20170817Comments.pdf

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BRANDON KARPEN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-03s7
IDAHO BAR NO. 7956
Street Address for Express Mail
472W. WASHINGTON
BOISE, IDAHO 83702-5918
Attomey for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
'i-t nt! ^'iI.. I I I ll i'-'Lr !,
IN THE MATTER OF THE APPLICATION OF )
GROUSE POINT WATER COMPANY, LLC FOR)CASE NO. GPW-W-17-01
AUTHORITY TO INCREASE ITS RATES AND
CHARGES FOR WATER SERVICE IN IDAHO COMMENTS OF THE
COMMISSION STAFF
The Staff of the Idaho Public Utilities Commission comments as follows on Grouse Point
Water Company's Application.
BACKGROUND
On February 22,2017, Grouse Point Water Company,LLc applied to the Commission
for authority to increase its monthly customer charge from $22.00 per month to $113.86 per
month, increase its usage rate for customers using over 8,000 gallons/month from $0.50 per
I ,000 gallons to $5.00 per 1 ,000 gallons, and add a new usage rate of $ I .83 per I ,000 gallons for
all monthly consumption less than or equal to 8,000 gallons. Grouse Point asked for the new
rates to take effect on April 15,20ll .
In its Application, the Company explained that during the2012 through 2015 period, it
has collected, on average, 40o/o of the expenses needed to cover its Operations and Maintenance
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1STAFF COMMENTS AUGUST 77,2017
(O&M) expenses. Furthermore, the Company seeks to recover the costs of significant capital
improvements totaling $119,018 in2009, and $8,423 in 2013.
The Company explained that the 2009 capital improvement projects were associated with
construction of a new well in order to meet new drinking water standards for uranium, and that
the 2013 capital expenses were associated with replacement of a failing well pump.
In the Company's last rate case (GPW-W-02-01), the Commission approved an annual
revenue requirement of $6,702 per year, which included a 12o/o return on an authorized rate base
of $3,453 (Order No. 29402). In the present case, the Company requests that the Commission
approve an annual revenue requirement of $36,997, which would include a l2Yo return on a rate
base of $99,056.
STAFF ANALYSN
Staff determined that construction of the new well was necessary to supply safe drinking
water, and that the costs of constructing the new well were prudently incurred. Staff also
believes that the Company should be allowed to recover operating expenses of a water treatment
system used to remove hydrogen sulfide from water obtained from the new well.
After adjustments, Staff recommends that the Company be authorized to collect an
annual revenue requirement of $28,973. In order to recover this revenue requirement, Staff
recommends a three tier inclining block rate structure consisting of an $82 monthly customer
charge, a $2.50 per 1,000 gallon usage rate for the first 8,000 gallons, a $3.75 per 1,000 gallon
rate for the next 12,000 gallons, and a $5.00 per 1,000 gallon rate for all usage in excess of
20,000 gallons. Staff believes that this structure will discourage excessive usage that could
exceed the capacity of the potable water well.
Staff recommends the following adjustments to the Company's case:
Rather than using the Company's proposed hybrid test yearl, Staff believes that a pro-
forma test year based on 2015 expenses and an I I o/o return on equity is more appropriate.
Staff also made adjustments to the Company's claimed capital expenditures, and reported
expenses, and a noteworthy adjustment to the Company's electrical expenses to reflect a well
pump that is being operated inefficiently.
1 The Company used average O&M expenses and billing determinants for the years 2012 through 2015
2STAFF COMMENTS AUGUST I7,2OI7
System Description and Overview
The Grouse Point Water Company serves 24 residential customers in the Grouse Point
subdivision east of Kuna, Idaho. The Company's water right allows domestic use and irrigation
of up to l/2 acre of land per customer. However, most irrigation water is obtained through the
Homeowners'Association from the nearby New York Canal.
The system includes a potable water well with a l5 HP pump, a fire well with a 75 HP
pump, and a back-up well with a l5 HP pump. The system uses a single 120 gallon bladder tank
to stabilize the system, but otherwise has no storage. The system is equipped with a hydrogen
peroxide injection system that is used to control odors.
Pro-Forma Test Year
The Company proposed a pro-forma Test Year with expenses equal to the four-year
averages of expenses for the Calendar Years Ended (CYE) 2012tfuotgh2015. Based on the
Company's proposed pro-forma test year, the Company estimates its revenue requirement to be
$36,997. Similarly, the Company proposed that Test Year consumption be computed using the
average consumption for the same four calendar years. Average consumption over this time
period was 2,488,000 gallons.
In August 2073, the subdivision's water allotment from the New York Canal was
temporarily curtailed, and residents began irrigating their property using Company water. To
meet this demand, the Company relied on its fire pump, and drew substantial quantities of water
from the uranium contaminated aquifer. Given the Company's four-year average test year, the
effect of this extraordinary event is to overstate average consumption, thereby leading to a rate
calculation that would not allow the Company a fair opportunity to earn its revenue requirement.
As noted earlier, the Company's potable water pump also failed at this time, and the Company
incurred capital costs associated with the new pump.
Staff also notes that the Company incorrectly aggregated operations, maintenance,
administrative, and chemical expenses as "Contract Services-Professional," resulting in the
Company's incorrect classification of a number of capital expenditures as expenses in 2012,
2013, and2014. Staff disaggregated the Company's "Contract Services-Professional" so that
plant in service and expenses could be treated properly.
aJSTAFF COMMENTS AUGUST I7,2OI7
Given missing documentation, extra-ordinary consumption in 2013, and misclassification
of capital expendituresin2012,2013, and2014, Staff believes that a pro-forma test year created
using 2015 as a base year to be a more accurate predictor of costs, revenues, and consumption.
Staff recommends the following pro-forma adjustments to the Company's 2015 base
year:
1. Consumption at one residence was abnormally high in July, August, and September
2015. Staff adjusted consumption to reflect more typical consumption for this residence. The
resulting pro-forma consumption for the Company is 1,945,000 gallons.
