20091105Reply to Staff Report.pdf

BAR CIRCLE '5' WATER CO
PO BOX 1870
HAYDEN ID 83835
2086659200
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iijU~ NO'4 -5 AM to= 23
IDAHO
UT\l\T\ES C
November 5, 2009
Jean D. Jewell, Secreta
Idaho Public Utilties Commission
P.O. Box 83720
Boise, Idaho 83720-0074
Re: CASE NO. BCS-W-09-02
IN THE MATTER OF THE APPLICATION OF BAR CIRCLE "s"
WATER COMPANY FOR AN ORDER AUTHORIZING INCREASES
IN THE COMPANY'S RATES AND CHAGES FOR WATER
SERVICE IN THE STATE OF IDAHO
Dear Ms. Jewell:
Enclosed for filing are an original and seven (7) copies of Applicant's "Reply to the
Report of the Commission Sta'.
Robert N. Turnipseed, President
Bar Circle "s" Water Company Inc.
P.O. Box1870
Hayden, Idaho 83835
TeL. [phone]
Fax [phone]
e-mail avondalecon~verizon.net
Representative for Bar Circle"S" Water Co.
D
2009 NOV -s AM 10: 24
IOAHO piy,;¡ it"
UTIUTIES cò~.lK1¡ŠSION
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )
BAR CIRCLE "S" WATER COMPANY )
FOR AN ORDER AUTHORIZING INCREASES IN)
THE COMPANY'S RATES AND CHARGES FOR)
WATER SERVICE IN THE STATE OF IDAHO )
REPLY TO THE
REPORT OF THE
COMMISSION STAFF
COMES NOW Bar Circle "s" Water Company Inc., ("Bar Circle "S",
"Applicant" or "Company") and hereby files this reply to the report of the Staff
(Staff of the Idaho Public Utilities Commission.
STAFF RATE BASE ADJUSTMENTS
Staff in its report proposes three adjustments to Applicant's rate base filed
in this case. Staff proposes to eliminate; 1) $20,661from Applicants investment
in water mains, 2) $1, 171from the Company's investment in fire hydrant locks
and 3) $44,985 for the proposed installation of automated water meter reading
equipment.
Applicant acæpts Staffs proposed adjustment No. 1 to eliminate $20,661
from water mains and adjustment No.2 to reduæ the Company's investment in
fire hydrant locks by $1,171. Although Applicant actually incurred costs in
exæss of $67,000 to complete the interconnection of the Garwood addition, well
Reply to Staff Report
BCS- W -09-02
1
and reservoir, the Company is aware that its preliminary estimate of $41 ,000 was
relied upon by the Commission in its determination to approve the acquisition.
Applicant's only defense is that it submitted the original rough estimate to the
Commission without the appropriate engineering specifications required to fully
estimate the real costs of completing the project.
Applicant opposes Staffs adjustment to eliminate from rate base
$44,985.00 for the new investment in automated meter reading equipment. Staff
incorrectly reported that "The Company has withdrawn its request to install the
automatic meter reading system at this time." (Report Page 6) Staff referenæd
Applicants response to Staff production request No. 11 part D in support of this
statement. The following is the entire text of that response:
Response to Part D of above request: Completion of the
conversion to electronic meters has been temporarily delayed. One of the
stockholders in Bar Circle "s" Water Company is quite elderly and has
given power of attorney to his sons who are reluctant to commit the
Company to the Commission approved loan neæssary to complete this
project. Negotiations are currently underway among the stockholders to
resolve the issue. The other stockholder is negotiating to possibly acquire
the remainder of the Company Stock. The Company hopes to have the
issue resolved in time to complete the project before the end of the year.
Otherwise the project wil be completed in the spring of 2010. Should the
Commission determine it is unwillng to accept this project for inclusion in
rate base it should also eliminate the proposed loan from the capitol
structure in calculating rate of return.
As indicated in that response, Applicant did not "withdraw its request" but rather
pointed out a problem that was delaying the project. The problem has been
resolved and Applicant is moving forward with the project. The Meters are being
ordered the week of November 1, 2009 Installation wil commenæ as soon as
the meters arrive. Applicant believes it wil be able to complete the project before
winter weather interferes. Should Applicant be unable to complete the project
this fall, it wil complete the project as soon as weather permits in the spring.
