20110527Crane Di.pdf

RECEIVED
2011 HAY 27 AM II: 01
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE )
APPLICATION OF ROCKY )
MOUNTAIN POWER FOR )
APPROVAL OF CHAGES TO ITS )
ELECTRIC SERVICE SCHEDULES )
AND A PRICE INCREASE OF $32.7 )
MILLION, OR APPROXIMATELY )15.0 PERCENT )
CASE NO. PAC-E-l1-12
Direct Testimony of Cindy A. Crane
Redacted
ROCKY MOUNTAIN POWER
CASE NO. PAC-E-l1-12
May 2011
1 Q.Please state your name, business address and present position with
2 PacifiCorp ("Company").
3 A.My name is Cindy A. Crane. My business address is 1407 West North Temple,
4 Suite 310, Salt Lake City, Utah 84116. My position is Vice President, Interwest
5 Mining Company and Fuel Resources for PacifiCorp Energy.
6 Qualifications
7 Q.Briefly describe your business experience.
8 A.I joined PacifiCorp in 1990 and have held positions of increasing responsibility,
9 including Director of Business Systems Integration, Managing Director of
10 Business Planing and Strategic Analysis and Vice President of Strategy and
11 Division Services. My responsibilities have included the management and
12 development ofPacifiCorp's 1O-year business plan, assessing individual business
13 strategies for PacifiCorp Energy, managing the constrction of the Company's
14 Wyoming wind plants and assessing the feasibility of a nuclear power plant. In
15 March 2009, I was appointed to my present position as Vice President of
16 Interwest Mining Company and Fuel Resources. In my position I am responsible
17 for the operations of Energy West Mining Company and Bridger Coal Company
18 as well as overall coal supply acquisition and fuel management for PacifiCorp's
19 coal plants.
20 Purpose and Summary
21 Q.What is the purpose of your testimony?
22 A.I explain the Company's overall approach to providing the coal supply for the
23 Company's coal plants.
REDACTED
Crane, Di - 1
Rocky Mountain Power
1 Q.Please summarize your testimony.
2 A.My testimony:
3 . Explains the coal cost increases reflected in the 2011 Idaho general rate
4 case and describes the primary reasons for the increases;
5 . Provides background on the third-par coal contract revisions that are
6 drving the majority of the increase in coal costs in this case;
7 . Reviews the Company's affliate mine coal costs and compares them to
8 other supply alternatives; and
9 . Reviews the Company's fuel stock levels incorporated in this test period.
10 Overview of the coal supplies for the Company's coal plants
11 Q.How does the Company plan to meet fuel supplies for its coal plants in 2011 ?
12 A.The Company employs a diversified coal supply strategy. For 2011, the Company
13 wil meet approximately 70 percent of its fuel requirements from third-par
14 multi-year contracts and 30 percent with coal from the Company's affiiate mines.
15 Q.What percentage of the Company's third-party coal contracts are fixed and
16 what percentage are indexed?
17 A.In 2011, approximately 50 percent of the Company's third-part coal supply
18 contracts wil be priced under fixed-price contracts and 50 percent wil be priced
19 under contracts that escalate or de-escalate based on changes to producer and
20 consumer price indices.
21 Q.Please identify the Company's affliate mines.
22 A.Coal production from the Company's Bridger mine is dedicated to the Jim
23 Bridger power plant. The Deer Creek mine supplies a portion of the coal
REDACTED
Crane, Di - 2
Rocky Mountain Power
1 requirements for the Hunter and Huntington power plants and the Trapper mine is
2 dedicated to the Craig power plant.
3 Coal cost increases in 2011 Idaho General Rate Case
4 Q.
5
6 A.
7
8
9
10
11 Q.
12 A.
13
14 Q.
15
16 A.
17
18
19 Q.
20 A.
21
22
23
Are coal costs in the 2011 Idaho General Rate Case above 2010 general rate
case levels?
Yes. Test period coal costs have increased from approximately $685.3 millon in
the 2010 rate case, to $697.6 milion, an increase of $12.3 millon. The increase
related to higher coal prices is approximately $62.3 milion; however, this
increase is parially offset due to reduced coal-fired generation, which reduces
2011 costs by approximately $50 milion.
Have average coal costs increased in this test period?