2. For the pro-forma test year, Staff determined that the Company would consume 1.676
barrels of hydrogen peroxide. Staff estimates an annual cost of $ 1 , I 03 to operate the hydrogen
peroxide system at current labor and material rates.
3. Power costs for the pro-forma year were computed by applying current Idaho Power
Company Schedule 9 rates to Staff s estimate of the power necessary to deliver 1,945,000
gallons to its customers. Power costs include the demand, Basic Load Capacity, and energy
charges required for periodic (4x per year) fire pump testing and maintenance.
Uranium Contamination, Water Quality, and the New Well
In 2005, the Company learned that uranium levels in water from its potable water and fire
wells exceeded Idaho Department of Environmental Quality (IDEQ) standards for uranium. In
2009, the Company drilled a new, deeper, potable water well into an uncontaminated aquifer.
The new well now serves as the system's primary source of potable water. Subject to IDEQ
oversight, the old potable water and fire wells may be used to provide drinking water in the event
that the primary potable water well requires maintenance.
The cost of the well and pump was $119,018. In 2013, the Company replaced the pump
at a cost of $8,423. The Company erred by not removing the cost of the defective pump from
rate base. Staff removed the cost of the defective pump, included the cost of the replacement
pump, and properly calculated accumulated depreciation, resulting in the inclusion of $74,650 in
rate base for the new well and pump for the 2015 pro-forma test year.
Staff notes that uranium could be removed from drinking water using commercially
available reverse osmosis, distillation, or ion exchange equipment, but that equipment,
4STAFF COMMENTS AUGUST 17,2077
maintenance, and uranium waste disposal could be very costly. Staff believes that the
Company's decision to drill a new well was a prudent decision.
The Commission received comments from l0 different customers who complained of
intermittent hydrogen sulfide odor. One of the customers stated that the odor was so bad that he
and his family temporarily abandoned their home. Several customers indicated that they had
purchased expensive water treatment systems, or that they purchased bottled water, in order to
meet their domestic water needs. Although the odor and taste of hydrogen sulfide can be a
nuisance, the IDEQ does not consider it a health risk in the levels found in the Company's
potable water well.
The Company was aware that the new well would draw water from a zone with elevated
hydrogen sulfide levels, and had planned to treat the water using chlorine. However, customers
complained about the heavy chlorine taste. Staff notes that the preferred method for removing
low levels of hydrogen sulfide is open air storage tanks and aeration that allow the noxious
smelling chemical to escape into the air. Higher hydrogen sulfide levels may be removed using
chlorine; however, chlorine treatment also requires aeration in order to remove excess chlorine,
chloramines, and other treatment byproducts: As noted earlier, the Grouse Point water system
uses no open air storage tanks.
The Company replaced its chlorine injection system with a hydrogen peroxide system.
Staff notes that hydrogen peroxide is not widely used for treatment of hydrogen sulfide in
domestic drinking water systems. However, unlike chlorination, hydrogen peroxide treatment
does not require aeration tanks. Nonetheless, with the exception of intermittent hydrogen sulfide
spikes discussed further in customer comments, hydrogen peroxide treatment has been a
satisfactory, albeit imperfect, solution to the system's odor problems. Staff believes that this
system benefits customers, and that it should be operated and maintained until the Company and
Homeowners Association agree to a better solution. Staff estimates the annual costs of operating
this system to be $1,103, or $213 less than the annual expense computed using the Company's
four-year average test year methodology.
The Fire Well
The Company's system is designed to start the fire pump automatically when system
water pressure drops below 30 psi, such as occurs when a fire hydrant is opened. The fire pump
5STAFF COMMENTS AUGUST 17,2017
produces between 800 and 1,000 gallons per minute, and will thus exceed the Company's
allowable pumping rate any time it is operated. Furthermore, because the fire well draws water
from the uranium contaminated aquifer, use of the fire pump introduces large quantities of
uranium contaminated water into the system. The Company's water right limits its pumpingrate
to a total of 2ll gallons per minute (0.47 cfs) from all of its wells. In normal operation, only the
Company's potable water well is used, and the 15 HP pump in this well is incapable of delivering
more than 150 gallons per minute. An exception to the Company's 2ll gallon per minute
pumping limit occurs when there is a fire. Residents may use all available water to extinguish a
fire, even if this means temporarily exceeding the Company's maximum permitted pumping rate.
It is possible for customer demand to exceed the 150 gpm capacity of the potable water
well, and thus initiate operation of the fire pump, even when no fire emergency exists. This
happened in2013, when the subdivision's allotment from the New York Canal was curtailed, and
homeowners switched to the Company's potable water supply in order to irrigate their property.
Following IDEQ mandate, the Company informed the Homeowners Association that increased
consumption had activated the fire well, and that use of the fire well was introducing uranium
into its drinking water. Analysis of hourly electrical consumption data obtained from Idaho
Power indicates that the fire pump was activated 336 times in2013. However, the fire pump has
only been activated an average of four times per year in subsequent years. Staff notes that the
Company has few options for handling instances of excessive demand, and believes that an
inclining block rate structure will discourage users from using the system in a way that activates
the fire pump.
The Commission received one comment from a customer concerned with the reliability
of the fire protection system. During the investigation, Staff spoke with other customers who
indicated that they had observed fire hydrants failing to produce significant water flow when
opened. Concerns about the fire system's reliability was a significant discussion topic at Stafls
workshop with Grouse Point Customers. During its investigation, Staff learned that although the
Company periodically tests operation of the fire pump, it does not perform any routine tests of
either the fire hydrants or the limit switches designed to activate the fire pump in the event of an
emergency.
6STAFF COMMENTS AUGUST I7,2OI7
The Grouse Point subdivision receives fire protection from the Whitney Fire District.
