of the reconsideration process and take us to court.  You need a final order from which to go forth on the standard.  All we are talking about here is the procedure for finding out if customers have met the standard and should they be given line blocking or not.  On the question of executive session, don't care if you say you can come on in.
Commissioner Nelson said if you go the other route and file a formal complaint, we have complaints that don't go to hearing.
Commissioner Miller said so on the process of the applicant at executive session, are you saying that on a case by case basis you don't mind if they came but don't want to make an ironclad decision?
Commissioner Nelson said yes, don't want to make a decision that they are entitled to come.
Commissioner Smith said it would only be that portion of the session that applies to them.
Mike Gilmore said if he were going to be arguing this before the Court, would want it to be shielding the name from the public at large.  
Commissioner Miller said as a general matter should not force people out but it is not an opportunity to speak, but an understanding of what happens to them and the process, people should be entitled to.
Commissioner Nelson asked - are you arguing that if we went into executive session on contested case, parties would have right to be there?
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Mike Gilmore said no.
Commissioner Miller said the contested cases concerns would be much different from investigatory records concern.
Mike Gilmore said the contested case exception will not fit under this section of the code.
Commissioner Nelson asked about personnel actions?
Mike Gilmore said that is a difficult one.  The grievant has some right to make their pitch at some point or another.
Jack Vanvalkenburgh said he appreciated the discussion.  Asked - what does the formal route that Commission might take involve, would that deter people?
Commissioner Miller suggested getting together with staff to review that.
Jack VanValkenburgh commented - wonder how an applicant denied line blocking where they don't divulge the reasons, would imagine they would want to go the private route .. if they went the private route and went into executive session and only looked at the form, what I hear Commissioners say is person would not have opportunity to discuss those concerns.
Don Howell said applicant would have an appeal once they appeal to set out in great detail why they felt their safety was jeopardized.  that would be protected.  There has to be some development of the facts.
Commissioner Nelson said we could allow a statement.
Commissioner Smith said if we choose they could make a statement.
Jack Van Valkenburg commented they could be assured it would be protected.
Don Howell said 90% of the complaints don't have all the information.
Bev Barker explained instances where people have expressed concerns and they have contacted the company and line blocking was given.
Commissioner Miller said that takes care of those who want formal and those who want private.  Have understanding
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Can we get this in some form of document clear to the public?  Do we need to address a third block - everybody that we have denied line blocking for, up until now, as Bev indicated, we started doing it out of concern for privacy for the individuals.  Now find some would have preferred to have their claim decided in a public way.  Do we need to go back and look at those we have already done?
Commissioner Smith asked - is there a process for reconsidering?
Don Howell said when they re handled informally, the Commissioners aren't necessarily involved in the process.  Because of the privacy concerns, the Commissioners have been involved informally.  Think the problem is we need a final order and they can ask for reconsideration.
Bev Barker said she thought a way of dealing wit it would be putting together a letter explaining formal and informal procedures and give it to the people who have already gone through this process and say we have revised our procedures and whether or not we advised you earlier that you can formally appeal and here are the standards and let them make that decision.
Commissioner Miller said lets do that.  Then we would have our understanding of all three blocks of people.
3.  Scott Woodbury's May 30, 1991 Decision Memorandum re:  Case No. IPC-E-91-8 Proposed Changes to Schedule No. 71--Line Extension Tariff and Beverly Barker's June 3, 1991 Supplement to Scott Woodbury's Decision Memo in this matter.
Commissioner Smith said her answers are all yes.  
Agreed to by other Commissioners.  Also agreed to Bev Barker's recommendations.
4.  Lori Mann's May 30, 1991 Decision Memorandum re:   Revision to Fuel Switching Program; Case No. WWP-E-90-4.
Agreed unanimously.
5.  Eileen Benner's June 10, 1991 Decision Memorandum re:  GTE Advice No. 91-9; Waiver of non-recurring charge for Econo-Calling and Toll Discount Plan I and II.
Adopted staff recommendation.
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6.  Randy Lobb's June 12, 1991 Decision Memorandum re:  GTE Advice No. 91-8; Dial Datalink Service.
Commissioner Miller asked if this was offered elsewhere?
