20061103Comments.pdf

SCOTT WOODBURY
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BAR NO. 1895
RECEIVED
2006 NaV - 3 PM 3: 35
IDAHO PUGUC
UTILITiES COMMlSSIOh
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
ACIFICORP DBA ROCKY MOUNTAIN
POWER FOR APPROVAL TO REVISE
ELECTRIC SERVICE SCHEDULE NOS. 10400 AND 401.
CASE NO. P AC-06-
COMMENTS OF THE
COMMISSION STAFF
COMES NOW the Staff of the Idaho Public Utilities Commission, by and through its
Attorney of record, Scott Woodbury, Deputy Attorney General, and in response to Order No. 30117
issued on August 21 , 2006, submits the following comments.
BACKGROUND
Pursuant to Commission approved Stipulation in PacifiCorp s 2005 rate case (PAC-05-
Order No. 29833) PacifiCorp agreed to file a general rate case no later than April 29, 2006 to
address cost of service issues not resolved in the 2005 Stipulation and to time the effective date of
new rates to coincide with the expiration of the current Monsanto contract (December 31 2006).
The Company s 2006 filing was delayed to permit Company contract negotiations to proceed with
Monsanto. The Company s filings in Case Nos. PAC-06-, 06-8 (Nu-West Stipulation) and 06-
(Monsanto Service Agreement) are intended to satisfy its 2005 Stipulation filing commitment.
STAFF COMMENTS NOVEMBER 3 , 2006
Applications
On June 21 , 2006, PacifiCorp dba Rocky Mountain Power (PacifiCorp; Company) filed an
Application with the Idaho Public Utilities Commission (Commission) in Case No. PAC-06-
requesting authority to implement revised rates in electric tariff Schedules 10 (Irrigation), 400
(Monsanto Company) and 401 (Nu-West Industries). Simultaneous and related filings were made
in Case Nos. PAC-06-8 (Nu-West Stipulation) and PAC-06-9 (Monsanto Service Agreement).
The Company in its Case No. P AC-06-4 filing requests authority to implement revised tariff
schedules that would result in a net increase in rates of $8.25 million (5.1 %) for retail customers
under irrigation Schedule No.1 0 ($1.7 million; 5%, less a 2007 load control credit of $450 000),
Nu-West special contract Schedule No. 401 ($150 000; 3.8%) and Monsanto special contract
Schedule No. 400 ($6.8 million; 16.5%). The proposed changes in tariff rates as reflected in a party
Stipulation dated May 24, 2006 filed in Case No. P AC-06-4 (PacifiCorp Exhibit No.5) are
agreed to by the Idaho Irrigation Pumpers Association (lIP A), Nu- West and Monsanto. No changes
in rates are proposed for other Idaho customer classes.
STAFF ANALYSIS
Revenue Requirement Analysis
Staff audited the Company Results of Operations (Larsen Testimony, Exhibit 1) for a test
year ending September 30 2005. During the course of the audit, Staff determined that there should
be adjustments to the Results of Operations for reductions in the return on equity, reductions in
capital projects that should not be included in rate base and reductions in annual expenses. Staff
believed it necessary to make these adjustments to the Results of Operations in order to evaluate the
reasonableness ofthe Company s combined revenue requirement increase proposal made in the
three filings. These adjustments and resulting revenue requirement will be considered preliminary
for future rate cases when other adjustments may be made. Staffs adjustments reduce the revenue
requirement for Idaho by approximately $5.0 million. The Staff Audit Report is provided as
Attachment A.
The Idaho revenue requirement including Staffs adjustments was compared to the revenues
the Company is currently collecting plus the $8.25 million in increases it is asking for in the three
cases. The total revenue that the Company has requested as a result of increases in these three cases
is less than the adjusted revenue requirement Staff determined through its audit. Therefore, from a
STAFF COMMENTS NOVEMBER 3, 2006
revenue requirement increase perspective, the requested increases in the Applications are
reasonable.
Cost of Service
The Company s cost of service results are shown on Company Exhibit No., Page 2 of3.
The Company s cost of service calculations are based on an Idaho jurisdictional revenue
requirement of $182, 112 209. For purposes of comparison with Staff s cost of service results the
Company s results are included in these comments as page 1 of Attachment B.