The Whitney fire district inspects and services2 the Company's fire hydrants, but does not
perform a flow test. Staff contacted the City of Boise, and leamed that the Boise City Fire
Department can provide flow testing for an annual fee of $500.3 Staffrecommends that the
hydrants be tested annually, and includes a $500 annual expense for flow testing in the revenue
requirement. In order to minimize the number of uranium contamination events, Staff
recommends that the Company coordinate its fire pump tests with the flow tests conducted by
the Boise City Fire Department. Staff also recommends that customers be notified in advance of
any flow tests that inject fire well water into the potable drinking water system.
Electrical Power Consumption
The Grouse Point Water Company's plant can be described as a constant pressure system.
In normal operation, only the potable water well and 15 HP pump are used to supply water and
maintain system pressure. Most small water systems rely on reservoirs, storage tanks, and a
system of small booster pumps to maintain pressure when there is no demand for water, so that
the main well pump only runs a few hours per day. The Grouse Point Water Company has no
such system. Rather, the 15 HP well pump runs almost continuously in order to maintain system
pressure, whether or not there is any demand for water. The l5 HP well pump is equipped with a
variable frequency drive that decreases power consumption by approximately 60% when there is
no demand for water; however, Staff estimates that approximately 90o/o of the electrical energy
consumed by the system is used to maintain system pressure when there is little or no demand
for water.
In its Application, the Company states that its power costs have averaged $4,206 over the
period between 2012 and2015. The Company's unit pumping costs are the highest of any
regulated Idaho water utility for which consumption data is available. Over the four-year test
period proposed by the Company, costs have averaged $1.83 per 1,000 gallons of water sold.
For comparison, the company with the next highest unit pumping costs, a company with42
2 Whitney Fire Department service typically includes clearing obstructions at the hydrant (bushes, etc.), taking the
caps off, bringing up the water, and drainback (water flow back into the system).
3 Boise City Fire Department flow test includes service, plus testing the flow rate at the hydrant.
7STAFF COMMENTS AUGUST I7,2OI7
residents, spends $0.64 per 1,000 gallons. Other small Idaho water companies typically spend
between $0.20 and $0.30 per 1,000 gallons.
Staff determined that the Company's large per-gallon pumping costs result from four
primary factors: 1) A system design requiring nearly constant operation of the main pump;
2) The rate structure for purchased electrical power; 3) Demand charges associated with periodic
testing and maintenance of the fire pump; and 4) A system configuration that does not take full
advantage of the energy savings possible with the Company's existing variable frequency drive.
Staff has determined that considerable cost savings are possible with relatively minor
adjustments to the existing system configuration. Figures la and lb illustrate hourly power
consumption for the years2072 and2015, respectively. In20T2, power consumption varied
between 2 and 8 kwh per hour, indicating that the variable frequency drive was reducing pump
motor speed in response to decreased customer demand. By 2015, power consumption was
nearly constant, indicating that the variable frequency drive was no longer responding to
decreased demand.
Staff believes that one or more of the following reasons explain the well pump's high
electricity consumption: The pressure tank may be pressurized incorrectly, there may be a water
leak in the system, or the pump's limit switches may be configured incorrectly.
In its Response to Production Request No. 6, the Company indicated that in 2013, it
replaced its 165 gallon pressure tank with a 120 gallon pressure tank. The Company also
indicated that when the new tank was installed, its empty pressure was 65 psi. Given the pump's
65 psi upper limit, this tank pressure would never allow the tank to be filled. Staff also notes that
the Company has neither inspected the tank, nor measured its pressure since it was installed in
2013 (Response to Production Request No. 9), so it is possible that the tank is empty, and not
actually functioning as intended. In either case, the result would be the same: The pump would
run continuously.
8STAFF COMMENTS AUGUST 77,2017
2OL2 Hou rly Consu mption
L00.oo%
90.oo%
80.00%
70.00%
60.0o%
s0.00%
40.00%
30.00%
20.00%
t0.00%
0.00%
0 1 2 3 4 5 6 7 8 9 1071,t2t3t4t51,617L8t920
KW
Figure la: Histogram of hourly power consumption for Calendar Year 2012.
2015 Hou rly Consu mption
00%
o0%
oo%
o0%
oo%
o0%
00%
00%
00%
00%
00%
0 1 2 3 4 5 6 7 8 9 10LL7213 141516t7t81920
KW
Figure lb: Histogram of hourly power consumption for Calendar Year 2015.
It is also possible that there is a leak in the system. A leak would place a continuous
demand on the system, requiring the pump to operate continuously. During a site visit, Staff
noted that the main valve to the old uranium contaminated well is still open, making it possible
for pressurized water from the potable water well to leak into both the fire well and the old
potable water well. It would also be possible for leaks at the point of use (customer side of the
meter) to cause the pump to run continuously. Unfortunately, the master meter on the new
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100
90
80
70
50
50
40
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0
9STAFF COMMENTS AUGUST 17,2017
potable water well has been inoperable for several years, making it difficult to ascertain either
the existence or provenance of such a leak. Staff recommends that the Commission order the
Company to repair and maintain its master meter.
Pump limit switches are typically configured so that there is a 20 psi difference between a
pump's low and high pressure limits; however, the Company's system is configured with
relatively tight limits of 55 psi and 65 psi. This could cause the pump to run continuously with a
small leak. Staff believes that by reconfiguring limit switches to a more standard configuration,
properly maintaining the existing pressure tank, and adding a second pressure tank, the power
required to meet test year consumption needs would be reduced to $1,960 per year, or an
adjustment of $2,163 as shown on Attachment D. Staff estimates that these improvements can
be made for $ 1,500.
The Company takes power under Idaho Power's Schedule 9 (Large General Service).
