20170215Reading Rebuttal.pdf

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BEFORE TIIE
IDAHO PUBLIC UTILMIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
INTERMOUNTAIN GAS COMPANY FOR TIIE
AUTHORITY TO CHANGE ITS RATES AND
CHARGES FORNATI.JRAL GAS SERVICE TO
NATI..IRAL GAS CUSTOMERS IN TIIE STATE
OF IDAHO
CASE NO. INT.G-16.02)
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REBUTTAL TESTIMOI\TY OF
DR. DON READING
ON BEIIALF OF
AMALGAMATED SUGAR COMPAI\TY LLC
TEBRUARY t5,20t7
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ARE YOU THE SAME DON READING WHO FILED DIRECT TESTIMONY ON
BEHALF OF THE AMALGAMATED SUGAR COMPAI\TY LLC IN THIS DOCKET ON
DECEMBER 16,2016?
Yes, I am.
BEFORE YOU BEGIN YOUR R"EBUTTAL TESTIMOI\IY DO YOU HAVE AII-Y
GENERAL REMARKS REGARDING THIS COMMISSION'S HISTORIC APPROACH
TO COST.OF-SERVICE STT]DIES AI\D TIIE MOVEMENT OF CUSTOMERS
TOWARDS COST.OF-SERVICE BASED RATES?
Yes. This Commission has historically, and appropriately, taken a very conservative approach to
movement of customers toward full cost-of-service rates. This conservative approach is
evidenced by the following passage from an Idaho Power general rate case order. It is important
to note that the Commission has declared, as a general policy, an inherent and healthy skepticism
about cost-of-service study results. It has also been very reluctant to make major sudden changes
in rates based on a single cost-of-service study. Finally, as is apparent from the following
passage, the Commission's view as to what constitutes a "significant" rate change puts both the
Company's proposal, as well as StafPs proposal, in this case in much better historic and real-
world perspective. Here is what the Commission has had to say about cost-of-service studies and
the magnitude of rate changes that ought to be driven by such studies in an Idaho Power general
rate case:
Important interests in rate stability and continuitv preclude adopting the extremely large
shifts in revenues from one class to another that are depicted. In addition, the results of
cost-of-service studies are not so precise that the determination of appropriate revenue
shifts is an exact certainty. Nonetheless, the passage of time since the Commission's last
examination of IPCo's rates has allowed several classes to drift further away from cost-
of-service rates. Recognizing that cost-of-service studies are not precise, we think it
important that cross subsidies among customer classes should be minimized.
Accordingly, as outlined below we take significant steps to move each class closer to its
indicated cost-of-service. The increases shown in Appendix 3 for the small general
service (Schedule 7) and the irrigation service (Schedule 24) should be tempered by
important interests in rate stabilitv and continuitv for these classes. Increases of l50% and
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10.230% respectively in these schedules represent significant moves toward cost-of-
service and send an important price signal to customers making consumption decisions
within these classes.l
a. ARE THERE OTHER INDTCATIONS OF THE COMMISSION'S GRADUALISM Ar\tD
SKEPTICAL POLICIES TOWARD IMPLEMENTATION OF COST.OF.SERVICE STUDIES?
A. Yes in a Washington Water Power (now Avista) general rate case the Commission
articulated and implemented the very same policy:
Important interests in rate stability and continuity preclude adopting the extremely large
double digit shifts in revenues from one class to another that were requested. In addition,
we recognized that the results of cost-of-service studies are not so precise that the
determination of appropriate revenue shifts is an exact certainty. The number of years
between examinations of cost-of-service and revenue allocation issues for the Company
has allowed several classes . . . to drift a considerable distance from full cost-of-service
and requires gradual incremental moves to cost-of-service rates. We approve a two step
move to accomplish the Company's one-third move to full cost-of-service, a20o/o move
the first year reflected in the rates approved by this Order, and an additional 1504 move to
begin one year from the date of this Order.2
It is important to note that even a "one-third move to full cost-of-service" was too extreme for the
Commission. Instead, the Commission rejected the one-third movement toward cost-of-service in
favor of two, much smaller, rate changes equal to a one-fifth (20%) movement toward cost-of-
service followed by a one-seventh (15%) move toward cost-of-service. Of course, those
Commission findings are completely in line with my recommendation in my direct testimony of a
one-fifth movement toward cost-of-service in each subsequent IGC general rate case.