Staffs adjustments, as previously discussed in these comments and shown in Attachment A
are included in cost of service results that comprise page 2 of Attachment B to these comments.
Staffs adjustments in this case reduce the Idaho jurisdictional revenue requirement to
$177 097 281 , which still represents a potential Idaho jurisdictional revenue requirement increase of
$14 340 942 or an 8.81 percent increase overall. Staffs cost of service analysis shows the
allocation of those costs among the various customer classes and suggests rate increases and
decreases necessary to bring each class to full cost of service. Study results indicate that four
customer classes require double digit increases to attain full cost of service and that three customer
classes should receive double digit decreases. The double digit increases total $17 362 782 and the
double digit decreases total $1 171 740.
The 2006 Settlement proposed by the Company addresses three of the four classes that
Staffs cost of service analysis suggests should receive double digit increases. The Company
2006 Settlement proposal represents that the Commission accept negotiated rate increases with its
two special contract customers in Idaho and the Idaho Irrigation Pumpers Association. The
irrigators have agreed to a $1.7 million, 5.0 % rate increase which constitutes a substantial move
toward the approximate $3.7 million required for full cost of service as suggested by the cost of
service study. In addition, the Company has agreed as part of the settlement to provide a $450 000
credit to those who participate in the irrigation load control program during the 2007 irrigation
season.
Nu-West, Special Contract 1 in the cost of service study, has agreed to a $150 000
increase in rates which moves it toward the $428 000 increase required to attain full cost of service.
Finally, Monsanto, Special Contract 2 in the cost of service study, has agreed to a $6 843 817
STAFF COMMENTS NOVEMBER 3, 2006
16.5% increase in rates which moves it more than halfway toward the approximate $13 million rate
increase required to achieve full cost of service.
The fourth customer class identified as needing a double-digit increase is the Street and
Area Lighting class. Although the calculated increase is extremely large at almost 80%, the dollar
amount is a relatively small $254 096. It is Staffs experience that customer classes with relatively
small total revenue requirements may be subject to volatile cost of service results as allocation
factors and accounting data change with each new test year. Rate changes for such customer
classes should probably be based on consistent results involving more than one test year.
Cost of service is an imprecise science and in Staff s opinion should be considered along
with other factors such as rate stability when rates are established. It is Staff s experience that when
large increases are required to move one or more customer classes to full cost of service, the
Commission often opts to make the move in smaller incremental steps over time. In Staff s view
the give and take involved in the proposed 2006 Settlement is unusual in that the three customer
classes whose rates are farthest below cost of service have agreed to substantial rate increases and
the Company appears to have left some money on the table while other customer class rates remain
unchanged. In terms of cost of service, acceptance of the proposed 2006 Settlement provides for
substantial moves toward cost of service and leaves customer rates in a position where cost of
service differences should be smaller the next time cost of service is considered. Smaller cost
service differences should make it easier for the Commission to consider rate moves for other
classes in the Company s next cost of service case.
RECOMMENDATION
Based on the results of Staff s audit and cost of service analysis, Staff recommends that the
Commission accept the proposed 2006 Settlement. Staff s audit demonstrated that reasonable
adjustments to the Company s filing did not reduce the Idaho jurisdictional revenue requirement to
a level below that proposed by the Company through settlement with the three customer classes.
Staff s cost of service results demonstrate that the negotiated increases for the three customer
classes furthest from cost of service do not raise those rates above full cost of service nor do other
classes with rates left unchanged, remain unreasonably above cost of service. In fact, it appears that
the Company could have potentially justified a larger increase than that proposed but chose to
forego the higher request in the short-term in the interest of settlement. This is a significant
STAFF COMMENTS NOVEMBER 3, 2006
customer benefit that allows rate stability for other customer classes. Staff also supports the
$450 000 credit that the Company is offering to irrigation customers who participate in the
irrigation load control program during the 2007 irrigation season.
Respectfully submitted this day of November 2006.