Randy Lobb said yes, nationwide, but U S West doesn't offer it.  Washington has approved it and one other state.
Commissioner Nelson said it would be cheaper than a more expensive modum he had to buy.  So he would say okay.
Commissioner Miller said it does raise the question of what is the minimal quality that should be included in basic local exchange.
Bev Barker said we do get a number of complaints about these.
Commissioner Nelson said this offering may raise the level of consciousness of service these people are getting.  Partly for that reason would let them offer it.  
Commissioner Miller said it is a legitimate question as to whether or not this should be a question of basic local service.
Decision was:  approve the tariff and keep an eye on it.
7.  Belinda Anderson's June 12, 1991 Decision Memorandum re:  Alternate Communication Technology's Request for "0-" Exemption from Telephone Customer Relations Rule No. 9.3, Emergency Access Required.
Commissioner Miller asked Belinda Anderson if it looked okay?
Belinda Anderson said yes but hasn't been able to do an actual test because they are not in Idaho yet.  Could perform test later.
Approved.
**Went back to Item 6 - will be reconsidered next Wednesday - whether it is basic local service.
Randy Lobb asked if there was additional information the Commission wanted?
Commissioner Smith responded - is there an industry standard?  What is U. S. West's standard?  What can other Idaho customers expect?
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Randy Lobb said there are standard transmission speeds for new equipment.  Those are the only standards but as far as voice transmission, there isn't a standard.
Commissioner Smith said NARUC Communications Committee has standards.
Randy Lobb said company said they are looking at 15% of their access lines not meeting this.
Don Howell asked if it was in the rural loop?
Randy Lobb explained it was lots of different places and they do it on a case by case basis.
Commissioner Miller asked - so 85% of the lines in the territory would meet the standard without the conditioning?
Randy Lobb said that was what they indicated to him.  There is probably a certain standard for what is adequate.
Commissioner Smith asked so 3/4 of the people will not know if they need it?
Commissioner Miller said assume most of the tariffs will say standards is voice grade.
**Matter will be held at this time.
9.  Tom Faull's May 24, 1991 Decision Memorandum re:  Cases Nos. WWP-E-89-6, IPC-E-89-11, PPL-E-89-3/UPL-E-89-5; Annual Update of Adjustable Portion of Avoided Cost Rate.
Commissioner Smith asked if Colstrip was the avoided resource?
Tom Faull said he did a blend of Colstrip and Valmy.
Commissioner Smith asked if this was a generic change involving more than one company?
Tom Faull said yes.
Commissioner Smith asked - do we have a notice problem in changing the avoided cost rate?
Tom Faull said if it is for generation June 1 it wouldn't be in the billing until July, don't think that is a problem.
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Scott Woodbury asked if we weren't asking for July 1 effective?
Tom Faull said June 1 is what companies are prepared for.
Commissioner Smith said that is why she wondered if we have a notice problem.
Tom Faull said the rate is going up.  So the QFs will not squawk.  All the companies are aware.
Commissioners replied yes to all 9 questions.
**Back to Item 3 - IPC-E-91-8.  
Commissioner Miller said he wondered if it shouldn't just be approved?
Scott Woodbury said he will attach the schedule to the order and people can ask for reconsideration if they wish.
**Approved instead of doing modified procedure.
**Held Item 10 - Lori Mann's Decision Memorandum re:  Case No. GNR-T-90-1; Privacy Investigation in Telecommunications Services.
11. Mike Gilmore's May 28, 1991 Decision Memorandum re:  Petition for Reconsideration from Order clarifying Potlatch Telephone Company's Certificate of Convenience and Necessity--Case Nos. POT-T-91-1 and INL-T-91-1--Order No. 23632.   
Commissioner Miller said perhaps Commissioners should grant reconsideration.
Mike Gilmore suggested denying it and say you can file a petition.  
Commissioner Miller said if there is something wrong with it, we should fix it but would give them 10 days (or 14) to respond.
Lynn Anderson said it does turn out that the certificate is correct except for Leon.  Their Leon map overlaps GTE.
**Give them 14 days.
Commissioner Miller said if you want to put in a zinger about no facts, you can.