HAVE THE COMMISSION STAFF OR THE COMPAI\IY ADHERED TO THESE
COMMISSION POLICIES IN THIS CASE?
No. I have seen nothing in this case that would warrant a departure from the Commission's
historical ffeatment of cost-of-service study results - both in terms of its skepticism as to the
results and as to its temperance in making "significant" changes to rates in response. I have also
seen nothing in this case that suggests either the Staffor IGC have even considered these cost-of-
service guidelines that have been so well articulated and consistently enforced by the
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I IPUC Docket No. IPC-E-95-5, Order No. 25880 at page 34. Emphasis provided
2 IPUC Docket No. WWP-E-98-l l, Order No. 28097 at page 30.
Reading, (Di-Reb), Amalgamated Sugar
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Commission. Amalgamated is, quite simply, relying on this Commission to adhere to its existing
policies relative to cost-of-service studies. This is especially important because no other party
has even mentioned those policies, let alone articulated any rationale for departure from those
policies. Although those policies are not embedded in a rule or regulation, I believe that
Amalgamated, and customers in general, are welljustified in their reliance on prior Commission
declared policies dealing with very gradual movement toward cost-of-service study results. All
that assumes, of course, that there is a valid cost-of-service study in the first place - which is
simply not the situation in this case regardless of one's view of the Commission's established
policies with regard to implementing rate changes based on cost-of-service studies.
WHOSE DIRECT TESTIMOI\TY WILL YOU BE ADDRESSING IN YOTTR R"EBUTTAL
TESTIMOITY?
The tdaho Commission Staffs' (Staff witnesses Michael Morrison and Bentley Erdwurm. My
Rebuttal Testimony will focus on why it is inappropriate for the Staff to make rate design changes
while at the same time Staffcompletely and unequivocally rejects the company's rate design
study (a.k.a. its cost-of-service study or'COS"). This inconsistency leads me to the conclusion
that the rate design for the transportation customers proposed by the Commission Staff is not
founded on sound rate making principles. It is simply not reasonable to make rate design changes
without at [east some certainty that those changes are supported by a valid cost-of- service study.
Rather than shooting in the dark, my recommendation to the Commission is that, whatever
revenue increase is granted Intermountain Gas (lGC, Company) that it be spread on an equal
percentage on the individual customers' bills. Significant changes to rate design should only be
implemented only after a valid, acceptable, cost-of-service (COS) is completed. This is
especially critical because of the thirty-plus years of commodity-usage-only rates; thirty-plus
years of no demand charge; and thirty plus years without a cost-of-service study.
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IN YOUR DIRECT TESTIMOI\IY DIDN'T YOU RECOMMEND THAT IT'THE
COMMISSION WERE TO ADOPT IGC'S COST-OF'.SERVICE STUDY THAT
DEMAI\D CHARGES SHOULD BE PHASED IN OVER THE COMPAIIY'S NEXT FTVE
GENERAL RATE CASES?
Yes. I am generally comfortable with and often supportive of some levelof demand charge as
part of an appropriate rate design. A critical caveat, and as I stated in my direct testimony, is that
my recommendation assumed the Company's COS sfudy was 'accurate'.3 That recommendation
changes now that I have reviewed Staff s thorough and thoughtful testimony regarding IGC's
cost-of-service study. I agree with Staff that, in its present form, the Company's COS should not
be used as the basis of determining an acceptable rate design. That, of course includes both the
proposed allocation among the customer classes, as well as the level of a demand charge. I will
review my recommendations, including the five rate case phase in for a demand charge, based on
the criteria discussed in my direct testimony - after an acceptable cost-of-service study is
prepared and adopted by the Commission.
WHAT IS THE TRANSPORTATION RATE STAFF RECOMMENDED IN ITS DIRECT
TESTIMOITY?
Despite its reasoned rejection of the Company's cost-of-service study, Staff still supports the
imposition of a demand charge. This is a dramatic change after more than thirty years of
commodity-only charges. Staffdoes recommend reducing the Company's proposed demand
charge for Transportation customers by only 28o/o, evan though it rejects the cost-of-service study
upon which that charge is based. IGC recommends that Transportation customer classes T-4 and
T-5 be consolidated and the imposition of a demand charge, based on the Minimum Daily Firm
Quantity (MDFQ), of $0.27923 per therm.4 Staffrecommends a reduction to the MDFQ based
3 Direct Testimony D. Reading, Amalgamated, p. 6, lines 6-7
a Application, Rate Schedule T-4.