Reply to Staff Report
BCS- W -09-02
2
STAFF EXPENSE ADJUSTMENTS
Staff proposes five (5 adjustments to Applicants operating expenses.
Staff proposes to; 1) eliminate $7,950 of Labor costs ($6,000 water master and
$1,950 Administration/bookkeeping), 2) increase pumping power costs by $2,445
to reconize a rate increase from Kootenai Electric Cooperative effective
November 1,2009,3) eliminate $818 of Applicants calculated normalized water
testing expenses, 4) Eliminate $12,628 of Applicants actual recorded
professional expenses and 5) adjust Applicants depreciation expense downward
by $4,316 to recognize Staffs adjustments to Rate Base discussed above.
Applicant acæpts Staff adjustment numbers two (2) and three (3). Staffs
Attachment NO.5 to its report is a work paper prepared by Applicant to show the
effect of the Kootenai Electric Cooperative rate increase. Staffs adjustment to
the Water Testing Expenses correctly adjusts Applicants costs in lieu of the
calculations of the Company using erroneous data.
Applicant objects to Staffs adjustment of $6,000 (part of Adjustment No.
1) for water master labor charges. Staff indicates on page 6 of its report that it
". .. contacted other water master services in the area and found one instance
where a water company only paid $1,300 per month for a water system that
served over 300 hundred customers." (Staff report page 6, emphasis added)
Staff did not indicate who the water master serviæ provider was, the water
system being served nor the level of service provided to this water system.
Water Master Service companies wil provide the minimum serviæ required to
meet Idaho Department of Environmental Quality (DEQ) requirements, maximum
serviæ including total management, operation, maintenanæ, customer biling etc
or something in between. If Staff found only one company that paid only $1,300
per month it must be assumed that the service provided was the bare minimum
required by DEQ. Staff did not indicate whether they had inquired about other
operating and maintenance costs paid by the example company for other
serviæs not contracted for with the water master service company
Reply to Staff Report
BCS- W -09-02
3
Applicant, in its work papers and responses to production requests,
provided Staff with the names of water master serviæ companies the Company
had contacted for comparison water master labor charges at the time the
Application was prepared. Subsequent to reæiving Staffs report, Applicant
confirmed with Staff that the example company cited by Staff was Spirit Lake
East water system who contracts with Water Systems Inc. to provide Water
Master Services. The contract between these two Parties provides for a two
hour service call every two weeks. Any repair and maintenance that cannot be
performed within the contracted 2 hr period is performed at an additional charge
of $45 per hour. The two hour service call includes travel time of about one hour
leaving one hour of service on site at the water system. An additional charge of
$0.65 per mile is charged for travel of approxirTately 25 miles or an additional
charge of approximately $32 per month. The contract also provides for twice per
year blow-off of flush valves and inspection and adjustment of pressure tanks on
a quarterly basis. Enclosed 3 page Exhibit No. 10 provides the details of the
charges by Waterworks.
The water master labor expense for Bar Circle "s" Water Company
includes not only the minimum water master service but all routine operation and
maintenance costs of the company on a daily basis including well and reservoir
inspections, patrollng the service area water mains daily to identify leaks and
damage to the system and making minor repairs to the distribution system as
neæssary. Staffs recommendation would provide compensation of $1 ,000 per
month for total operation and maintenanæ labor costs including water master
service as compared to the one company staff identified that pays as little as
$1,300 per month. Applicant believes that an additional $300 per month in
addition to the minimum $1,300 identified by Staff is quite frugal considering the
additional services and responsibilities.
Applicant also objects to Staffs $1,950 adjustment (remainder of
Adjustment No.1) to bookkeeping serviæ. Staff ties this adjustment to its rate
base adjustment (discussed earlier) for the automated meter reading system and
Reply to Staff Report
BCS- W -09-02
4
states "If the Company were to convert to the automated meter reading system,
the customers would be biled on actual usage every month. This would require
additional bookkeeping services. Those additional serviæs are not now required
with the Company's decision to not do automated meter reading, and the
increase for bookkeeping should not be allowed." (Report page 7) As discussed
earlier the Staff has incorrectly assumed the automated billng system project has
been canælled. Staff also ignores the other services provided in addition to
bookkeeping including bil payments, bank reconciliation, phone answering
service, dispatching, dealing with regulatory agencies or any other general office
management serviæ.