Yes. Average test period coal costs have increased from $27.88 per ton in 2010 to
$30.51 per ton in the 2011 test period, an increase of $2.62 per ton.
What are the primary drivers of the $62.3 milion increase in coal prices in
this case?
Approximately $9.2 millon of the price related increase is associated with the
affiiate mines; the remainder of the price related increase, approximately $53
milion, is associated with third part coal purchases and transporttion costs.
Please explain the increase associated with the affliate mies.
The increase is associated with higher operating costs at Bridge and Trapper
mines. Bridger mine costs have increased from _ per ton to _ per ton,
an increase of _ per ton primarily due to reduced coal deliveries in 2011.
Trapper mine costs have increased from _ per ton to _ per ton, an
REDACTED
Crane, Di - 3
Rocky Mountain Power
1
2
3 Q.
4 A.
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
increase of _ per ton. The Trapper increase is due to wage escalation and
higher material and supply costs.
Please summarize the major cost increases in third-party coal supplies.
In 2011, the Company wil experience third-par coal supply cost increases at all
of the plants with the exception of the Carbon and Hayden power plants. A
summary of these increases is as follows:
· The majority of Hunter and a portion of Huntington's fuel requirements
are supplied by the Sufco mine under the Company's long-term coal
supply agreement with Arch Coal Sales. Approximately of
the overall test period coal price increase is associated with an increase in
the Sufco coal price pursuant to the 2011 contract price re-opener.
. A portion of Hunter and Carbon fuel requirements wil be supplied by the
West Ridge mine under a new coal supply agreement. The overall impact
on test period results is approximately
· The Company wil experience an increase of approximately
in the delivered cost of Black Butte coal to the Jim Bridger power plant
due to higher coal costs and higher Union Pacific rail rates.
. The Naughton power plant is supplied under a long-term coal supply
agreement with Chevron Mining's Kemmerer mine. The contract price
was reset effective July 2010 pursuant to a price re-opener provision. The
overall impact on test period results is approximately
. The Company wil experience an increase of approximately
in Dave Johnston power plant costs as a result of fixed price increases
REDACTED
Crane, Di - 4
Rocky Mountain Power
1
2
3
4
5
6
7
8
under the three multi-year coal supply agreements and higher rail rates.
· The Company wil experience an increase of approximately
in Cholla power plant costs. The increase in curent test period costs relate
to the increased price of coal from Lee RanchÆl Segudo due to
escalation of contract specific producer and consumer price increases
under the coal supply agreement with Peabody and higher rail rates under
the long-term rail agreement with the Burlington Nortern Santa Fe.
· The Company wil experience an increase of approximately
9 in Colstrp power plant costs as a result of increased operating costs under
10 the long-term coal supply agreement with Westmoreland's Rosebud mine.
11 Coal cost increases related to contract price-reopeners
12 Q
13
14 A.
15
16
17
18
19
20
21 Q.
22 A.
23
Does the Arch Coal Sales (Arch) agreement for Sufco mine coal contain a
2011 price re-opener?
Yes, the Company's long-term coal supply agreement with Arch for Sufco allows
the Company to extend the contract term though 2020 and contains several price
re-openers. In June 2010, the Company exercised its right to extend the Sufco
agreement for five years, 2011 through 2015. The contract provided for a price
reset effective January 1, 2011. Pusuant to the contract terms, the Company and
Arch exchanged prevailing market estimates in June 2010. Despite ongoing
discussions, the parties were unable to reach an agreement.
What is the status of the price reset?
Because the Company and Arch were unable to agree on pricing, quantity and
quality of coal to be delivered durng the 2011 - 2015 extension period, the
REDACTED
Crane, Di - 5
Rocky Mountain Power
1
2
3
4
5 Q.
6 A.
7
8
9
10
11
12
13
14
15
16 Q.
17
18 A.
19
20
21
22
23
Company filed a lawsuit in November 2010 against Arch Coal Inc., Arch Coal
Sales Co. and Canyon Fuels Company. Negotiations are ongoing as both
companies attempt to reach a comprehensive settlement that addresses the 2011
price reopener, coal quality specifications, coal volumes, and nominations.
Please explain what price is included in the 2011 test period.