Reading, (Di-Reb), Amalgamated Sugar
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1 demand charge to $0.20 per therm without the benefit of a valid cost of service studys.
WHAT DID STAFF USE AS A BASIS FOR ITS RECOMMENDATION OF $0.20 Pf,R
THER}I OF NOMINATED MDFQ FOR TITE DEMAND PORTION OF THE T.4 RATE
DESIGN?
Staff witness Erdwurm stated:
Introducing a demand charge into the Company's large volume and transportation rates
recognizes that the Company's costs to serve these customers are driven in large part by
the maximum demands they place on the system. At this time, the Company has not
supported the amount of its proposed MDFQ charge with a cost-of-service study.
Consequently, Staffrecommends that the amount of the MDFQ charges be addressed at
the aforementioned workshop proposed by Staff.6
Therefore, Staffsimply accepts the introduction of a demand charge for transportation customers,
even though it rejects the use of IGC's cost-of-service study as a basis for determining the level
of what that demand charge should be.
IF THE COMMISSION STAFF AFFIRMATMLY REJECTS IGC's COST-OF-
SERVTCE STUDY TO DETER]VTTNE THE MDFQ RATE, WHAT COULD FORM THE
BASIS OF ITS RECOMMANDATION?
The level of the MDFQ demand rate per therm is admittedly not based on any cost-of-service
justification. I can only conclude, therefore, that it is arbitrary. Staff witness Erdwurm justifies
this recommendation only by observing that his proposed rate is lower than that proposed by the
Company:
The recommendation to reduce the charge is based on the impact on specific customers.
Introducing a demand charge will shift costs from higher load factor customers to lower load
factor customers. Staffbelieves this is appropriate, and that lower load factor customers
should pay more, because they are more costly to serve (other things being constant).
s Direct Testimony B. Erdwurm, IPUC Stafl p. 19, lines 9-l l.
6 Direct Testimony B. Erdwurm,IPUC Stafl pgs. 18, 19, lines l8-2.
Reading, (Di-Reb), Amalgamated Sugar
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However, Staff supports a more gradual phase-in of demand charges than proposed by the
Company.T
Therefore, the goal of Staffs proposed rate design is to moderate the impact of the Company's
proposed rate design on 'specific customers' by proposing a lower demand charge than that
offered by IGC. However, if the starting point, (the Company's demand charge proposal) is
based on afatally flawed cost-of-service study, it seems illogical and arbitrary to use that same
starting point to set rates at all - even if the goal is to moderate the effect.
DO YOU BELIEVE STAFF WAS ABLE TO ACCOMPLISH ITS GOAL OF
MODERATING THE RATE IMPACT OF THE COMPANY'S DEMAND CHARGE
PROPOSAL?
No. It is certainly not true for Amalgamated Sugar. It is hard to make an exact apples to apples
comparison because Staff s rates are based on its proposed lower revenue requirement, however
as pointed out in my Direct Testimony, IGC's proposal would result in a72.2%o rate increase for
Amalgamated's three plants based on the original nomination of MDFQ and a 48.5%o increase
based on updated MDFQ. Based on the updated MDFQ and StafPs lower recommended revenue
requirement, Staffls rate design would still mean an unacceptable 68.2%o rate increase for
Amalgamated. Mr. Erdwurm points out in his Direct Testimony that T-4 transportation
customers' percentage changes in rates, based on the Company's original proposal would range
from a decrease of 56%o to an increase of 190%.8 I do not have monthly therm data for all T-4
customers and therefore cannot calculate StafPs rate design recommendations in order to judge
the moderating impact StafPs proposal would have on individual customers in the class.
Nevertheless, just looking at a very small moderating impact on the rate shock concerns I have
for Amalgamated it would be safe to assume there would still be a wildly disparate rate impacts
(both plus and minus rate changes) among customers in the T-4 class.