Schedule 9 uses a declining block rate structure whereby the Company pays approximately $0.10
per kWh for the first 2,000 kWh of energy, and $0.046 per kWh for each additional kWh. The
Company consumes approximately 4,000 kWh per month, so that nearly half of the energy
consumed by the Company is purchased at the high $0.10 per kWh rate. On average, the
Company pays $0.068 per kWh, or about 40o/o more than the average rate paid by larger water
Companies in Idaho Power's service territory.
The Company also pays a monthly demand charge and Basic Load Capacity (BLC)
charge for all power in excess of 20 kW. Under normal operation, it is not possible for system
demand to exceed 20 kW; however, when the fire pump is operating, system demand may
exceed 80 kW. Staff estimates that the incremental increase in demand and BLC charges due to
fire pump maintenance and testing to be $420 per year.
Staff believes that the Company should be permitted to recover the following power
costs:
Energy and Related Costs:
Fire Pump related Demand and BLC Charges:
Total:
$1,960
420
$2,380
In the Company's last rate case (GPW-W-02-01), Staff was concerned with the
Company's high level of power consumption. In that case, the Commission accepted Staffs
recommendation to adjust the Company's revenue requirement to reflect a nominal $0.50 per
STAFF COMMENTS 10 AUGUST I7,2OI7
1,000 gallons. In the present case, Staff s proposal would effectively increase this to $1.22 per
1,000 gallons.
Financial Information
The Company reported its financial information on a variety of schedules rather than
using Financial Statements as reported to the Idaho Public Utilities Commission in its Annual
Reports. The Company submitted a large amount of documentation in written and electronic
format. Staff appreciates the Company's electronic responses, which minimized handling of
paper documents. Staff determined most supporting documents were reliable. Responding to
Audit Request No. 1, the Company replied that it reported on an accrual basis. Staff believes the
documentation demonstrates the Company reported on a cash basis. Staff also believes that the
Company properly records cash payments and cash receipts.
Accounts Receivable
The Company's responses to Audit Request No. 3 included Schedules of Accounts
ReceivableAgingforDecember3T,2012throudtr20l5. Staffsanalysisrevealedthemajority
of delinquencies were one to 30 days overdue. Staff corrected the reported balances for pre-
payments. Additionally for 2015,16 customers represented94.4o/o of all unpaid balances. With
a total of 24 customers, 16 delinquent customers equals 66.7%% of all customers. Staff believes
this is an extraordinary high delinquency rate. Consequently, Staff performed extended testing
of Accounts Receivable Aging for the period August 31,2012 through 2015 revealing the same
delinquency pattern for the entire period. Staff recognizes the revolving nature of Accounts
Receivable and believes a large portion of customers have a persistent pattern of delinquency
aggravating cash shortages for the Company. Staff recommends the Company pursue more
effective collection procedures. Staff encourages the Company to discuss changes with Staff to
meet the UCRR requirements when establishing enhanced procedures.
Late payment charges encourage timely payment and help the Company recoup some of
the cost of collecting past due bills. The Utility Customer Relations Rules allows a minimum of
fifteen days after the bill is issued (bill date) before payment is due. Although the Company did
not propose implementation of such a charge, Staff supports adoption of a late-payrnent charge
to encourage prompt bill payment. Staff recommends that the Company be allowed to charge
STAFF COMMENTS 11 AUGUST I7,2OI7
lo/o on any past-due balance owed at the time of the next billing statement. This allows a
reasonable grace period for customers to pay their bills before a late charge is imposed.
The Company did not propose a returned payment charge when a customer's check or
electronic payment is not honored by his/her financial institution due to lack of sufficient funds
in an account, a closed account, or some other reason. However, Staff recognizes such a charge
is appropriate to allow the Company to recover its cost from the customers causing the cost to be
incurred. Idaho Code $28-22-105 allows a company to charge up to $20.00 for dishonored
checks, and the Commission has approved such charges for other utilities. Staff recommends
that the Commission approve a $20.00 retumed payment charge.
Results of Operations and Revenue Adjustment
The Results of Operations shows if the Company is operating at a profit or loss. The
reported loss of $13,669 for 2015 is shown on Attachment A. Within the 2015 results, the
Company reports Total System Revenue of $6,438. However, the Revenue Account for 2015
totals $6,732. This difference of $294 is from prepayments and other items. Staff believes that
incurred expenses are included in reported expenses associated with this $294 so the revenues
should also be included. Staff recommends $6,732 be used as the proper revenue amount to
determine the incremental revenue required.
Repairs and Maintenance Expenses
The Company reported Repairs and Maintenance Expenses totaling $1,887. [n regulatory
accounting, repairs differ from maintenance. Maintenance is routine and more predictable.
Repairs are irregular and the amounts vary. To reflect a normal repair expense amount an
average allowance is used. Attachment B shows the Staff calculated allowance in three steps.
First, Staff reclassified the chemical pump from expense (ln. 6) equaling $1,289 to Plant in
Service. The addition to plant in service is included on Attachment F, line 10. Second, Staff
added 4 repair items from 201 3 and 2014 expenditures (lns. 8- I 1 ). Finally, Staff calculated a
three-year average of the rernaining expenses. The repairs allowance recommended by Staff is
$274 (1n.15), resulting in a total adjustment of $1,613.
STAFF COMMENTS t2 AUGUST 17,2017
Administrative Expense
The Company reported Administrative Expenses totaling $1,925 for the CYE 2015. This
total includes accounting expenses, administrative compensation and legal fees. Staff s analysis
of the invoice for Legal services revealed there were six charges for services related to the
Homeowners' Association. The Homeowners' Association provides irrigation water and has no
part in producing potable water. Consequently, Staff removed $715 for Legal Fees as shown in
Attachment C.
Meter Reading and Billing
In2015, meters were read every two months. The Company reported $675 in meter
reading expenses during 2015. The Company requested monthly meter reading in its
Application. Staff believes monthly meter reading will result in more frequent price signals.
Staff increased meter reading costs by $675 reflecting reading meters monthly.
