19930601.docx

Minutes of Decision Meeting
June 1, 1993 - 1:30 p.m
In attendance were:  Commissioners Marsha H. Smith, Joe Miller and Ralph Nelson and staff members Mike Gilmore, Scott Woodbury, Lori Mann, Tonya Clark, Gary Richardson, Joe Cusick, Belinda Anderson, Tom Faull, Stephanie Miller, Mary Friddle, Eileen Benner and Myrna Walters.  Also in attendance were Walt Sorg of GTE, John Souba of U S West, Woody Richards, Attorney at Law and Conley Ward, Attorney at Law.
First item of discussion was Item 10 - Lori Mann's May 20, 1993 Decision Memorandum re:  Springfield Petition for Toll-Free Calling to Blackfoot; Case No. GNR-T-92-9 - held from May 24, 1993 Decision Meeting - for further discussion.
Commissioner Smith asked staff to report on blocking and access to 911.
Lori Mann responded.  Said there are only 8 circuits available.  Staff talked to U S West and they indicate 911 is on a dedicated switch and it will not be interfered with by implementing EAS.  If the circuits happen to be busy, you can still get 911.  O-would also not be blocked.  They are dedicated circuits.  Said it will also take 90 days to do the analog cut-over.
Discussed when to implement.
Commissioner Miller said if we are satisfied there couldn't be blocking, that would take care of public safety.  
Commissioner Nelson said he didn't think 90 days was unreasonable.
John Souba reported why it would take 90 days.
Commissioner Smith said the other choice is to do it next year when there is a sizeable upgrade.
Belinda Anderson responded it will be equipment they can use somewhere else.
**Go ahead in 90 days.  
Commissioner Miller said in our draft order we have this summary of staff testimony to the effect that the toll carriers loose money on these routes.  That is seen as lack of competitive harm.  Seems to him that part of the problem is that access for Contel, when Commission did residual ratemaking, creates high access charges.  In fact, Contel
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access charges are so high they are anti-competitive.  So to set access rates at anti-competitive levels and use those to set competitive...and in this phase there were enough other factors to grant EAS that that wasn't relative.  That is not a persuasive argument for EAS.  So whether we want to do anything about it in this order, if there is enough other information.. that question could be... another way of saying that is when staff embarks on global EAS, this wouldn't be proof to expand on contract calling areas.
Commissioner Smith said her decision to grant EAS in this case was not on that either.  Didn't think the Commission relies on that in the order.
Commissioner Miller suggested not reciting it at all in the order.
**Will leave in that there are no other toll providers.
1.  Regulated Carrier Division Agenda dated June 1, 1993.
Commissioner Nelson said he found nothing in any of the letters of support that indicated an urgent need.  (Support letters were attached).
Commissioner Smith asked - do you suppose we should continue our past mode of operation until our rules are effective July 1?
Mike Gilmore said he would recommend that.
Discussed what new rules will request.
Discussed "urgent need".
Mary Friddle spoke to the letters of support.  They are typical of letters of support.
Commissioner Smith asked if there was a motion.
Commissioner Miller moved approval.
Commissioner Smith seconded.
Commissioners Nelson said he was not going to vote.
2.  Mary Friddle's May 28, 1993 Decision Memorandum re:  Petition for Reconsideration-Olson Construction & Manufacturing Housing Services.
Commissioner Nelson asked what authority Olson Construction has now?
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Mary Friddle responded.  This will be mobile home authority.
Commissioner Nelson asked if he has gotten a satisfactory rating?
Not recently.
Discussed when the 42 days are up.  Discussed whether or not another trucking company in the area was the reason for the denial?
Mr. Kelley's petition was timely.
Commissioner Miller said he guessed you don't have to be a party to it before petitioning for reconsideration.
Commissioner Nelson said based on history...can't see reason to deny.
Discussed how this would affect new rules.
Commissioner Miller said - could grant reconsideration for written comment which would allow Kelley to state his case and then evaluate this in light of what we come up with on any policy that comes out of our rule proceeding.
Commissioner Smith asked - don't you think we have to consider this application on what is in effect now, not after July 1.
Commissioner Miller said he didn't know theoretically when they would apply to applications.
Tonya Clark said protesting applications is not new.
Mary Friddle said the law still states you have to prove public convenience and necessity.
Commissioner Nelson asked if they weren't based on fitness?