7 Direct Testimony B. Erdwurm, IPUC Staff, p.19, lines l8-20.
8 Direct Testimony B. Erdwurm, IPUC Staff, pgs. 20, 21, lines 25-3
Reading, (Di-Reb), Amalgamated Sugar
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WHAT IS THE CAUSE OF THESE WILDLY DISPARATE RATE IMPACTS AMONG
IGC'S CUSTOMERS IN THE T-4 CLASS WITH THE INTRODUCTION OF DEMAi\D
CHAI\GES BASED ON MDTQ?
As pointed out in StafPs testimony, an individual customer's load factor plays a major role the
percentage change in rates with the introduction of a full, as determined by the Company, COS
demand charge. I do not have load factors for all of IGC's T-4 customers; however a proxy for a
T-4 customers' Ioad factor can be developed by dividing the annual therm consumption by the
total customers' nominated MDFQ. The chart below depicts this load factor proxy on the left axis
plotted against the percentage rate change on the right axis as proposed by the Company for the
T-4 customer class for 2016 as provided by IGC in a Production Request Response.e The chart
also identifies the three Amalgamated Sugar plants (Nampa, Paul, Twin Falls).
tGC T4 Customers 2016: Therms/MDFQ (teft Axis) and Percentage
lncrease in Proposed Rates (Right Axis)
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change Line
As the chart clearly indicates most (84%) T-4 customers that have the highest load factors would
receive a rate decrease, while the other 16%T-4 customers with the lowest load factors would
9 Response to IPUC Staff Production Request #199
Reading, (Di-Reb), Amalgamated Sugar
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experience rate increases, with just four or five customers exceedin g a l00Yo increase, including
Amalgamated's Paul facility.
WITH THE LARGE PERCENTAGE INCREASE FOR AMALGAMATED'S THREE
PLAIITS RELATM TO THE MAJORITY OF OTHER T-4 CUSTOMRS, CAN ONE
DEDUCE TJNDER THE COMPAIIY'S PROPOSAL, THAT THEY ARE BEING ASKED
TO CONTRIBUTE A SIGNIFICANT SHARE OF THE CLASS RATE INCREASE?
Yes, and then some. As originally filed by IGC, the T-4 class as a whole is slated to receive a
DECREASE of $1,386,472.10 Amalgamated, on the other hand would see an INCREASE in its
rates of $839,529.11 Keep in mind that rate design is a 'zero sum game.' That is, one customer's
rate decrease is directly funded by its neighbor's rate increase. So, then, Amalgamated is solely
funding the majority of the rate decreases for the bulk of IGC's transmission customers.
TRANSPORTATION CUSTOMERS WERE GryEN A CHANCE TO ADJUST THEIR
NOIYIMATED MDFQ AFTER IGC FILED ITS RATE CASE. WERE THE PROXY
LOAD FACTORS tN THE CHART ABOVE CALCULATED WITH THE ORGINAL
MDFQs OR THE ADJUSTED FACTORS THAT WERE ALLOW BY IGC AFTER
CUSTOMERS CAME TO UNDERSTAND THE IMPACT IT WOULD HAYE ON
RATES?
I do not have individual firms' data for the adjusted MDFQ so the above chart was developed
using the originally filed values. However the Company did provide the values for changes in
MDFQ for the LV-1, T-4, and T5 classes.12 The data shows the MDFQ for the LV-l and T-5
classes were actually adjusted upward by 4.0% and 21.7%o respectively. While the T-4 classes
adjusted MDFQs 252,722 therms lower or down l7.lYo. Amalgamated dropped its MDFQ for the
three plants by 85,000 therms or 17.9%o. An indication of the magnitude of the importance
l0 Direct Testimony Lori Blattner, IGC, Table B-2, p. 17.ll Response to Amalgamated Production Request #4.
12 Email from Mike McGrath, IGC, to Bentley Erdwurm, IPUC Staff, December 24,2016.
Reading, (Di-Reb), Amalgamated Sugar
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Amalgamated is to IGCs system is that for both the original and adjusted MDFQs Amalgamated
comprised 32%o of total revenue for the T-4 class.
STAFF WITNESS ERDWUR]VI DEVELOPED HIS RATE DESIGN PROPOSALS USING
THE REVENUE REQUIREMENT FOR EACH RATE CLASS AS PROPOSED BY
STAFF WITNESS MICHAEL MORRISON. HOW DID DR. MORRISON ASSIGN
STAFF'S RECOMMENDED REVENUE REQUIREMENT AMONG THE VARIOUS
RATE CLASSES?