Scott Woodbury
Deputy Attorney General
Technical Staff: Joe Leckie
Keith Hessing
i: u mi sc :commen ts/paceO6.4s wtckhjldesmp b 1 md .doc
STAFF COMMENTS NOVEMBER 3 , 2006
PACIFICORP dba ROCKY MOUNTAIN POWER
AUDIT REPORT
FOR
RESULTS OF OPERATIONS
TEST YEAR ENDING SEPTEMBER 30, 2005
IDAHO PUBLIC UTILITIES COMMISSION
ST AFF AUDIT REPORT
PREPARED BY
JOE LECKIE
AUDITOR
OCTOBER 2006
Attachment A
Case No. PAC-06-
Staff Comments
11/03/06 Page 1 of 9
ACIFICORP d/b/a ROCKY MOUNTAIN POWER
Audit Report on Results of Operations for
Test Year Ending September 30, 2005
BACKGROUND
In June 2006, PacifiCorp (Company) filed three Applications with the Commission in the
following matters:
Case No. PAC-06-
Application for Approval to Revise Electric Service
Schedule Nos. 10 400, and 401.
Application for Approval of Stipulation with Nu- West
Industries.
Application for Approval of an Electric Service Agreement
with Monsanto Company.
Case No. PAC-06-
Case No. PAC-06-
These three filings increase annual revenues from the Idaho jurisdiction (Idaho revenue)
to the Company in the amount of $8.25 million. The Company would receive approximately
$6.84 million additional Idaho revenue under the new Monsanto contract, $150 000 additional
Idaho revenue from Nu- West Industries under the proposed stipulation, and $1.26 million
additional Idaho revenue from customers under changes to Schedule 10, 400, and 40 I
(Irrigators ).
The purpose of this audit is to determine if the Company s requests for additional revenue
in these cases are reasonable. The Company has submitted as part of its case Results of
Operations for a test year ending September 30, 2005 (Larsen Testimony, Exhibit 1 and hereafter
referred to as Results of Operations). The Company s Idaho revenue requirement based upon
these Results of Operations will be compared to its current authorized Idaho revenue requirement
($163 120 418) plus any additional revenue it may receive if the Commission granted any or all
of the Company s requests.
SCOPE OF AUDIT
Staff attended workshops sponsored by the Company prior to the filing of the
Applications. The Company filed testimony and exhibits in Case No. P AC-06-4 that
supported its Applications in all three cases. Because the reasonableness of the Idaho revenue
requirement is at issue in all three cases, this audit does not discriminate among the three cases in
any of its findings. The reasonableness of the Company s requests is measured by whether the
additional revenue the Company could receive in conjunction with the proposed settlement
ACIFICORP AUDIT REPORT
Attachment A
OCTOBER 2006 Case No. PAC-06-
Staff Comments
11/03/06 Page 2 of 9
would result in a revenue requirement greater than, equal to, or less than what the Company
could potentially justify based on the Results of Operations.
Staff reviewed the Results of Operations and then submitted audit requests and data
requests, which the Company answered. Staff traveled to Salt Lake City and reviewed
documentation on site at the Company s office. Additionally, Staff interviewed Company
employees concerning questions about the information submitted by the Company. The model
assumptions, inputs and results were evaluated by Staff along with adjustments proposed. Staff
believed that it had sufficient information to evaluate the Idaho revenue requirement for the
Company and therefore measure the reasonableness of the Company s requests.
In determining the revenue requirement for the Company, Staff made adjustments to the
Company s requested rate of return, the Company s rate base and the Company s yearly
expenses as set forth in the Results of Operations. Each of the adjustments Staff used to
determine the revenue requirement were adjustments that Staff believed could be justified and
supported if the matters were put before the Commission in a contested rate case. These
adjustments are preliminary and subject to further review in the next general rate case.
Subsequent adjustments may be modified or expanded based on the facts of the case at that time.
SUMMARY OF ADJUSTMENTS
Staff s adjustments, based upon the Results of Operations with a test year ending
September 30, 2005, reduce the Company s revenue requirement by $4 906 519. With the Staff
adjustments developed in this case and the Revised Protocol cap of 1.67% (Order No. 29708
PAC-02-3) a revenue requirement increase of no more than $14 340 942 could have been
justified.