Commissioner Smith said she was confused on the dates.
Mary Friddle explained.
Discussed the timeframe.
Commissioner Miller suggested - could deny it as being out of time.
**Be sure that it was more than 3 days late.
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3.  Belinda Anderson's May 21, 1993 Decision Memorandum re:  MCI's Transmittal No. 31 for Collect Calls.  Returned to the Agenda from the 5-24-93 Decision Meeting.
Commissioner Miller said he asked to have this put back on the agenda - may have led the Commissioners down the path..thought this should have the benefit of being exposed to what the staff point really is.  Not sure if he agreed or disagreed but at least MCI will have an opportunity to state their side of it, whether that can be accomplished in the deaveraging case or in some other way, is not sure.
Lori Mann said she added Option J to the case but did not add the "ff" reference.
Commissioner Miller said how we can get that organized in a way MCI can respond to, is what he wants to do.
Commissioner Smith asked why the earlier decision was inappropriate?
Commissioner Miller said he thought what we did in the meeting was to decide that the ff was okay and the other deaveraging issue should be in the deaveraging case.  Now think the issue is should we step back and address the footnote issue?
Belinda Anderson said it is a deaveraging issue but staff also thinks it is charging prices not on the price list.  It is leaving out something that would allow people to determine rate charged for the product.
Commissioner Smith said all you have to do is take them a tariff page.
Belinda Anderson said you would have to know every other carrier's price list.  
Explained how they would get the rate.  Would have to know whose rates that person originally used in order to identify whether they had charged the correct rates or not.
Commissioner Nelson said it is a tariff strategy.
Belinda Anderson said staff believes it is entirely deaveraged but there is also a problem with the footnote.
Commissioner Miller said it gets to a bigger question, whats the reason for price lists, do we serve the public good by looking at numbers, or is there some benefit allowing competing carriers to find different ways on
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price?  This is not an uncommon form of price setting.  Those are the questions involved.  Somehow would like to hear MCI's point of view as to why we should allow this or is it more important to have public documents where prices are more readily ascertained.  How do we do this?
Lori Mann said Option J has been added to the case.  Explained how they would be deaveraged.  Said she could call MCI's attorney about the footnote.  Their brief is due June 11 now.
Eileen Benner explained why it was brought to decision meeting.  In accepting it, the footnote was overlooked.
Mike Gilmore suggested opening a generic case to discuss this.
Was decided to do that.
4.  Jim Long's May 25, 1993 Decision Memorandum re:  Chatcolet Petition for Toll Free Calling Between Chatcolet, St. Maries and Plummer-Worley Exchanges.
Commissioner Smith asked if there was anyone who wanted to do anything rather than suspend, pending outcome of EAS study?
No one did.
Matter will be held.
5.  Scott Woodbury's May 4, 1993 Decision Memorandum re:  Case No. IPC-E-92-31--Rosebud - Mountain Home.
Scott Woodbury said he circulated the correspondence between the parties, that occurred the last week.  Reviewed what was said.  Said he circulated earlier, memo regarding facilities larger than 10 mws.  No case has been filed by Idaho Power saying it is inappropriate for QFs over 10 mws.  Should a more direct filing be required?  There us no record to base reasonableness of rates and rate structures on rates offered to Rosebud.  Both parties believe the case should go to hearing.  Idaho Power's contention in its identification of issues is that Rosebud is the complainant and they should go forward and file testimony first.  Don't think a petition for declaratory ruling is appropriate for change of methodology.
Mike Gilmore said you could have simultaneous filings by both parties.
Commissioner Nelson suggested opening a case on the appropriateness of the existing methodology, for facilities larger than 10 mws.
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Commissioner Miller said in some manner we need to get this to a hearing and have a hearing record.  It is important to have a good record in this case.  Either party may seek review.  Beyond that how you set up the issues and how you require the parties to address them is a little more complicated.  On the one hand, Idaho Power is not filing what is a well-established procedure.  There is the practical question of do you want to commit ratepayer funds for a 40 mw sulphur plant.  So it is not totally clear in either direction which way it would be coming out.  First inclination is if it is a case that we do have a procedure then it is not just up to the company to do something different.  With that framework, do we get something set up for their next project?
Commissioner Nelson said he agreed with COmmissioner Miller.  Don't see this as being particularly time sensitive.  Was sure he sees it differently than Rosebud.  But don't think we just sit on it.