In both adjustments to labor discussed above Staff compares requested
labor costs to actual cost paid in 2008 and indicates the increases are too great.
Staff ignores the fact that these costs have not increased for a number of years
because the water company simply could not afford higher costs. Water master
labor costs have not increased since 2004 and Bookkeeping labor costs have not
increased since 2005. Staff has pointed out that these serviæs are provided by
an affiliated company with common ownership. As pointed out in the original
Application ''The charges include direct labor costs as well as employer provided
taxes and benefits including unemployment insuranæ, FICA taxes, workman's
compensation insurance, health insurance, vacation pay, sick pay, etc. In
addition, Bar Circle "s" owns no utility vehicles. The labor charges paid to
Avondale include all vehicle related operating expenses including fuel,
depreciation, insuranæ, taxes, repairs and maintenanæ." (Application Pg 6)
Simply put, the affiliated company, Avondale Construction, its owners and
employees, have been subsidizing the water company for a number of years.
Applicant opposes Staffs Expense Adjustment NO.4 for Professional
Services. Staff has reduæd the Applicant's professional expenses by $12,628 to
a total allowanæ of $500 annually for the preparation of income taxes only. Staff
stated that "The Company included $11,628 of expenses paid to consultants and
engineers for serviæs provided to the Company that related to the preparation
Reply to Staff Report
BCS- W -09-02
5
and approval of the intertie between the Company's system and the Double T
Subdivision." (Report Page 8) Staff assigns all these costs to approval of the
interconnection and assumes such costs have no benefit to the system as a
whole. Enclosed 2 page Exhibit NO.9 is e-mail correspondence between
Applicant's consultant and Mr. Gary Gaffney of the Idaho Department of
Environmental Quality (DEQ) in Coeur d'Alene. The Commission Staff has ben
copied with this correspondenæ. That correspondence indicates that as early as
2004, the DEQ was conærned about the general capacity of the Bar Circle "s"
system and was requesting a comprehensive water production and demand
monitoring program. DEQ's intent was to have the Company use the data to
model system performanæ using actual data. The correspondenæ from Mr.
Gaffney goes on to say that the addition of the Double T Estates to the system
allowed DEQ to require the hydraulic analysis. Further it indicates that without
Double T Estates the DEQ would have still pushed Applicant to do the study.
Further, the correspondenæ indicates that DEQ intends to have the engineer for
the Company rerun the hydraulic model with new data indicating Applicant wil
continue to incur engineering expense.
Staff has not reviewed the ongoing nature of professional fees Applicant
has realized. The Company incurred professional outside service expenses for
engineering, legal and consulting services (excluding taxes) of $3,400 in 2005,
$1,300 in 2006, $415 in 2007, and in 2009 an additional cost of $4,400 related to
the water system hydraulic modeling project. The Idaho Department of Water
Resouræs has begun an adjudication project for the Rathdrum aquifer and
Applicant expects to incur future legal costs to insure and protect its water rights.
During the course of this case, Applicant has heard the comments and
criticisms of its customers regarding the magnitude of the increase requested
and the burden it imposes upon them especially during the high use summer
months. Ttle Company has had preliminary discussions with its consultant and
intends to look into the possibility of initiating a budget pay plan for the
Commission's consideration to be responsive to our customers conærns.
Reply to Staf Report
BCS- W -09-02
6
Applicant believes an annual professional fees expense allowanæ of at
least $5,000 in addition to the cost of tax preparation is justified as not
unreasonable.
Staffs Adjustment NO.5 is a mechanical proæss. The adjustment is tied
directly to the rate base adjustments discussed earlier.
Staff, in its calculations of revenue requirement properly removed the loan
approved by the Commission in case No. BCS-W-09-01 from the capital
structure to calculate the overall 12% return on rate base the Commission should
approve in this case. However, Staffs approach assumes the loan wil not be
completed sinæ Staff assumes the electronic metering project wil not be
completed. As discussed above, the metering project wil be completed this fall
and the loan wil be required to provide the funds to complete the project.