During its investigation, Staff determined that the Company's meter-reading and billing
policy does not wholly conform to the Idaho Public Utility Commission's Utility Customer
Relations Rules (UCRR), IDAPA 31.21.01. The UCRR requires the Company to read meters on
a regular schedule and to base bills on those readings. The Company has stated in response to
Staff Production Request Nos. 33 and 34 that it will read meters the second week of each month
and mail bills within three (3) days of the meter read. Although the Company indicated that it
has not had to estimate bills in the past, it stated that estimated bills would be based on a
customer's usage for the previous three months. Given the possible seasonal variability of usage,
Staff recommends that estimates be based on usage during that same billing period for the
previous year. Per Rule 201.03, UCRR, if usage must be estimated, the customer's billing
statement must be clearly marked as "estimated."
The Company's current billing statement does not comply with rules 201 .03 and 201 . 1 1 ,
UCRR. These rules require that the bill must include the beginning and ending meter readings
and itemize all applicable rates and charges. In addition, the bill must include a contact phone
number for the Company. Staff recommends that the Company make the necessary changes to
its meter reading and billing practices, and revise its new billing statement at the conclusion of
this case. Staff will work with the Company to ensure that its policies meet UCRR requirements.
STAFF COMMENTS l3 AUGUST 77,2017
Water Testing
The Company reported water testing expenses for the CYE 2015 totaling $229. The
Company has a nine-year water testing cycle, with l6 water tests. These tests occur at different
intervals and the charges are not equal. Thus, the amount reported for Water Testing Expenses
during a single year may not be proportional to all charges during the testing cycle. Staff
constructed a chart of water testing charges and calculated the nine-year average. The average
annualized water testing cost equals $471. Staff s adjustment increases Water Testing Expenses
by $242, as shown in Attachment E.
Plant in Service
The Company's Worksheet B-Summary lists three items for Plant in Service, with a Net
Book Value (NBV) at the CYE 2015 totaling $96,930. The three items are: Well installed in
2009, a l5 HP Pump installed in2009 and a 15 HP replacement pump installed in 2013. Staff
tested the Company's schedule of Plant in Service and the related depreciation. Staff found two
exceptions. First, the Company did not include Customer Meters, as shown in Commission
Order No. 29402, dated December 19, 2003. Second, the Company did not retire the plant and
continued to depreciate the 15 HP pump installed in 2009 and replaced in 2013. This pump
should have been retired as it fails the "used and useful" test. As shown on Attachment F (ln 7),
Staff removed the original pump, added the meters (ln. 5) and corrected the accumulated
depreciation. Finally, Staff added (lns. 9-11 of Attachment F) the reclassified Capital
Expenditures found during the audit of Repairs Expense and Professional Fees Expense for the
CYE2012 through 2015. The Net Book Value, as corrected, totals $85,907 resulting in a
difference of $ I 1,023 as shown on Attachment F, line I 3. The corrected depreciation expense to
reflect the Staff recommended plant in service is $3,572 resulting in an adjustment of $1,027 as
shown on Attachment G.
Amortization of Rate Case Expenses
Details of Company requested Rate Case Expenses are shown on Company Worksheet C,
totaling 525,944. The Company requested a seven-year amortization equaling $3,706 annually.
Staff analysis revealed three items. First, the Rate Case Expenses for the CYE 2015 were routine
accounting expenses not rate case expenses. Second, the Rate Case Expenses for the CYE 2017,
STAFF COMMENTS 14 AUGUST I7,2OT7
totaling $17,000, were estimated, and not actual, and thus, could not be documented. Third, with
a2015 test year, alarge portion of the Rate Case Expenses are for labor and documentation for
years not used. Staff notes, Spirit Lake East, with about 300 customers, was authorized a five-
year amortizationperiod with annual Amortization of Rate Case Expenses equaling $800. Staff
believes $800 annually is reasonable and more accurate for this case, This results in an
adjustment of $2,906, as shown on Attachment H.
Revenue Requirement
Grouse Point Water Company, LLC, reported a Rate Base, on Exhibit 1, Schedule C,
totaling $99,056. Staff calculated a Rate Base totaling $87 ,77 5. The difference equals $ 1 1,281
as seen on Attachment I.
The Company requested a 12.0%o Rate of Return. Staff recommends an 1 1.0% Rate of
Return. An llo/o return on equity reflects current market conditions and is consistent with the
return authorized in Order No. 33658 for Morning View Water. This return on equity is the
same as the overall rate of return since there is no authorized Company debt.
The Company reported a loss for the CYE 2015 so, the Company reported no lncome
Tax Expenses. However, Staff s Revenue Requirement for the CYE 2015 includes a taxable
Retum on Rate Base. Staff grossed the return up to reflect Income Tax Expenses.
The Staff recommended Revenue Requirement is $28,973 as shown on Attachment J.
Attachment K reconciles the Revenue Requirement requested by the Company and the
Revenue Requirement calculated by Staff. This schedule, beginning with account balances for
CYE 2015, shows the Staff adjustments and ends with the 928,973 Staff recommended Revenue
Requirement.
RATE DESIGN
Staff believes that the Company's current rate design fails to provide an adequate
incentive to limit water use to a level consistent with the capacity of the Company's potable
water well. To provide an incentive to reduce water consumption - especially in the warrner
months of the year - Staff recommends modifying the current inclining block rate design to
collect a larger percentage of revenue based on the volume of water used. Under an inclining
block rate structure, usage rates per gallon increase as usage increases.
STAFF COMMENTS l5 AUGUST I7,2OI7
Existing and Company-proposed rates are illustrated in the following table:
Table 1: Company's Current and Proposed Rates
The Company's proposed rate design recognizes the need for higher usage-based charges.
Based on adjusted test-year usage, the Company-proposed rate recovers 87oh of revenue through
the customer charge, with l3o/o (8% l't ier; 5oh 2'd tier) of revenue through usage charges.