Commissioner Miller suggested Rosebud act as complainant.  They must think they have certain obligations to prosecute their case.  Don't see how they could expect upon the filing of the complaint, to suddenly shift the burden to somebody else.  Would treat it like a complaint.  Let them file testimony.  Tell Idaho Power to file their testimony, have a hearing and decide.
Commissioner Smith said they probably expected us to read the complaint, tell Idaho Power to shape up and issue an order on current rates.
Commissioner Miller said we can always rely on the concept of developing a record to allow for decision.  Have filings, but not record to be reviewed.
Commissioner Smith said the problem she has is that in order to tell Idaho Power to calculate a rate under the current methodology, would require her to ignore reality in terms of company's load resource balance and the size of this facility.
6.  Scott Woodbury's May 27, 1993 Decision Memorandum re:  Case No. INT-G-93-1 - Gas Tracker.
Commissioner Smith asked about modified, specifically putting at issue the use of historic therms versus estimated '93 therms.
Scott Woodbury said we have already addressed that.
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Commissioner Smith said give company notice.
Commissioner Nelson asked if it was normal to conduct a full desk audit before we grant it?
Stephanie Miller explained what a desk audit was.  (Review things here instead of going out to the company).
Commissioner Miller asked - is it possible to do a careful analysis of Northwest Pipeline pass-thru?  See if there is anything there that shouldn't be part of a tracker?
Stephanie Miller said most of it is pretty straight forward.  IGC and WWP have to pay until FERC decides.
Commissioner Miller asked - are these 636 things?
Stephanie Miller said they are - the change from old ODL rat3e to transportation rate and fixed variable in place of what they used to use.  They are 636 issues.
Commissioner Miller asked - is there any issue of prudence of the company's action to put themselves in a position to get nailed with those charges or are they unavoidable?
Scott Woodbury said he thought it was factual.  Said he was setting the 27th as deadline.
7.  Washington Water Power Company Case No. WWP-G-93-4 - Potlatch Contract Case.
Discussed scheduling.    
Scott Woodbury said he would suggest that this just be a notice of application and comment deadline be established.  Staff has not had an opportunity to review it.
Commissioner Smith asked if this was the way we processed the last case?
Decided there was time spent on it before.
Commissioner Miller asked if this was a departure from current procedure?
Stephanie Miller said this is part of "capacity parking approach.
**Decided to issue a notice of application and comment period.
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8.  Mike Gilmore's May 23, 1993 Decision Memorandum re:  Rulemaking Cases with Comment Deadline of May 28, 1993:  Title 62 Rules, Universal Service Fund Rules, TRS Rules, Operator Service/Pay Telephone Rules, Railroad Clearance Rules, Railroad Accident Reporting Rules and Railroad Safety and Sanitation Rules.
Commissioner Smith asked about the comments of the payphone operators?
Mike Gilmore said he would check on that.
Discussed the comment deadlines.
Commissioner Miller asked about setting a month and putting them in the August version.
Mike Gilmore said yes.  Explained the July 1 date.  If we have a minor problem, it is not a big deal.  Think what killed us on MC was waiting for the ICC rule on single state registration.
Commissioner Nelson said he would move approval of Item #8.
Commissioner Miller said he was just trying to decide if it is better to meet the first deadline to get them published 99% okay and then go through clean-up or is it better to wait?  
Commissioner Smith said given the lack of comment on these, it would be better to go ahead on these and make the minor changes.  Can make the minor changes and get those over on time.   
No notice and comment on "typos".
9.  Mike Gilmore's May 28, 1993 Decision Memorandum re:  Adoption of Final Rules for Motor Carriers--Case No. 31-6101-9301.
Rule 9 - Fees - Staff recommended approval.
Note will be sent to the carrier indicating overpayment.
**Automatic, over 10, upon request under 10.  Refunds for 3 years.
Don't have accounts here so they can't be credited.
Make sure it says administrator on all rules.
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Rule 11.
Should be "Commission".  
No declaration of emergency without Commissioners knowing about it.
Rules 12/17 -
Tonya Clark explained how this came up.  (Leave out the number).
Drug testing.  Is something else for under 16.  This was not a concern.
Commissioner Smith said for 12, all we are doing is eliminating the 15 or more passengers?  So we are saying for whatever we are authorized to regulate we want to include safety and less than 16 passengers.