Restoring the loan to the capital structure produæs a weighted cost of capital or
required return on rate base of 10.59% as requested in the Company's original
application
Staff included $6,667 of rate case expenses amortized over 5 years in its
calculation of the Company's revenue requirement. This amount was based
upon Applicant's estimated costs included with the original Application. That
estimate included actual costs to prepare and file the Application together with an
estimated cost of $1 ,000 to complete the case including responding to production
requests, preparing this reply and filing final Tariffs. Applicant's $1,000 estimate
was understated. Applicant has incurred addition costs of $1,680 to prepare
responses to production request of the Staff, $2,125 to analyze staffs report and
prepare this reply and estimates at least another $255 to prepare and file final
tariffs after the Commission issues its final order in this case. Applicant's total
Rate Case Cost of $9,922 should be amortized over a period of three (3) years
as opposed to the five (5) years proposed by Staff. Applicant intends to be more
dilgent in adjusting rates in response to increasing costs in the future to avoid
subsidizing the water operation and such large increases in the future. We
Reply to Staff Report
BCS- W -09-02
7
believe our customers wil better understand and accept more frequent and
smaller adjustment to their water rates.
Attached Exhibit Number 8 reflects the Rate Base, operating results and
Revenue Requirement Applicant requires based upon the Discussion above
restoring items Staff eliminated and accepting those adjustments Staff proposed
with which the Company agrees. As shown on lines31 and 32 of that exhibit,
Applicant requires an increase in revenues of $70,175 or 104.34%
Respectfully submitted,
,~
President
Reply to Sta Report
BCS- W -09-02
8
Page 1 of3
Avondale Construction
Subject:
"Bob Smith" .:utiltygroup~yahoo.com~
"Bob Turnipseed" .:avondalecon~erizon.net~
Monday, November 02,200910:17 AM
BarCircleSRanch. DoubleTsub.8-4-5.doc; BarCircleSRanchPWS.1 0-27 -5.doc; BarCircleSRanchPWS.1-10-6.doc;
BarCircleSRanchPWS. Double TExtension. 9-23-8.doc; BarCircleSRanchPWS.Double TExtension.12-4-8.doc;
BarCircleSRanchPWS.6-23-5.doc
Fw: Bar Circle S Ranch Water System - Hydraulic Analysi
From:
To:
Sent:Attch:
Robert E. Smith, Utilty Consultant
Cell [phone]
Fax [phone]
----- Forwarded Message ----
From: "Gary .Gaffney(§deq. idaho.gov" -:Gary.Gaffney(§deq.idaho.gov,,
To: utiltygroup(§yahoo.com
Cc: bweymouth(§to-engineers.com; gerry .galinato(§puc.idaho.gov; Joe.Leckieipuc.idaho.gov
Sent: Fri, October 30, 2009 4:48:00 PM
Subjec: Bar Circle S Ranch Water System - Hydraulic Analysi
Bob,
Stang about four to five years ago when the Rach Aero water system was incorporated into the Bar Circle S water
system, we began to have concern about the general capacity of the system. The concern was not based on complaits
about the service as much as it was on the large size of the properties served and the potential for very large irgation
demands. Our first attempt to address ths concern was to require the operator to monitor water production and
consumption in a maner that would provide actu data valuable in predicting system performance. About this same
time a proposal for Double T Estates was submitted which fuer supported the need for a comprehensive look at
performance of the existing system alone and at the system with Double T included.
In 2005 we received information suggesting peak demand at Bar Circle S for water was 2,364 gallons per day (gpd)
which was well in excess of the 1500 gpd peak demand value used in the previous Master Plan prepared for Bar Circle
S. This new inormation increased our concern about possible system limitations and the need for intensified
monitorig of production and consumption of water.
In our Janua 10, 2006 letter we indicated tht "The one remaining compliance item that you did not specifically
address involves a commtment from you to conduct a comprehensive water production and demand monitoring
program during 2006. We asked for this report because the water consumption criterion used by your engineer in the
master plan for ths system may prove to be significantly lower than the actul water consumption data." Once the data
was available from this effort, our plan was to use it have the owner model system performance using actu numbers.
Fast forward to 2008 when a proposal for adding Double T Estates was: submitted along with a hydraulic anlysis of the
system. The analysis was eventually accepted and phase 1 of Double T built.