Under current rates, less thartT%o of revenue was collected on the basis of water usage
during 2015. Of the 288 monthlybills prepared in2015,270 bills (73%) include no usage-based
charges; the monthly usage for these 210 bills is less than or equal to the 8,000 gallons provided
free of charge. For the remaining 78 bills, usage in excess of 8,000 gallons per month is priced
at the current 2ndtier usage rate of $0.50 per 1,000 gallons. However, the current rate offers
practically no incentive to avoid excessive water use. At a usage rate of $0.50 per 1,000 gallons
a customer could fill a 25,000 gallon swimming pool for $12.50, substantially less than the $200
national average typically required to fill a backyard swimming pool.
Staff believes that approximately 20oh of revenue should be recovered through usage-
based charges, more than the l3Yo recovered volumetrically in the Company's proposal. A
larger volumetric recovery percentage is needed to reduce excessive water use and to recognize
that some variable (volumetric or usage-based) costs vary directly with the quantity of water
consumed. For example, the Company incurs an incremental cost of approximately $0.56 per
1,000 gallons for electricity and for hydrogen peroxide. A meaningful usage-based charge helps
ensure that customers who add variable costs by consuming relative large quantities of water
contribute equitably to covering those costs, thus minimizing the subsidization of high-use
Description of Charge/Rate Applies to:Existing Rates
Company
Proposed Rates
Percent
Change
Customer Charge $22.00 $113.86 417.5%
l't Tier Usage Rate
in ($/1,000 gallons)
I't 8,000 gal No charge $1.83
2nd Tier Usage Rate
in ($/1,000 gallons)
Over 8,000 gal $0.50 s5.00 900%
STAFF COMMENTS t6 AUGUST 17,2077
customers by low-use customers. Given that rates are calculated based on a given revenue
requirement, increased usage rates are offset by a lower customer charge. Shifting more cost
recovery to usage-based charges from fixed customer charges does not change the calculated
revenue collected from all customers, but it does increase bills for high-use water customers
relative to low-use customers, an appropriate and desirable result. However, Staff recognizes
that to the extent that new rates are effective in reducing consumption, the Company's revenue
collections may fall short of the authorized revenue requirement. If the revenue shortfall is
significant, the Company may need to request additional rate relief from the Commission.
Staff s recommended rate design differs from the Company's proposed rate design in
three ways. First, Staff s rate design would collect less revenue than the Company's proposed
design. Staff s rate design recovers Staff s proposed revenue requirement of $28,973, which is
less than the Company's proposed revenue of $36,997.
Second, Staffs proposed rate design recovers l9oh ofrevenue through usage charges, as
opposed to the 130lo recovered volumetrically under the Company's proposed rate design. This
provides a further incentive for customers to limit consumption to system capabilities. Recovery
of 19%o of revenue through usage is consistent with the rate design approved by the Commission
for Morning View Water Company in January of this year. Order No. 33698. In that case,20o/o
of revenue was recovered through usage charges under an inclining block rate design. Finally,
Staff proposes three tiers for usage rates, as opposed to two tiers in the Company's proposed
design. Staff s proposal is as follows:
Description of Charge Applies to:
Staff
Proposed Rates
Customer Charge $82.00
1't Tier Usage Rate in ($/1,000 gallons)1't 8,000 gallons $2.s0
2'd Tier Usage Rate in ($/1,000 gallons)Next 12,000 gallons $3.75
3rd Tier Usage Rate in ($/1,000 gallons)Over 20,000 gallons $s.00
Table 2: Staff s proposed rates.
STAFF COMMENTS 17 AUGUST 17,2017
Staff s proposed rate design includes an $82.00 per month customer charge. Staffls
lower proposed customer charge provides customers with better opportunities to manage bills
through controlling usage. Assuming monthly usage of 6,000 gallons, which is the average use
per customer during the four lowest-use billing months, the current monthly bill is $22.00. The
bill under the Company proposal would be $124.84 (467% increase), and the bill under the Staff
proposal would be $97.00 (341% increase). Assuming monthly usage of 16,000 gallons, which
is the average use per customer during the two highest-use billing months, the current monthly
bill is $26.00, the bill under the Company proposal would be $168.50 (548% increase), and the
bill under the Staff proposal would be $132.00 (408% increase). The monthly bill under Staff s
proposed rate is less than the bill under the Company's proposal for all usage levels.
Relative to the Company proposal, Staff s rate design is more focused on providing a
disincentive to the most excessive water use. Customers using over 20,000 gallons per month
are probably using water over more hours of the day, which would increase the probability that
their use will be coincident with the use of other customers. "Pancaking" of water use over a
number of customers could push the system toward the capacity of the potable water well.
PROPOSED FEES, COMPA}{Y POLICIES, AND CUSTOMER RELATIONS
Reconnection Fee
In its Application, the Company requested an increase of its reconnection fee from $20 to
$65. In response to Staff s Production Request No. 31, the Company elected to change this
amount to $45, which is based on the System Operator's contract rate for one hour of onsite
work. Historically, the Commission has allowed a portion of actual costs to be recovered
through a direct charge to affected customers. However, the amount requested by the Company
is inconsistent with charges authorized by the Commission for other regulated utilities. Staff
instead recommends maintaining the $20 reconnection charge for reconnections following an
involuntary disconnection of service for nonpayment during normal business hours. Staff also
proposes a $40 reconnection charge for reconnections following an involuntary disconnection of
service for non-payment to be applied when the reconnection is requested outside of normal
business hours. These charges are within the range of charges previously approved by the
Commission for other regulated utilities under similar circumstances. Staff defines normal
business hours as 8:00 a.m. to 5:00 p.m., Monday through Friday, excluding legal holidays. In
STAFF COMMENTS 18 AUGUST I7,2OI7
addition, Staff recommends that the Company work with Staff to revise its Tariff to describe the
circumstances under which a customer may be disconnected.