Tonya Clark said we always rated them except for hours of service.  Said she would note that we don't purport to include anything that we don't regulate.  
Commissioner Miller asked how many carriers does this mean will be inspected..their general ability ... you can have all the rules you want but if you can't enforce them it detracts from your credibility.
Mary Friddle said she thought there was enough staff to keep up with these.
Commissioner Smith asked - on Rule 17, do we want to have less than 16, have drug testing?
Commissioner Nelson asked what the federal rule was?  16 also?  Didn't have a problem with that until it becomes a problem.
**No drug testing.
Commissioner Smith said - see the Department of Law Enforcement for their comments.  Would like to update our adoption by reference.
**Clarify Rule 19.
Rule 22 -
Mary Friddle explained Horton's proposal here.  Said she agreed with that.
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Rule 26 - Tariffs.  
Commissioner Smith said it sounded like we have to get rid of our maximum rate tariff but what we replace it with, don't know.
Mary Friddle recommended filed rate versus maximum or minimum.  If we can at least have them file it and have standard to fill in blanks, would help them.  Then maybe get an accountant to set up an implementation plan to get them filed and train staff to audit them.  Then we could tell a consumer if they were overcharged or not  (Could verify rates).  Think we would be protecting the consumers yet not having a cumbersome system.
Commissioner Nelson asked about complaints?
Mary Friddle said she thought it was a fair amount.
This is only a change for a portion of the truckers.
Tonya Clark thought workshops were leaning towards filed rates.
Commissioner Nelson said what we would be saying is you can charge what you want if you have them on file?
Tonya Clark said if it is challenged.
Commissioner Nelson said if they have a filed rate they couldn't discriminate.
Mary Friddle said Oregon has some software they developed on tariffs.
Tonya Clark said the tariff section is for July 1, 1994.
Commissioner Nelson asked if there was any objection to filed rate?  This extends it under full truck load.
Commissioner Miller said it gets down to rate regulation.  Reason for tariffs is to prevent discrimination and market power in loose sort of way.  Shipper has market power.  Making the trucking part of the industry file tariffs won't change that.  If the shipper part of the industry is one of market power, think invariably the pressure is toward negotiated rates.  Pressure has been too much.  Trucking companies have been forced to charge below rates.  Seriously doubt rate regulation is possible in this industry now.  Wouldn't get as far as Commissioner's first step.
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Commissioner Nelson asked - are our maximum tariffs legal?
Commissioner Miller said he thought we probably have broad discretion on this.
Mike Gilmore said they have never been addressed in Idaho.
Don Howell spoke to what the statute says about "tariffed rate".
Mary Friddle said when it was discussed before it was decided to go with legislation but that didn't happen.
Discussed who was on the Motor Carrier Advisory Committee.
Discussed the fact that filed rates were the most popular at the meetings.
Commissioner Smith said it seemed to her if you want to force the issue at the legislative level, adopt a filed rate.
Tonya Clark said the people who want Commission to regulate want to be able to hold up to the shipper, PUC says I can charge this.
Commissioner Miller said he thought with the strength of market pressure it is still going to happen.  In a competitive market you want an administratively determined price.
Commissioner Nelson said with filed rates, if the shipper pays less than the filed rate, that shipper has had to make it up in bankruptcy.
Tonya Clark mentioned MCI rates being on file, it is the same issue.
Mary Friddle said having the maximum tariff is like not having one.
Commissioner Nelson asked how often they can file rate changes?
Mary Friddle explained.
Commissioner Nelson said he would like to put the onus on the legislature to change it if they don't like it.
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Mary Friddle spoke to the 1994 deadline, can reverse it if need be.
Commissioner Smith said she wasn't viewing these ad administratively approved rates, view them more as Title 62 rules.
Commissioner Miller said that would be subject to complaint, though.  Said he would not write a dissent, but did have strong reservations about any rate regulation.  Think it is unnecessary and a burden on the Commission.  Don't see any strong public benefits.
Commissioner Nelson said he didn't see us sitting down and setting rates for carriers.  Do see having a price list on file that a shipper can look to for discrimination.
Tonya Clark said she didn't think it was a legislative decision on reasonable rates.  If you don't look at it at all, is a $100 a mile or hour rate reasonable?