The Company utilized the pricing methodology proposed in the contract to
estimate the 2011 Sufco coal price. However, one of the pricing components, the
_ index, has changed since the execution of long-term coal supply
agreement. Because the Company and Arch have different interpretations of the
curent _ index; the test period reflects the mid-point of the Company's
and Arch's estimate for the _ index. The test period Tier 1 coal price of
_ per ton represents a _ per ton increase over the 2010 price of_
per ton. Hunter and Huntington power plant coal costs are approximately"
millon higher in the curent test period as a result of increased pricing under the
Arch coal supply agreement.
Has the Company recently entered into other supply arrangements for Utah
coal?
Yes, in 2010, the Company executed a new coal supply agreement with Utah
American Energy for coal from the West Ridge mine for 2011 though 2014 and
with America West Resources, Inc. for coal from the Horizon mine for 2011
through 2015, with an option to extend the contract an additional seven years
though 2022. The West Ridge mine is the only other longwall operation in Uta
not owned by Arch. West Ridge mine's high ash fusion temperatue mitigates the
REDACTED
Crane, Di - 6
Rocky Mountain Power
1
2
3
4 Q.
5 A.
6
7
8
9
10
11
12 Q.
13
14 A.
15
16
17
18
19
20
21
22
23
low ash fusion characteristics of Sufco coal that can contrbute to boiler slagging.
The Horizon mine, a continuous miner operation, wil partially supply the Carbon
plant's long-term coal needs.
How do these prices compare to current Utah coal prices?
Favorably. The Sufco coal price is a delivered price at the Hunter power plant
whereas other market transactions are normally priced at F.O.B. loadout.
Curently, spot coal is being transacted for approximately. per ton or
equivalent to . per ton at the Hunter power plant. Test period Sufco costs are
approximately. per ton less than curent spot coal prices. Similarly, F.O.B.
mine test period costs for West Ridge coal and Horizon, are _ per ton and
_ per ton, respectively.
Please explain the .. million increase in Black Butte coal and Union
Pacific Railroad costs.
The delivered cost of Black Butte coal to the Jim Bridger power plant has
increased from _ per ton in 2010 to _ per ton in 2011, a rise of_
per ton. The majority of the cost increase is due to inclusion of 377,946 tons of
car-over tonnage in the 2010 general rate case. This carr-over tonnage, priced
at _ per ton F.O.B. mine, was associated with the 2003 Black Butte coal
supply agreement. The 2003 coal supply agreement was extended into the first
quarer of 2010 to allow for the make-up of the carr-over tonnage. Absent this
car-over tonnage, the 2010 test period delivered cost of Black Butte would have
been _ per ton rather than _ per ton. Of the" milion increase, the
inclusion of the carr-over tonnage in the 2010 test period accounts for
REDACTED
Crane, Di-7
Rocky Mountain Power
1
2
3
4
5
6 Q.
7 A.
8
9
10
11 Q.
12 A.
13
14
15
16
17
18
19
20
21
22
23
approximately .. milion of the . millon increase, escalation of rail rates
under a long-term rail agreement with the Union Pacific Railroad accounts for
. milion, and escalation of contract specific producer and consumer price
increases under the curent Black Butte agreement constitute the remainder of the
Increase.
Please explain the" million cost increase under the Naughton contract.
The delivered price of coal from the Kemmerer mine to the Naughton power plant
has increased from _ per ton in the prior test period to _ per ton in
2011. The increase is the result of escalation of contract specific producer and
consumer price increases and the impact of a July 2010 contract price reopener.
Please discuss the Naughton supply arrangements.
Originally, the Company's long-term coal supply agreement with Chevron
Mining's Kemmerer mine extended through 2016 with a market price re-opener
in January 2011. Due to at the Kemmerer Mine, Chevron Mining
requested that the Company consider advancing the market price re-opener date.
In September 2010, the Company and Chevron Mining restrctued the coal
supply arrangement. In exchange for the price commitment from
Chevron Ming, the Company agreed to amend certain terms of the curent coal
supply agreement and enter into a new coal supply agreement for the term of2017
though 2021. The amended terms include advancing the effective date of the new
price from January 2011 to July 2010, establishing contract minimums, and the
inclusion of price resets. The price resets adjust the contract price to Chevron's
actual mining costs, but allowed the Company to avoid the
REDACTED
Crane, Di - 8
Rocky Mountain Power
1
2
3
4 Q.
5
6 A.
7
8
9
10
11
12 Q.
13
14 A.
15
16
17
18
19
20 Q.
21
22 A.
23
. The new coal supply
agreement provides for coal deliveries to the Naughton power plant from January
2017 through December 2021 and pricing based on mine costs.