The Idaho Rules for Public Drinkg Water Systems (Section 503.03.g) allow DEQ to require a hydraulic analysis as
par of the Preliminar Engineering Report required whenever a water system undergoes a modification. We used the
opportunity of Double T Estates to require a hydraulic analysis. With or without the concerns about the existig
system's high demands, Double T would have trggered the analysis. Without Double T Estates, DEQ would have stil
pushed the developer to do the analysis because there were enough undeveloped lots with the system to suggest a
growig demand might create problems. ~híbil.lq ... ..
i~PIY to ,Sttff)
ÐC- w - O'..O~
PIUl- I of ')
Page 2 of3
With instalation of better meters this year and (hopefully) the operator having read the meters frequently durng peak
usge, we wil be receiving much improved water production and consumption data ths Janua. It is our intention is
to have the engineer for Bar Circle S employ the new data in the hydraulic analysis to see if the predictions are changed
from the 2008 analysis.
The bottom line is the hydraulic analysis benefitted both the existing users because we leared if there were any
problems in the existing distrbution system and benefitted the developer by providing Bar Circle S with justification
for allowing the subdivision to connect. In this instace I'd suggest a 50-50 split of the benefits from the analysis.
Gar J. Gafney, P.E.
Idaho DEQ Coeur d'Alene
[phone] or 769-1422
From: Bob Smith (mailto:utiltygroup(§yahoo.com)
sent: Friday, October 30,2009 12:27 PM
To: Gary Gaffney
Subjec:
Gar .
Thans Gary. I put you e-mail address in as all lower case. Here is my original message.
Following up on our phone conversation her is the sitution.
I am sending this also to Ben Weymouth (with Bob Turpseed's permission) at ToothanOrtn Eng for any input he
may have. Ben I would appreciate any comment you may offer also.
I am consulting Bob Turpseed on his Bar Circle "S" Water Company Application with Idaho Public Utilties
Commssion.(Case No. BCS-W-9-02)
1. Bar Circle "S" Water Company was required by DEQ to hire Toothman-Oren Engineering to perform a hydraulic
modeling study of the water system in 2008. The Company Spent over $11,000 to perform the Study.
2. Bar Circle "S" Water Company curently has an application filed with the Idaho Public Utilities Commssion (PUC)
for a rate increase. It has been more than nineteen years since the company increase its rates so the curent application
is quite large.
3. The Staff at the PUC is tag the position that the need for the study was precipitated by Bar Circle "S " desire to
expand its system to serve the new Double T Estates subdivision. Therefore the entire cost of the study should have
been paid by the developer of the new subdivision not by the water company. Their position assumes tht all the
benefits of the study accrue to the developer of the new subdivision and the existing customers of Bar Circle "S" Water
Company do not realize any benefit.
4. PUC Stahas eliminated the cost of the studies from their fInancial analysis and propose to deny recovery of these
costs as an operating expense for the company in determinig rates to be chaged for water service.
5. The Company of course objects to the entire elimnation of these costs and believes there is a benefit to the
management of the company and its existing customers resulting from the studies.
We would appreciate any insight you may have regarding cost!nefit of such a study for a water system.
How often do you believe such a study should be performed.
Any other volunta comments regarding the benefits of such a study
Than you for your attention to ths issue. Unfortately, operating is a quai legal envionment, we are on a strct
legal time line and must submit a reply to the Commssion Staff early next week. Your cooperation and insight is
much appreciated.
Than You,
Bob b~hLbit llq
(~Iy to Stiff)
lbCb ., vJ, O'l ' Oi.