According to Dr. Morrison, because the Company's cost-of-service study was fatally flawed and
could not be used, he spread Staff s recommended revenue requirement proportionally to each
customer class based on the revenue collected at current rates.
The Company's methodology will not result in a fair allocation of the Company's
revenue requirement among its rate classes and, absent a load study, it is not possible to
develop a suitable alternative revenue allocation methodology. I propose that the
Company, Commission Stafl and the Company's stakeholders hold workshops in order
to develop a suitable load study and cost-of-service methodology. Until a satisfactory
cost-of-service study is completed, I propose that the Company's revenue requirement be
allocated in proportion to the normalized revenue currently being collected from each rate
class.l3
It would take a giant leap of faith to assume the current revenue allocation among customer
classes on IGC's system has any relationship to current cost causation. As stated above, the
current rates have been in place for 31 years and no matter how those allocations were determined
three decades ago, the Company's customer class profile has certainly undergone enoffnous
changes in that time.
COULD YOU PLEASE BRIEFLY DISCUSS SOME OF THOSE 'ENORMOUS'
CHANIGES THAT HAVE OCCI]RRED TO INTERIVIOI]NTAIN GAS OVER THE PAST
31 YEARS?
13 Direct Testimony M. Morrison, IPUC Staff, pgs. 2,3,lines 22-8.
Reading, (Di-Reb), Amalgamated Sugar
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The Company's rate base of approximately $66.4 million as filed in its last rate
proceeding in 1985 has increased to about $237 million, as filed in this proceeding.
Operating costs, excluding Cost of Gas and income taxes, have also increased since the
last rate filing from approximately $26.8 million to approximately $71.7 million, or an
increase of $44.9 million.la
Therefore since IGC's last general rate proceeding back in 1985, the Company's rate base has
more than tripled and it operating costs have increase by 268%.
DO YOU KNOW WIIAT RELATIYE SHIFTS THERE HAVE BEEN AMONG TI{E
VARIOUS CUSTOMER RATE CLASSES ON INTERMOI]NTAIN'S SYSTEM SINCE
THE LAST RATE CASE THAT WOULD IMPACT TI{E RESULTS OF ANY VALII)
COST.OF.SERVICE STUDY?
Only to a certain extent. For example, consider just two consolidated rate classes; the residential
class and the commercial class for the number of customers. There has been a significantly
higher growth rate in the number of residential customers than in the number of commercial
customers. The number of residential customers grew from 85,418 in 1985 to 302,790 in 2015 or
by 254%o, whereas commercial customers increased from 13,3 l0 to 3 1,860 or by a rate about half
as fast at 139%o.ts The slower growth in the number of commercial customers is due, in part, to
the fact that the Company did not have transportation rates in place in 1985. With the
deregulation of interstate pipelines in the 1990s IGC put in place an evolving set of 'T' rates that
were approved by the Commission. As a result, large use customers migrated from the
commercial class to the various transportation classes. The current T-4 rate was approved by the
IPUC in July 1998.t0 It is axiomatic that different customer classes have different load profiles.
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14 Direct Testimony Nicole Kivisto, IGC, p. 2, lines l8-23.
l5 Direct Testimony Scott Madison, IGC, p. I l, Table M.5.
l6 ldaho Public Utilities Commission Order No. 27656, Case No. INT-G-98-2, July 1998.
Reading, (Di-Reb), Amalgamated Sugar
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These different load profiles form the foundation of cost allocation studies and drive the cost
responsibility for each class. Therefore, there is no way to determine what cost responsibility each
customer class might have simply by looking at the current revenue from current rate classes.
IN YOTIR DIRECT TESTIMOI\IY, YOU PROVIDED A BRIEF PROFILE OF
AMALGAMATED SUGAR'S EXTENSIVE OPERATIONS AI{D ITS IMPORTANCE TO
IDAHO'S ECONOMY. HOW DOES AMALGAMATED'S NATIIRAL GAS
CONSUMPTION COMPARE TO OTHER T.4 CUSTOMERS ON IGCS SYSTEM?
The chart below clearly shows Amalgamated is, by far, IGCs largest individual transportation
customer. The thinner lower bars to the right of the Amalgamated three plants' combined bar
include other T-4 customers that have more than one facility in IGC's service territory along with
those single site customers.