Commissioner Nelson asked - isn't the shipper going to ask what he will be charged?
Commissioner Miller said if you are dealing with full truck loads, you are dealing with sophisticated people, and they know how the industry works and they know how to negotiate, they know what the going rate is, and to him having a price list here in the office in Boise, can't see how that is helpful to the shippers.
Mary Friddle gave the example of tow truck rates.  There are lots of complaints about mobile home moves.  Those are the most complaints.
Commissioner Smith said she had in mind to do separate rules for tow trucks.
Commissioner Miller said he didn't see how any of this would solve mobile home problems.
Tonya Clark said she thought this was a policy decision, are we in or out?
Commissioner Miller said he thought this could be a legislative determination but also know there are overlaps and we are in a position of having broad range of policy decisions, if legal staff says we are compelled to go one way or another, that is different.  Think we have broad range of policy decisions.
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Don Howell said Idaho does have a filed rate statute.
Commissioner Smith said maximum rate is worthless.  One way or another we have to get rid of them.  Whether it is a filed rate or magic words in the statute.
Commissioner Nelson said going with ruled rates with year to implement, gives everyone a chance to speak up.
Commissioner Smith asked why July 1?
Commissioner Smith said - might want longer thank July 1, 1994.
Discussed "fill in the blank" tariff.
Decided on filed rate with October 1, 1994 date.
Mary Friddle said she would like to have an accountant review Oregon's software.
Commissioner Miller asked - when we have a fixed rate tariff, what becomes the role of negotiation between shipper and carrier?
Tonya Clark said they have two options.  They can either change their tariff to accommodate the particular shipper or they can enter into a contract.
Mike Gilmore said - or they can file a point to point tariff.
Commission can respond to unreasonableness complaint.
Commissioner Miller said he this was going to force the carriers to do all kinds of things to get around the filed rate.  Said his focus was on overall consumer benefit.  Said he was not convinced this will accomplish that.
Rule 41 -
Commissioner Smith said on financial fitness, thought people should be given a choice.
Commissioner Nelson said his problem with working capital is that it is going to be difficult for staff to determine that.
Mary Friddle said it would be nice to give them an option.
Mike Gilmore suggested wording - "have to meet the 10%".  Indicate what the alternative could be.
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Commissioner Nelson said he thought that was a good way to go - "or otherwise show financial ability".
Commissioner Miller said this one wouldn't cause him "heartburn".  You can make some possible link between financial and safety.  Don't think it is a regulatory concern if people "enter and fail".  It is a concern if they are unsafe.. you can see some financial threshhold will make some contribution to that.  One of the commenters said "it wouldn't matter what your financial condition is when you start... ultimately you are going to be in trouble and with financial requirement at the start, don't do anything but prolong the agony."
Commissioner Miller said he supposed it was okay, but he was not enthusiastic about it.
Page 8 - EquipmentListTest.
Proposed language on equipment list - approved.
Page 9 - Shipper support standards.
Commissioner Nelson said it is going to make temporaries difficult.  It says you are going to need a letter from someone who is going to use the service and they can't get it from anyone else.  Discussed whether or not it would be for transfers.
Commissioner Miller said he thought the problem here is, speaking generally, at this time we have a pretty low threshhold to enter the market.  We let anyone in, basically.  Seemed to him we are now raising hurdle of some amount but as time goes on, will have a difficult time knowing how much you have raised that hurdle.  You are going to open up again litigation of right to enter.  You are going to start to have to make individual decisions about whether or not people can or cannot enter the market.  Think that will be a very long, difficult process, assuming we don't get overruled by the legislature to find out where that new threshhold is.  Think there will be a lot at contest on that.  Appeared to him that suddenly you will have a lot of people trying to stop entry.  Secondly, don't think it is worth doing.  Other than protecting incumbents, can't see strong cause for having entry barriers where you have a market that is not a monopoly market.  Seemed to him we are raising the hurdle by an undefined amount when raising the hurdle serves no good purpose except protect incumbents.
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Commissioner Nelson said it would seem that in a large part we are raising the hurdle to all the current rule says it is - temporary.  What bothers him is that we let these people out on the road with absolutely no showing of safety fitness and particularly these summer passenger carriers.  Don't think they should be able to get a temporary each summer and then cancel and get new one each year.  