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Mike Gilmore's May 30, 1991 Decision Memorandum re:  Commission Staff Motion to Initiate an Investigation to Restructure U S West-Southern's Rate for Local Exchange Service--Case No. USW-T-91-5.
Commissioner Miller said perhaps we should get further comments on what staff was trying to get at when they filed the motion.
Mike Gilmore explained what staff was thinking.  It was to set things in proper relationship, not just that they were making too much money.  Did not have in mind establishing EAS rates but wanted to get things in order so there won't be so many EASs.
Commissioner Smith asked what standard are you going to use if something is not in appropriate relationship.
Mike Gilmore said - kind of the common good of the society.  
Commissioner Miller asked if staff was thinking about all Title 61 or just some?
Lynn Anderson said just monthly local exchange rates.  At one time wanted to look at zone connection and upgrade charges.
Mike Gilmore said he didn't think we can recommend decrease in all rates.
Commissioner Miller asked what staff thought about the idea of looking at all the rates (Title 61) and as component of that, trying to figure out some cost allocation principles based on value of service, universal service, social goals, etc.
Mike Gilmore said for Title 61, left it whichever way you wanted to go.  For rates, think we will probably expand the scope of the case beyond what U S West thought.  They don't want it expanded like that.  We thought what we did try to do is get rural exchange rates in rough parity.  Our rate setting goal was to keep costs out as much as possible.  Don't think a system that is so overwhelmed by capital costs can be sensibly ...giving that kind of blessing is not how we want to go.
What staff had in mind was something that could be raised up in 6 months to a year.  
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Commissioner Miller said - don't know whether the time, effort and expenses would be worth the outcome.  From his point of view, that sort of evidence would be more elaborating than restrictive (fully disputed cost study).  Moving rates around solely on the basis of value of service, probably has role in telephone, concern about accepting cost studies in telephones are simply vodoo economics and if you accept that principle, would never be able to allocate costs between regulated and unregulated.  We may decide that rather than share revenues.  The other thing that started him thinking along those lines is these rates have not been viewed since May of '85 and since that time a lot of the things have changed.  Guess you are envisioning something not that dramatic.
Commissioner Nelson asked - did this just start out as what are we going to do about EAS and it expanded?
Lynn Anderson said yes.
Commissioner Nelson said if you open a case and one intervenor comes in and asks how are you going to limit it, what is the response?
Mike Gilmore said he didn't think you need to grant the motion right away, but convene a hearing on the motion.  U. S. West would be there and it would smoke out intervenors.
Commissioner Miller said that might be a reasonable approach.  Give everybody a chance to say where they would like to see it go.
Mike Gilmore said developing the record was mentioned.   Think we can get feel from the parties about what they will be challenging.  Think you can take care of one of your record-building concerns at a prehearing conference.  
Commissioner Smith said we are much more vulnerable on cost-related case.  
Commissioner Miller said if you really did cost, could get study to justify whatever you wanted to do.
Commissioner Smith said she had reservations about opening a case where the rates could go up to some residents.  Think the answer will be the same if it is cost case or value of service.
Don Howell said if your focus is to nullify EAS, unless they agree to bring it to the table, that is at least one on the shelf package.
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Mike Gilmore suggested a prehearing conference to discuss the Motion.
Commissioner Miller agreed but said he wouldn't give up on his cost idea.  Is not necessarily committed to it so prehearing conference would be good.
Commissioner Nelson said he didn't object to a prehearing conference.  Is concerned about what started as what to do with EAS has now escalated.  Don't think you get very far beyond that before you have problems with limiting issue.
Commissioner Miller said the question of where you draw the fence around this case is difficult but important.  You can try to keep it small, but things keep being added.  Then would reach a point where all rates should be looked at.
Commissioner Nelson said maybe prehearing conference would help come to conclusion as to how far we want to go.
**Find date for prehearing conference was the decision.
13. Don Howell's June 5, 1991 Decision Memorandum re:  Calling Data from the Three GTE Border Exchanges, Case GTE-T-89-7.
Don Howell explained the situation.  Options are basically - do nothing, leave things the way they are, or to order TOLLPAC and change that rate.  Calling rates and calling data are attached.