IGC T-4 Customer Class Therm Consumption 2015:
Combined Plants
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Ifjust individual locations of T-4 customers are considered the pattern looks much the same with
Amalgamated ranking first, second, and seventh in annual therm consumption.
Reading, (Di-Reb), Amalgamated Sugar
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IGC T-4 Cnstomer Class Therm Consumptiou
201530,000,000
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% 20,000,000
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10,000,000
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T:.1Custorners
Frankly, Amalgamated was ambushed by the Company's filing in this case. By that I mean the
recommendation of fullcost-of-service-based rates (flawed as the COS may be) by IGC and the
proposed imposition of demand charges after paying only commodity charges for well over thirty
years. As I explained in my direct testimony, customers must have adequate time (years) and
advance notice (years) to adjust to such dramatic rate structure changes, especially those as
dramatic as filed by IGC in this case. The Commission Staffhas recommended rate design
workshops with the Company and interested parties. Amalgamated plans to fully participate in
those workshops. In conjunction with those workshops Amalgamated plans to explore a range of
alternative rate designs that might include seasonal rates, ratchet rates, establishing a new
customer class for the largest transportation customers or have special contracts that would better
accommodate the utility and the customers' load profile, along with other, yet to be defined,
possible approaches.
WHAT ARE YOUR RECOMMENDATIONS TO THE COMMISSION?
My recommendations are, once the Commission determines the revenue requirement for
Intermountain Gas that it be spread on an equal percentage on each customer's individual bills
and that any significant rate design changes are made only after the Company prepares a cost-of-
Reading, (Di-Reb), Amalgamated Sugar 72
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1 service (COS) that is acceptable, reasonable and approved by the IPUC
2 Q, DOES TIIIS EI\[D YOLIRTESTIMOI\IY AS OF FEBRUARY 15,2016?
3 A. Yes
Reading, (Di-Reb), Amalgamated Sugar
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CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 1Sft day of February, 2Ol7 , a true and correct
copy of this Rebuttal Testimony of Dr. Don Reading on behalf of the
AMALGAMATED SUGAR COMPANY, LLC to be served on the following both
electronically and via U.S. Mail, First Class, Postage Prepaid (unless otherwise
indicated).
Diane Hainan, Secretary
(Hand Delivery)
Idaho hrblic Utilities Commission
472 W Washington Street
Boise, ID 83702
Michael C. Creamer
Givens Pursley LLP
[e-mail]
Electronic Copies Only
Ron Williams
Williams Bradbury PC
1015 W Hays
Boise ID 83702
ron@williamsbradbury. com
Brad Purdy
CAPAI
2Ol9 N 17th Street
Boise ID 83702
[e-mail]
Chad Stokes
Cable Huston LLP
1001 SW Fifth Ave, Suite 2OOO
Portland, OR 972O4-L136
c stoke s@cablehuston. com
Karl Klein
IPUC
472 W Washington
Boise, ID 83702
Karl. klein@puc. idaho. sov
Benjamin J. Otto
Idaho Conservation League
710 N 6ft Street
Boise, ID 83702
botto@idahoconservation. org
Mike McGrath
Intermountain Gas Company
PO Box 7608
Boise ID 837OT
mike. mcsrath@intqas. com
Edward Finklea
Northwest Industrial Gas Users
545 Grandview Drive
Ashland, OR 97520
[e-mail]
Tommy Brooks
Cable Huston LLP
1001 SW Fifth Ave, Suite 2OO0
Portland, OR 97204-1136
tbrook@cablehuston. com
Sean Costello
IPUC
472 W Washington
Boise, ID 83702
sean. co stello(Epuc. idaho. qov
Ken Miller
Snake River Alliance
223 N 6th St, Suite 317
Boise, ID 83702
kmiller@.snakeriveralliance. org
Andrew J. Unsicker
Lanny L. Zieman
Natalie A. Cepak
Thomas A. Jernigan
Ebony M. Payton
AFLOA/JA-ULFSC
139 Barnes Dr, Suite 1
Tlndall AFB, FL 32403
Andrew. unsicker@us. af. mil
Lanny ziernan(dts.af.mil
Natalie. cepak@us. af. mil
Thomas. i ernisan@us. af. mil
Ebonv. payton@us. af. mil
Dated, this 15u, day of February
Kandi Walters, Administrative Assistant
Richardson Adams, PLLC