PAße, ;; cf 2J
Bar Circle liS" Water Company
Calculation of Required Revenue
Item
1 Plant in Service Proposed by Staff $
2 Electronic Meter Reading Equipment
4 Corrected Plant in Serviæ
5 Accumulated Depreciation Proposed by Staff $
6 Electronic Meter Reading Equipment
8 Corrected Accumulated Depreciation
9 Net Plant in Serviæ
10 Working Capital
11 Total Rate Base
12 Required Rate of Return
13 Net Operating Income Required
14 Gross Revenue Per Staff
15 Operating Expenses Per Staff $
16 Labor Charges
17 Professional Services
18 Corrected Operating Expenses
19 Depreciation Expense Per Staff
20 Depreciation Expense Meter Reading Equip
22 Corrected Depreciation Expense
23 Net Operating Loss
24 Revenue Increase required to Overcome Loss
25 Incremental PUC Fees ~ .1662%
26 Total Revenue to Overcome Loss
27 Net Operating Income Required
28 Gross-up Factor
29 Revenue Required to Produce Income Required
30 Amortize Rate Case Expenses
31 Total Revenue Increase Required
32 Percent Increase Required
(A)(B)
330,695
45,000
$375,695
131,191
0
131,191
$244,504
10,069
$254,573
10.59%
$ 26,959.23
$67,255
67,098
7,950
5,500
$80,548
15,989
3,000
18,989
$(32,282)
32,282
54
$32,336
26,959
128.09%
34,532
3,308
$70,175
104.34%
Exhibit No. 8
(Reply to Staff
BCS-W-09-02
ATERWOAKS
U,íAT(,A .. +UC\, ~
Fax
To:From:
Bo Smit
1-208-3Í"2-294
Leslie Abms
Fax Pa 3 incuding coer
Ph Date 11/01109
Re . Water Wors, Inc.~ . ,-cc
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. Commets:
Bob,
Following are the anua chages for Spint Lake Eat. The bas anua charges, ending
with the anua subtota of 15,420.80 come out to approx 1285.00 a month. The chages
on page two are for the requied reporting for the IDEQ, we provide these as optional to
our systems, some choose to do it themselves some have us do it. The thgs that I chose
to include in a monthy charge to SLEWCo, as opposed to charging for them hourly or by
the job, were costs that we know ar fairly stagnant. There are some other thgs th we
chage hourly on tht ar requied only in cert years or ca var gratly pe system,
such as the Santa Surey, lead and copper testing, other requied sapling, valve
exercising, meter readg, biling and receivig, etc. Most of the time afer the fi year
most of operation these varable items can be built into the anua cost estiate and paid
monthy because we have a "test year" to set their individual rates frm. The pnce I
quoted to the PUC included the items on page one only and are only pnces for our system
of just over 300 hook ups. Let me know if you need any clarfication on anytg!
Leslie
P.O. Box 920 Rathdrum ID 83858 .. Phone: [phone] .. Fax: [phone]
E-mail: info€?mywaterworksonline.com
ww.mywterworksonline.com
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Rathrum, il 83858
1.208.687.0802 offce
1.208.687.1583 fax
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Name / Address
Estimate
Date Estimate #
111/200 42
Spit Lae East Watr
P.O. Box 3388
Coeur D Alene ID 83816
Description Qty U/M Rate Total
Responsible charge operaor. 2 hour visit per week includes 104 45.00 4,680.00
travel time.
RT mieage port to port (Spirit Lae Eat) 40 mies 2,080 in 0.65 1,352.00
Backup operator charge monthly. $100 Miniuni up to 100 12 300.00 3,600.00
customers. $50 for each additional 50 customers up to 5OD.
Includes 24 hour on ca support and wi act as RCO when
reuested and scheduled. Quaerly site visit includig
mieae included in cost.
Monthly Bacee Samplig. One sample pe month includes 24 45.00 1,080.00
pung sample, checkig chlorine at well house and at site,
and delivery tie to lab. La fees not included.
RT mieage port to port (Spirt Lae East) 40 mies. To 480 in 0.65 312.00Spirit La.
RT mieage port to port (Coe D Alene) 36 mies. To 432 in 0.65 280.80
Laoratory.
Pressure ta quaerly ai check. 6 hour per quarer 24 45.00 1,080.00
includes trvel time. Consists of drang and aig up al
pressure tas to determne accury of pressure ta
RT nueae port to poral (Spirit Lae Eat) 40 mies 160 in 0.65 104.00
End oflne twice per yea flushig. Require by IDEQ. 2 64 45.00 2,880.00
days 2 men.
RT mieage port to portal (Spit La East) 40 mies 80 in 0.65 52.00
Subtota 15,420.80
Than you for your business.
I Total
Page 1
Exhi\?~r ¡s ID
(Replt tD Stoff)
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Rathdru, ID 83858
1.208.687.0802 offce
1.208.687.1583 fax
info (g mywaterworksonline.com
Name / Address
Spirit La East Watr
P.O. Box 3388
Coeur D Alene ID 83816
Estimate
Date Estimate #
1111200 42
Description Qty UlM Rate Total
Annual Consumer Confidence Report to DEQ. Includes 1 513.40 513.40
prpang, on site posting, on line poting, and customer
notce of report by ma.
Annual sampling plan review and preparation.1 45.00 45.00
Cross Connection Control Progra. Per Customer $5.10.320 5.10 1,632.00
Than you for your business.
$17,611.20 II Total
Page 2
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