Meter Testing Fee
Notably, in its Application, the Company requested a new meter testing fee of $65. In
response to Staff s Production Request No. 30, the Company withdrew its request to implement
this charge. Staff likewise recommends that there be no charge for meter tests requested by
customers.
Tariffs, Notices, and Other Documents
The Company's current Tariff was last updated January I , 2004, at the conclusion of Case
No. GPW-W-02-01. Commission Staff recently revised its Model Tariff, which includes revised
General Rules and Regulations and incorporates the Uniform Main Extension Rule for Water
Utilities based on Order No. 7830 (Case No. U-1500-22). Staff recommends that the Company
update its Tariff using this model.
In response to Staff s Production Request No. 28, the Company indicated that it had
adopted a Cross Connection Control Program in March 2017. Because Grouse Point Subdivision
has a pressurized inigation system that connects to several customers' potable water systems,
cross connection control is critical.a Staff recommends the Company work with Staff to add the
requirements of this new program to its Tariff.
In addition to revising its billing statements and Tariff, Staff recommends that the
Company revise or create notices and other documents that comply with the UCRR. In
particular, Staff has identified problems with the initial and final disconnection notices, notice of
procedure for reconnection, summary of rules, and explanation of rate schedule. Staff
recommends the Commission order that the Company work with Staff to revise its Tariff, notices
and other documents to ensure compliance with the Commission rules.
a According to IDEQ, "a cross-connection is an actual or potential connection or piping arrangement between a
drinking water system and another source that could introduce anything other than the potable water intended to
normally supply the system. Cross-connections include bypass arrangements, jumper connections, removable
sections, swivel or changeover devices, and other devices that may cause non-potable water to backflow into the
potable water supply. Backflow occurs when the normal flow direction of the water system is reversed due to back
pressure or back siphonage." DEQ Drinking Water Cross Connections Control Programs Fact Sheet (FS-0416).
STAFF COMMENTS 19 AUGUST 77,2017
Customer Notification
The Company filed a "proposed" customer notice with its Application for a rate increase
on February 22,2017. The notice was not sent to customers before the Application was filed,
and Staff found that it did not meet the requirements of Rule 125 of the Commission's Rules of
Procedure, IDAPA 31.01.01. Staff worked with the Company to revise the notice, and the
Company subsequently included the revised notice with customer bills sent on April 13, 2017.
The Company emailed a copy of its customer notice to the list of local media contacts provided
by Commission Staff, which included the Idaho Statesman, the Boise Weekly, 670 KBOI Radio,
and Channel 2 (KBCI), 6 (KIVI) 7 (KTVB), and 12 (KTRV) News.
Public Workshop
Staff held a public workshop at Kuna City Hall on July 20,2017. It was attended by
more than 20 people. Among the topics discussed at the workshop were concerns about the
proposed rates and rate design, issues involving the peroxide water treatment system, and the
need for timelier customer notification of exposure to uranium whenever the fire well is used.
Where appropriate, Staff has attempted to address these comments and concerns here.
Customer Comments
As of June 8, 2017, 13 comments have been submitted, all of which oppose the rate
increase. Two customers did not approve of the proposed tiered rate structure, and one requested
arate reduction after capital expenses were recouped. Four were concerned that the rate increase
was to fund a water system that was too large for the current users or that the existing customers
were paying for future development.
One customer noted that many who live in the subdivision are retired, with fixed or
limited incomes, and expressed concern about the impact of the large rate increase proposed by
the Company.
The majority (10) commented on the odor and taste of the water, especially when the
treatment system was not working properly. When there are issues with the water treatment
system, several customers say that not only is the water undrinkable, but they cannot use it to
bathe or wash clothes. Eight customers state they have installed filtration systems in their homes
to try to improve the quality of the water. There was concern expressed by four customers that
STAFF COMMENTS 20 AUGUST I7,2OI7
the Company might discontinue water treatment as a cost-cutting measure. One customer did
not feel it is reasonable to require her to pay the proposed rates when she has to flush the pipes in
her home up to five times ayear to remove discolored water. There were two comments about
an HOA meeting with Grouse Point to discuss possible water treatment solutions, noting that no
agreement was reached on any proposal. One customer pointed out that the bill does not show
the actual usage.
With regard to comments regarding expanding customer base, Staff notes that because
the Grouse Point Water Company is very small, each additional customer would result in a 4o/o
increase in revenue. Staff thus recommends that the Commission order the Company to file a
new rate case within one year of adding any new customers.
Customer Complaints and Inquiries to Commission
From September 2014 through June 2077, the Commission's Consumer Assistance Staff
received one complaint and thirteen inquiries about the Company. ln2014, there were two
inquiries about the rate case process, which were prompted by a letter sent by the Company to
customers regarding filing a rate case and offering to defer the request to increase rates if all
homeowners installed a filtration system to reduce the Company's costs.
In May and June of 2017, there were eleven inquiries related to water quality and safety.
The single complaint concerned fire hydrant maintenance and testing. Notably, Staff spoke with
each of the commenting customers to better understand their comments and concerns.
STAFF RECOMMENDATIONS
Staff recommends that the Commission approve the Company's Application with the
following adjustments :
1. A 2015 pro-forma test year, as described in these comments.
2. Arate base of $87,775.
3. An 1lolo retum on rate base.
4. An annual revenue requirement of $28,973, which includes $1,103 for operating the
peroxide system, and $500 for annual fire testing by the Boise City Fire Department.
5. That the Company coordinate fire pump flow testing with Boise City Fire Department,
and notifu customers in advance.
STAFF COMMENTS 2l AUGUST 17,2OI7
6. The rate design proposed by Staff, and shown in Table 2.
7. That the Company be required to file a new rate case within one year of adding any
new customers.