Please explain the increase in Dave Johnston power plant coal
supply costs.
Dave Johnston's fuel requirements are supplied by three mines: Wyodak,
Rawhide and Dry Fork. Anual fixed price increases under these multi-year coal
supply agreements account for of the cost increase; higher rail rates
account for . Rail rates adjust quarterly based on changes to contract
specific indices per the Company's long-term rail agreement with the Burlington
Northern Santa Fe Railway.
Please explain the increase in Cholla power plant coal supply
costs.
The Company wil experience an increase of approximately _ in Cholla
power plant costs. The increase in curent test period costs relate to the increased
price of coal from Lee RanchÆl Segudo due to escalation of contract specific
producer and consumer price increases under the coal supply agreement with
Peabody, _, and higher rail rates, _, under the long-term rail
agreement with the Burlington Northern Santa Fe.
Please explain the. milion increase in Colstrip power plant coal supply
costs.
The Colstrp plant is supplied under a long-term coal supply agreement with
Westmoreland's Rosebud mine. Test period coal costs are per the approved
REDACTED
Crane, Di - 9
Rocky Mountain Power
1 Anual Operating Plan prepared by Westmoreland and approved by the Colstrp
2 plant owners. On an anual basis, the Colstrip plant owners' review and approve
3 Rosebud's mine plan. Curent test period costs are higher due to increases in labor
4 and supply costs and, increased curent reclamation expense and in-pit inventory
5 levels.
6 Coal costs related to the Company's affilate mines
7 Q.
8 A.
9
10
11
12
13
14
15 Q.
16 A.
17
18
19
20 Q.
21
22 A.
23
Have Deer Creek mine costs increased from 2010?
Deer Creek costs are expected to increase on a per ton basis, from _ in 2010
to _ in 2011, but decrease on an mmbtu basis, from
Increases in material and supply and post-retirement expense are the primar
drvers of the minimal cost increase. The increase in material and supply costs is
associated with the transition of longwall operations from the Blind Canyon seam
to the lower Hiawatha seam starting in December 2010. The reduction on a per
mmbtu basis is due to the higher average heat content in 2011.
Please explain the change in Bridger Coal costs between 2010 and 2011.
Bridger Coal Company costs increase from _ per ton to _ per ton, an
increase of _ per ton largely due to higher underground mining costs.
Underground mine operating costs increased from _ per ton to _ per
ton while surace ope~ating costs increased from _ per ton to _ per ton.
What are the primary drivers for the increase in the underground mine
costs?
The increase in underground costs is due to several factors, including higher
operating costs, reduced mine deliveries and increased manpower associated with
REDACTED
Crane, Di - 10
Rocky Mountain Power
1
2 Q.
3 A.
4
5
6 Q
7 A.
8
9
10
11
12
13
14
15 Q.
16 A.
17
18
19
20
21 Q.
22 A.
23
mine development, conveying and blending costs.
Please explain the mine production changes.
2011 test period underground mine deliveries are approximately 200,000 tons
lower than the 2010 test period. The lower delivery level is the result of two
longwall moves in 2011 versus only one longwall move in 2010.
Please compare Bridger mine costs relative to other supply options.
Bridger mine's average test period costs of _ per ton remain less than any
available market alternative. While Kiewit Mining curently has _ tons of
- uncommitted Black Butte production capacity in 2011, the delivered cost of this
uncommitted tonnage to the Jim Bridger power plant is approximately _
in 2011. Similarly, any Kemmerer coal that becomes available, as part of the
Naughton contract amendment, is over . per ton F.O.B. mine. The
transporttion costs associated with the 125 mile haul to the Bridger power plant
would render Kemmerer coal uneconomic.
How does the Company's Trapper mine compare to other alternatives?
The 2011 Trapper price is _ per ton delivered to the Craig power plant. This
delivered price is considerably less than the Company's other Colorado coal
supply options. The price is over. per ton less than the delivered price under the
Company's long-term coal supply agreement with the Colowyo mie for the
Craig power plant.