The Company is requesting in the three cases, an Idaho revenue increase of
approximately $8.25 million. Based upon Staffs audit, the Idaho revenue increases requested by
the Company in its three Applications is less than it potentially could have justified if the
revenue requirement issue were fully placed before the Commission on the basis of the Results
of Operations. Therefore, from a revenue requirement increase perspective, the requested
increases proposed in the Applications are reasonable.
ACIFICORP AUDIT REPORT
Attachment A
Case No. PAC-06-
Staff Comments
11/03/06 Page 3 of 9
OCTOBER 2006
STAFF ADJUSTMENTS
Return on Equity
The Company has included a return on equity of 11.4% in its Results of Operations. This
return on equity is not justified. It is not consistent with returns that the Commission has
recently approved in rate cases for similar electric companies. Also, the current economic
conditions and the current financial condition of the Company do not justify this rate.
The Commission in recent rate cases has allowed the following returns on equity for the
following Companies:
Idaho Power Company 10.25%(Case No. IPC-03-13;
Order No. 29505 (ill p. 43)
Avista Utilities 10.4%(Case No A VU-04-
Order No. 20602 (ill p. 9)
Additionally, the Company recently filed a Stipulation on July 21 2006 in its Utah rate
case (In the Matter of the Application ofPacifiCorp for Approval of its Proposed Electric Rate
Schedules & Electric Service Regulations; Docket No. 06-035-21) wherein it agreed to a return
on common equity of 10.25%.
There is no reason to justify a return on equity in Idaho that is any different than the
10.25% the Company stipulated to this rate in its Utah case just this year; and this rate is
reasonable when compared to the authorized rates received by other electric companies in Idaho.
Therefore Staff has adjusted the Results of Operations to reflect a return of equity at 10.25%.
The change in the revenue requirement is a decrease of$4 253 669.
Rate Base Adjustments
Staff believes that the Company s rate base should be reduced by $18 086 441 Total
Company or $1 163 689 for Idaho Allocation. This reduction is the anticipated cost of the
following specific major plant additions that were included in the Results of Operations:
Attachment A
Case No. P AC-06-
Staff Comments
11/03/06 Page 4 of 9
ACIFICORP AUDIT REPORT OCTOBER 2006
ital Addition
Controls Replacement & Rewind Main Generator
L1 Rogue Relicensing Hydro South
Cache Valley Transmission Line
Line 1 Conv to 115kV Line 14 Cap
Copco 2 Install 230/115 Tranfrmr
Total Co
$ 6 187 683
$ 2 699 378
$ 3 026 888
$ 3 615 030
$ 2,557,462
$18 086 441
Idaho Allocation
$ 398 118
$ 173 679
$ 194 751
$ 232 593
$ 164,548
163 689
The Company included these plant additions because these additions were originally
scheduled to be completed prior to December 2006. This cutoff date for completion of major
plant additions included in the Results of Operations was chosen by the Company under the
assumption that these major plant additions would be in service prior to the issuance of an order
by the Commission in any of the Applications.
The Company has admitted in its answers to audit requests that these specific major plant
additions will not be completed by December 2006. Therefore, under the Company s own
parameters, these projects should not be included in the Results of Operations.
Staff does not accept the Company s initial premise that major plant additions should
include all projects with a scheduled completion date of December 2006. In a fully litigated rate
case, any capital project that is not in use within the test year must be closely scrutinized before
it is included in rate base. If a capital addition not in use within the test year is included in test
year rate base, care must be taken to insure that all revenues, expenses and expense savings
associated with that specific capital addition are also included in the test year Results of
Operations.
Because the Company included these major plant additions in its Results of Operations, it
also included depreciation expense for these assets. The Company s increase in depreciation
expense and the resultant addition to Accumulated Depreciation should be adjusted to reflect the
removal of these capital projects. Annual depreciation expense will decrease by $466 169 Total
Company and $29 994 Idaho Allocation. The Accumulated Depreciation balance will also be
reduced by six months of the depreciation expense, or $233 084 Total Company, and $14 996
Idaho Allocation.
EXPENSE ADJUSTMENTS
Staff believes at least five (5) adjustments should be made to annual expenses the
Company has included in its Results of Operations.