Discussed the attachment.
Don Howell explained it is about 8 to 8 Rock Creek to Spokane and Rock Creek to Coeur d'Alene.
Commissioner Nelson said he thought that was Setters numbers and they were skewed because of the grain company.  There are 27 in Setters, etc., 50 total.
Commissioner Miller said he came back to the question, do the customers in these exchanges have a desire for these service and do they have a need for these services that would justify the work of getting them provided.
It wouldn't from the call volume number - it wouldn't seem real compelling.
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Don Howell said to make any kind of change you need LATA waiver first.  If you don't want to do it now, that makes the company happy.
Commissioner Smith said her inclination is to not make any changes unless we have a large customer outcry.
Commissioner Miller said the reason we wanted data was because Lynn Anderson thought reason there wasn't any outcry was because people didn't know about it.
Lynn Anderson said he was sorry we didn't take care of these when we took care of Tensed.
Commissioner Miller said how about if we set this aside for a few minutes and see what else we can get through and come back.
Commissioner Smith asked about Tensed call data, in that with the waiver?
Lynn Anderson responded it was for Tensed into Idaho.
Matter was held at this time.
14. Terri Carlock and David Schunke's June 5, 1991 Decision Memorandum re:  Pacificorp Interjurisdictional Allocation Issues.
Commissioner Miller said one of his reactions as that one of the three Commissioners work on this.  It is a topic you have to have studied to be able to confer about it.  Right now, have not devoted himself to the topic.  When he read through this stuff, realized how difficult this was and how difficult to give any advice or guidance, but at the same time are doing Dave Schunke and Terri Carlock a disservice by sending them off to these without guidance.
Commissioner Nelson said perhaps he should study these because he did have questions.  Questioned #7 - it is so different in every state.
Dave Schunke said unless all the taxes are treated situs they should all be considered jurisdictional.
Commissioner Nelson said if it is jurisdiction, yes.
Dave Schunke said Wyoming's biggest tax was on the coal.
Commissioner Nelson questioned that.
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Dave Schunke said actually Wyoming wrote a paper and they take position all taxes should be considered situs.  
Commissioner Nelson said it is certainly worth some discussion.
Dave Schunke asked Commissioner Nelson about this?  Think the shift is toward them all be treated the same.  Asked Commissioner Nelson if it was his preference to use jurisdiction?
Commissioner Nelson said he wanted taxes used that are not way out of sinct.
Agreed Commissioners should get involved.
Commissioner Miller asked Dave Schunke what Commission needed to do for him before he goes to Monday's meeting?
Dave Schunke said he needed response to questions - tax was major one.
Went over the questions.
Washington and Oregon commissions sent letters out a a year ago saying the two divisions ought to be retained forever.  Wyoming and Utah would like to see them rolled together in the foreseeable future.
Is leaning toward a roll-together at some time also.
Commissioner Nelson said there should be one company at sometime.
Dave Schunke said we only promised them that they will not be adversely treated.
Spoke to the stand alone clause.
Question 3 - Is it necessary to maintain the stand alone comparisons?  Are other options more feasible?
Everybody agrees that the stand alone analysis is difficult to do and impossible to test but at least for Oregon and Washington, they admit they need some assurance.  Assume that the Commission wouldn't be opposed to a measure that would improve upon that.
4.  Should Idaho be treated as a separate jurisdiction in the Pacific Power Division?
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Dave Schunke explained he had written a paper on that.  We have also take the same position on conservation.  Only thing that is a little different here is all are fairly active and all are situs except Idaho jurisdiction.
Commissioner Miller said he wouldn't be in favor of abandoning our position on this.  Case is stronger for it then it has been.
Commissioner Smith said the region is moving more toward regional concern.
8.  Should consultant be hired or group formed to evaluate the APS and Colorado-Ute deals?
Commissioners said yes.
**Dave Schunke said he had enough information now.
Meeting adjourned - to be reconvened June 14 on held items.
        DATED at Boise, Idaho this       day of August, 1991.

PRESIDENT

COMMISSIONER

COMMISSIONER
ATTEST:

Commission Secretary
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