Mary Friddle explained the fire fighters' temporaries.  Explained the insurance requirements for temporary versus permanent.  They don't get a safety review.  There is nothing that prevents them from coming in for permanent authority.  More and more people are getting extensions on their temporaries, with no review of why they are asking for the extension or whether it is necessary.
Commissioner Miller said he didn't have any problem with making sure our safety requirements are appropriate.  Problem he didn't agree with is controlling entry with administratively determined need for their service.  That is where he disagreed.
Commissioner Smith suggested that Commissioner Miller wants it to say the Commission "presumes".
Tonya Clark said she wished she would have said we are at this point because they were going to deregulate this division, so as a result of that we agreed to go out and run this rulemaking past on what we thought we were hearing from the industry.  We took the show on the road, and we got input and think each commissioner has his own opinion on what you think the trucking industry should look like, but would like to say on behalf of the public, this is what we heard, this is what they wanted.  Other alternative, if we are not going to have meaningful regulation, then we will have a bill before the legislature.  Just want Commissioners to bear that in mind as they debate each rule on personal philosophy, on how you would regulate the industry, do not overlook the public.
Commissioner Smith asked - how broad was the participation in the workshops?  Were there larger carriers in each location?
Tonya Clark said the workshops were well attended by everything from two truck operators to Simplot.  Thought we got diverse input.
Mary Friddle said she thought it was all aspects of the motor carrier industry.  It was 10 to 11%.
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Tonya Clark explained that it was mentioned at all workshops, to make their comments.
Commissioner Nelson said he thought it should be harder to get a temporary permit than a permanent.
Commissioner Smith said she didn't mind saying on permanent that says - all comers are welcome with certain requirements.  Think you need more on temporaries.  
Commission could make finding on public convenience and necessity.  Think if you have insurance, safety rating and financial test, don't need a support statement.  Said she had already decided public is best served by having lots of alternatives.
Temporary is something different.  Maybe you need a guy saying I have to have him tomorrow and there is nobody else.
Mary Friddle said part of the reason for the shipper support letter is showing what they are qualified to haul.
Tonya Clark said some of the input was whatever he asked for he could have if he had shipper support for it.
Commissioner Smith asked - does that preclude someone from entering a new line of business?
Gave reasons to break it down by category.
Commissioner Miller asked -  if you are keeping low threshhold, are the two categories important enough to have?
Mary Friddle discussed the categories.
Commissioner Smith said what was important to her was financial fitness, safety and insurance.
**Want support statement for the temporary.
Tonya Clark said the only think support statement might do is eliminate protests.
Commissioner Smith said Commission has already determined that the more applications, the better, would deny protests.
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Mary Friddle said the carriers wanted support statements.
On letters of support for two truckers, they get input from sheriffs.  
Tonya Clark said if you drop the support statements, you are dropping what we have now.
Commissioner Miller said - but if we are going to say public is best served by having the most options, think shipper support is a formality.
Commissioner Nelson said for temporary, think they should have a showing of need.
Commissioner Miller said that didn't bother him.  Don't want to limit entry.  Don't think a letter of support is as important on permanent but is on temporary.  
Tonya Clark asked - do commissioners want to limit the temporary to that shipper?
Commissioner Nelson said - rule that we have proposed here is pretty strict.  Don't limit the public to just the supporter.
Page 15 - okayed.
Mike Gilmore is to do Rule 26 correction now.
Commissioner Miller said his concern is the end product may look quite a bit different than the proposed.  Does what he has in his hands become rules?
Mike Gilmore said he would go ahead unless the Commissioners tell him not to.
Up to 41.03 were okay.  
Commissioner Miller said he guessed we could knock out substitute language in this.
Commissioner Smith said the only worry is if industry thinks those are important, they are going to be disappointed.
Commissioner Miller said as you work down from there to political concerns, will have to deal with those who want whipper support letters and the incumbents.  Is trying to predict what this will set off from the legislative point of view, is something we don't know..  
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Commissioner Smith said it would be much easier for her to say entry shouldn't be restricted.  We are only concerned with equipment, fitness and insurance, that makes more sense than having this requirement because shippers already in business want them.
**Was decided to send 41.03 over to the Rules Coordinator as Mike Gilmore suggested and send others over later.
Meeting adjourned.
        DATED at Boise, Idaho this       day of August, 1993.
Myrna J. Walters
Commission Secretary
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