ACIFICORP AUDIT REPORT
Attachment A
Case No. PAC-06-
Staff Comments
11/03/06 Page 5 of 9
OCTOBER 2006
Capital Stock Amortization
The Company is asking to include past costs it has incurred when acquiring equity
capital. It is the cost for issuing common stock. The total amount of costs the Company has
asked to recover is $41 101 061. The Company elected to amortize the recovery of these costs
over 20 years. The annual amortization is $2 055 053 Total Company and $122 143 Idaho
Allocation.
Staff does not accept the amortization for any of these costs, and has removed all of this
expense. The Company hasn t received authorization from the Commission to defer any of these
costs. Additionally, the Commission hasn t allowed the recovery of costs for the issuance of
common stock as an expense item. The authorized return on equity includes a component for
issuance costs and this cost has been reflected in Staffs discounted cash flow analysis.
Therefore annual expenses are reduced by $2 055 053 Total Company and $122 143 Idaho
Allocation.
Recovery of Grid West Costs
The Company incurred costs as part of its participation in the Grid West process. Now
thai the process is no longer active, the Company is asking to defer these costs in a case currently
before the Commission (Case No. PAC-06-3). The Results of Operations include an annual
amortization of these Grid West costs to Idaho in the amount of $204,462.
Commission Order No. 30156 in Case No. P AC-06-3 authorized deferral of only the
loan amounts made to Grid West. The Commission established a five-year amortization period
beginning January 1 , 2007.
The ordered amortization of these costs is different than the assumptions made by the
Company in the Results of Operations. The $2 300 000 originally loaned to Grid West
amortized over five (5) years without any interest or carrying charges results in an amortization
of $460 000 Total Company and an Idaho Allocation of$29 597. Therefore, the revenue
requirement is reduced by $174 865 ($204,462 - $29 597).
ACIFICORP AUDIT REPORT
Attachment A
Case No. P AC-06-
Staff Comments
11/03/06 Page 6 of 9
OCTOBER 2006
Incentive Pay for Non-Union Employees
The Company has an incentive pay program in place for its non-union employees. The
current algorithm for determining the amount of each individual employee s incentive award is
divided into three different factors. First, 60% of the award is based on the individual employee
achieving personal objectives as determined by the employee and supervisors. Second, 25% of
the award is based upon the achievements of the business unit where the employee is a member.
Part of the achievement measure for the business unit is profits and net income contribution. The
last 15% of the award is based upon the achievement of the Company in meeting its business
plan objectives. Again, profits and net income are a measure used to determine the amount of
awards given to the employees based upon this factor. Profits and net income contribution are
not the only measure used to determine the incentive awards in the second and third factors, but
profits and net income are clearly a part of the algorithm.
Any portion of the incentive awards attributable to the profit and net income contribution
measure is an expense that should not be included in rates. Therefore, Staff has made an
adjustment to remove that portion of the incentive awards.
The Company does not have precise amounts nor has it identified any objective criteria to
determine what portion of the incentive awards are attributable to profits and net income.
Therefore, Staff evaluated the components to establish its position to remove a portion of the
incentive award and to determine the amount of the adjustment. Staff does not believe any
portion of the individual performance factor (60%) is attributable to profits or net income
contribution. Staff estimates 10% of the 25% factor for business unit performance and 5% of the
15% of the Company performance are attributable to profits and net income contribution. This
15% of the total award (10% plus 5%) should be removed from expenses in the Results of
Operations.
The Company has budgeted $21.7 million for incentive awards in 2006. Staff reduced
employee compensation by $3.25 million ($21.7 million X 15%) Total Company and $193 165
Idaho Allocation. In the next rate case actuals versus budgets and percentage allowances will be
evaluated further.
P ACIFICORP AUDIT REPORT
Attachment A
Case No. PAC-06-
Staff Comments
11/03/06 Page 7 of 9
OCTOBER 2006
Lease Expense
The Company is currently not using all the office space it is currently leasing at the One
Utah Center in Salt Lake City, Utah. One complete floor of the three floors leased by the
Company at this location is vacant. The Company does not have any future plans to use this
space, and is looking to sub-leasing it. Staff reduced lease expenses by $1.0 million Total
Company as the expense for this unused lease space that is not reasonable as an ongoing expense
or used and useful. This adjustment reduces the Idaho allocated expenses by $59,435.