Please summarize the benefits of the Company's coal supply strategy.
Customers have significantly benefited from the Company's diversified fueling
strategy with both owned mines and market supply contracts, and the Company
REDACTED
Crane, Di - 11
Rocky Mountain Power
1 has prudently managed its fuel costs to the benefit of its customers. Although the
2 affiliate mine supply represents approximately 30 percent of the plant supply
3 requirements, it accounts for only 15 percent of the overall coal cost increase.
4 Relative to the affliate mines, third-part coal supply costs have increased
5 primarily due to the timing of long-term coal contract reopeners.
6 Test Period Fuel Stock
7 Q.
8
9 A.
10
11
12
13
14 Q.
15 A.
16 Q.
17
18 A.
19
20
21 Q.
22 A.
23
Did the Commission adjust the Company's fuel stock balances in the 2010
General Rate Case?
Yes. The Commission determined that the record at that time did not demonstrate
a reasonable and persuasive explanation for the increase in the fuel stock at
different plant sites and ordered a three-year transition of stockpile increases. The
Commission also invited the Company to come back after it completed its review
of its inventory targets in Utah.
Has the Company completed a review of its inventory targets?
Yes.
As a result, is the Company utiizing the three-year average identified by the
Commission in the 2010 General Rate Case?
No. As a result of the review of inventory targets, test period fuel stock levels
reflect curent inventory targets as documented in the Company's Coal Inventory
Policies and Procedures.
Please explain.
PacifiCorp's updated Coal Inventory Policies and Procedures is included as
Exhibit No. 37. The Company retained Pincock, Allen & Holt (PAR) to analyze
REDACTED
Crane, Di - 12
Rocky Mountain Power
1
2
3
4
5
6 Q.
7
8 A.
9
10
11
12
13
14
15 Q.
16
17
18
19
20
21 Q.
22 A.
23
the coal inventory policies associated with the Utah and Wyoming plants. As
discussed in the document, system and plant inventory tagets are reviewed and
evaluated periodically by the Fuel Resources Departent to determine if the
tagets are adequate to provide an economic supply of fuel to the generating
stations.
Are there any plants whose inventory levels were below target as of
December 2010?
Yes, inventory levels at Huntington, Hunter and the Prep Plant were below taget
at the end of 2010. The extended longwall outage at the Deer Creek mine durg
July 2010 through November 2010 caused the Huntington plant's inventory to fall
below target. Production issues at Arch's Sufco mine in 2010 resulted in a
contract delivery shortfalL. Both Hunter and the Prep Plant inventory levels
declined as Arch curailed Sufco mine deliveries due to poor coal quality and
extended longwall moves.
Are December 2011 test period balances in line with Company targets?
Yes, projected inventory levels in Utah are consistent with Company targets.
Arch's agreement to make-up the Sufco delivery shortfall resulted in the increase
in inventory. Inventory levels at the Cholla and Dave Johnston plants which were
above target as of December 2010 are now projected to be substantially lower as
of December 2011.
Has test period fuel stock increased from December 2010?
Yes. As reflected in Company Witness Mr. Steven R. McDougal's Exhibit No.2,
coal fuel stock balances have increased from $ 1 81.2 milion as of December 2010
REDACTED
Crane, Di - 13
Rocky Mountain Power
1
2 Q.
3 A.
4
5
6 Q.
7 A.
8
9
10
11 Q.
12 A.
13
14
15
16
17
18 Q.
19 A.
to $219.0 millon in December 2011, an increase of$37.8 milion.
Please explain the increase in fuel stock.
The increase in fuel stock can be attibuted to higher inventory levels, $20.3
milion, mostly at the Uta plants, and higher unit costs, $17.5 milion, as shown
in Exhibit No. 38.
Has the average cost per ton in inventory increased?
Yes, the majority of the $17.5 milion of the stockpile unit cost increase is due to
higher average costs for the Utah plants. The increase in average coal costs for the
Utah plants is largely due to the 2011 Sufco contract price reopener and the new
multi-year contracts with West Ridge and Horizon.
Does the Company anticipate reducing plant inventories from current levels?