Corporate Cross Charges
Staff examined the costs the Company is claiming in the Results of Operations
attributable to cross charges from its affiliate companies. Because most of the historical
information in the Results of Operations are a result of cross charges by ScottishPower, the
historical financial information is not a good reflection of actual cross charges from the
Company s current affiliates.
Staff reviewed the bills and detail the Company received from MEHC for the period of
April 2006 to July 2006. Based upon this limited review, Staff reduced annual expenses for
cross charges by $1.5 million. The detail in MEHC's bills indicated that some of the charges
billed to the Company are for services and activities that are a duplication of services and
activities already being performed by the Company. The Company s expense for providing
these services and activities are already included in the Results of Operations. As an example
there are charges for legal service performed at the MEHC level. The Company has its own
legal department and the costs for the Company s legal department are included in costs
recovered in rates. The bills received for legal services from MEHC do not distinguish between
legal services that are specific to the Company s operations and those legal services that focus on
legal matters that are affiliate related.
Also, the Company was billed for activities that appear to be related to MEHC's tax
obligations as an affiliated tax filer. Because the Company is collecting income taxes in rates
based on a "stand alone" basis, the Company s customers should not be charged for MEHC's
expense for tax compliance activities.
ACIFICORP AUDIT REPORT
Attachment A
Case No. PAC-06-
Staff Comments
11/03/06 Page 8 of 9
OCTOBER 2006
OTHER ISSUES
During Staffs audit, the following matters were observed, however, further investigation
into theses matters did not result in an adjustment to the revenue requirement for the purpose of
this case:
The coal pile at the Jim Bridger Power Plant was shrinking to a coal reserve that was
less that normally maintained. The Company has reversed the shrinking trend and is
building up the pile to more normal reserves. Impacts if any from this building up of
the coal reserve on the Net Power Costs will be evaluated in the next rate case.
MEHC appears to be on an aggressive program to reduce the number of employees
working for the Company. The Results of Operations do not reflect any indication of
how the work force reduction will eventually impact employee expenses. Staff
anticipates the Company will reduce the total employee costs and benefits expenses.
The ultimate impact on the revenue requirement will be determined in the next rate
case.
MEHC is under an obligation to reduce the Company s O&M Expense as part of the
Acquisition Conditions. The initial obligation to reduce these costs are included in
the Results of Operations; however, any other cost reducing activities MEHC initiates
are not included.
Commission Order No. 29998 in the acquisition Case No. P AC-05-8 provided that
customers are entitled to rate credits. These credits are being deferred and any offsets
resulting from the credits granted in that Order will be determined in a future rate
case.
CONCLUSION
In order to determine if the combined revenue requirement increase requested by the
Company in Case Nos. P AC-06-, 08 and 09 was reasonable, Staff compared the request to
what the Company could potentially justify in a general rate case. While Staffs adjustments to
test year Results of Operations in this case were not necessarily exhaustive, they were sufficient
to conclude that the revenue requirement increase proposed by the Company as part of these
three cases is reasonable.
i:jleckie/final draft of audit report-pac 2006
Attachment A
Case No. P AC-06-
Staff Comments
11/03/06 Page 9 of 9
ACIFICORP AUDIT REPORT OCTOBER 2006
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-
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 3RD DAY OF NOVEMBER 2006
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN CASE
NO, PAC-06-, BY MAILING A COpy THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
BRIAN DICKMAN
DEAN BROCKBANK
P ACIFICORP
DBA ROCKY MOUNTAIN POWER
201 S MAIN ST STE 2200
SALT LAKE CITY UT 84111
E-mail: brian.dickman~pacificorp.com
dean, brockbank(illpacificorp, com
ERIC L OLSEN
RACINE OLSON NYE BUDGE & BAILEY
PO BOX 1391
POCATELLO ID 83204-1391
E-mail: elo(illracinelaw.net
DATA REQUEST RESPONSE CENTER
P ACIFICORP
825 NE MULTNOMAH STE 800
PORTLAND OR 97232
E-mail: datarequest(illpacificorp.com
BRAD M PURDY
ATTORNEY AT LAW
2019 N 17TH ST
BOISE ID 83702
E-mail: bmpurdy(illhotmail.com
SECRET AR
CERTIFICATE OF SERVICE