No. While plant inventory levels wil fluctuate from month to month, the
Company does not anticipate any reduction from curent target ranges that are in
line with policy. In addition to the ever depleting coal reserve base in Utah and
Colorado, the Company faces uncertin labor negotiations with the Deer Creek
mine's represented workforce, which is a significant supply of the Company's
fuel supply for the Uta plants.
Does this conclude your direct testimony?
Yes.
REDACTED
Crane, Di - 14
Rocky Mountain Power
ioii HAY 27
CONFIDENTIA
AM II: 08 Case No. PAC-E-11-12Exhibit No. 37
Witness: Cindy A. Crane
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
ROCKY MOUNTAI POWER
CONFIDENTIAL
Exhibit Accompanying Direct Testimony of Cindy A. Crane
PacifiCorp Coal Inventory Policies and Procedures
May 2011
THIS EXHIBIT IS CONFIDENTIAL
AND IS PROVIDED UNDER
SEPARATE COVER
2911 HAY 27 AM If: 08 Case No. PAC-E-l1-12
Exhibit No. 38
Witness: Cindy A. Crane
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
ROCKY MOUNAI POWER
Exhibit Accompanying Direct Testimony of Cindy A. Crane
Coal Inventory by Plant
May 2011
õ~ 8 tJ
.§ .§ ìí:; ti ~:; ~
o?
~ j 1-~ s
II
~'i:
~
= ~
~ ìíS
~.. _j 6::8v, 8 II
§:~
l'~ B
r' IIg
" ~
~ II€
'"II
~"'1X Õ
t N ~
.s -ts =§ §:00 l Ci
~ .:
~
§ B¡.
~~ II
Q
ooN j
i ~ ê
~ $
CI
Ô
~
I
~u
Rocky Mountain Power
Exhibit No. 38 Page 1 of 1
Case No. PAC-E-11-12
Witness: Cindy A. Crane
Oi:tñt;NONNt=OOOS\C~~oo~~f2(,te~~"'~~oo
¡g~~~~¿::"'t;"'g~ i g~ ~\0 in-f1Nf1OO'..C"lroo"Cf1o't! N"'~£_ N
OO-~~_N~~~8~N~~~oo ~~,i ~oô~~~s~!-lli"'oooo~~tnoO'f1_r-oo;-~~~V7~~;¿~~.q.. ..v..V7 -a~ t;~~
~ f~ ~ t2~;; i'§'r; ~ ~ 00;;~;; ~ ~ ~ci ;g;; ~ t; a~ ~~~~~..~~~~~~~e~
r- oo"'r- ~ trON v)v"'('o\-:"'O'"'~01 '0_ _ \0 ~ M 0\ "" "' ..'"t" ~ Y7 r- - (' ,- 0 :: 0'.. ~.. 00Yl g ~~~iigV7aY7å
~ ~oô -r"
iñ-NNV'~~..~t..~è- 0 lt ~
~S~\o~("
"" ~ ~ 0' gg
t, 00 v" N'" ., r-N:' ff ~ ~ I,
~~~~~~~~~~~~~r.O~~~~~Ms!~~g~
~ t4 ~ ;; ~ ~ (A (A Yl Yl Y7 El El
~~~..i~§~t;~$~..~..~
~ ~õ ~~ ~~~§..~..~ ~..g~;;~El~(At;~~å~u~
""
G~~~~:~~~~~~B
tgo"'in"('"óòr- ~ &; .¿V'..~r- ~M\O"'~~lIM~~g.¿
~~~~~~~£1~;S~gg~~~~'Ó~~g~M~~~~
Yl El V7 El El El El Eo ;; El Y7 El El
$~~~~~~o~~~~~~
80" ~ ~ r- rJ 00 ~ r= M ~~ :; ii Ë"V) ~ó~ :"~~~"'oo" .,¿~..~ El El El El ~ ~ El V7 El &l ~
V' ~ \0 ~
$ oq.. 00 InÓ"' r-" .¿00 If 0 M.. M
~~~;B~gg~~o~,- M ~ _ .., 00 (" -. ("~~~ ~~"v)f;rll ~
00.. "C. \0 M\O t".¿
=8€~~eE€€~=g:
a § .$
:g il u:8i: u
..
~
~£ "Q, " ""£'~bO.gB'.§CI
õ .~ ~ § § .Ëu u::::::.s
íi
" '" ~
~ £ 0
~ c. t i
~ £ ~ ~