8. That the Commission order the Company to repair and maintain its master meter.
9. That the Commission approve the following charges:
a) Reconnection charge for reconnections following an involuntary disconnection
of service. $20 for reconnection during normal business hours, and $40 for
reconnection outside of normal business hours.
b) A late-payment charge of lo/o on any past-due balance owing at the time of the
next billing statement.
c) A $20 returned payment charge.
d) No charge for meter testing.
10. That the Company make the necessary changes to its meter reading and billing
practices to comply with the UCRR.
11. That the Company revise its Tariff to comply with the UCRR, including:
a) The Company use the 2017 Model Tariff developed by Staff.
b) Add Cross Control Program Requirements.
12. That the Company revise or create the following documents to comply with the
UCRR:
a) Billing Statement.
b) Initial Disconnection Notice.
c) Final Disconnection Notice.
d) Notice of Procedure for Reconnection.
e) Summary of Rules.
f) Explanation of Rate Schedule.
STAFF COMMENTS 22 AUGUST 17,2017
\'fyRespectfully submitted this
Technical Staff: Michael Morrison
Jolene Bossard
Bentley Erdwurm
Chris Hecht
John Nobbs
i:umisc/comments/gpww I 7. I bkmmjnbejbcwh comments
day of August2017.
Attorney General
STAFF COMMENTS 23 AUGUST 17,2OI7
Grouse Point Water Company, LLC
Results of Operations
CYE 2015
Worksheet A-Summary
Total System Revenue
Repairs & Maintenance
Professional Fees
Utilities - Power
lnsurance Expenses
Licenses and Fees
Telephone Expenses
Worksheet D
Depreciation Expense
Regultory fee
Total Expenses
Gain (Loss)
Attachment A
Expenses subtotal
s6,439
S1,887
57,297
S4,543
S 1,18 i.
s120
s440
s4,5gg
Sso
520,107
(s13,669)
Attachment A
Case No. GPW-W-17-01
StaffComments
08lt7lt7
Attachment B
Case No. GPW-W-17-01
Staff Comments
08/l7lr7
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Grouse Point Water, LLC
Ad ministrative Expenses
cYE 201s
Company
Account Balance
Staff
Phone Conf Re: HOA
E-Mail Re: HOA
Phone Conf Re: HOA
Phone Conf Re: HOA
HOA eveng Board Mtg
Review Status
audit adjustment
d iffe re nce
Attachment C
Date Amount subtotal
Adjusted
Total
s/t49lt4
0s124/14
tol22/1.4
to/27114
70128/1.4
02/L3lts
547.67
s23.83
ses.33
547.67
5476.67
s23.83
s1,925
(Szrs1
S1,210
Attachment C
Case No. GPW-W-17-01
Staff Comments
08117117
Grouse Point Water, LLC
Utilties - Power
CYE 2015
Company
Utilties - Power
Utilties - Fire Pump
Total
Attachment D
Balance EffAdj AdjTotal
54,723 (S2,163)
s420
S1,960
s420
s4,543 (s2,163) s2,380
Attachment D
Case No. GPW-W-17-01
Staff Comments
08lt7lt7
Grouse Point Water Company, LLC
Water Testing Expense
cYE 2015
Test
WellNo. 1
Nitrate
Well No.2
Nitrate
Well No.3
N itrate
Nitrite
Alpha
Uranium
VOCs Group
Arsenic
Sodium
Flouride
lnorganic Contaminants Phs 2
lnorganic Contaminants Phs 5
Volatile Organic Contaminants
Distribution System
TotalColiform
Copper
Lead
subtota I
Reported-Worksheet A-Sum ma ry
Difference
Attachment E
No. Tests
Frequency 9 Yr Cycle
Total Avg
Cost/Cycl Cost/Yr
Cost per
Test
Audit
Adjustmt
Annual e.0 s18.00 s162.00 srs.oo
Annual 9.0 s18.00 s162.00 s18.00
Annual
lin9Yrs
lin9Yrs
lin9Yrs
lin6Yrs
lin3Yrs
lin3Yrs
L in 3Yrs
f. in 3 Yrs
2in3Yrs
lin6Yrs
s18.oo
s17.oo
s7o.oo
Sgo.oo
s190.00
s21.oo
s13.00
s16.oo
s104.00
s76.00
sleo.oo
s162.00
s17.00
s70.00
s30.00
s28s.00
s63.oo
s3s.00
s48.oo
s312.oo
s228.00
ss70.00
s1,620.00
s1s6.00
S31s.oo
s18.00
Sr.ag
57.78
Se.ss
s31.67
s7.00
s4.33
ss.33
$34.67
s2s.33
S63.33
s180.oo
s17.33
s3s.oo
Monthly
4in3yrs
5in3yrs
9.0
L.0
1.0
1.0
1.5
3.0
3.0
3.0
3.0
3.0
3.0
108
t2
15
s1s.o0
s13.00
s21.00
s471.oo
$22s.00
5242
Attachment E
Case No. GPW-W-17-01
Staff Comments
08lt7lt7
Grouse Point Water Company, LLC
Plant in Service
CYE 2015
Attachment F
Date Hist Cost AccDepr NBV subtotal AmountLine
Worksheet B-Summary
1 Well
2 1,5 HP Pump
3 Repl 15 Hp Pump
4 subtotal- Company
Staff
5 Customer Meters
6 Well
7 L5 HP Pump
8 Repl 15 Hp Pump
9 Cap Exp - Fire Well/Pump
10 Cap Exp - Chem Pump
1,1, Cap Exp - VFD
12 subtotal
13 Difference
s84,41,6 (517,137)
s34,602 (s12,111)
58,423 (S1,263)
2009
2009
201,3
1996
2009
2009
2073
2OI2 to 201,5
2OL2 to 201.5
2072 &2015
567,279
522,491,
57,L60
s\27,441 (sAO,Srr1 S96,930
S3,453
S84,416
S34,602
S8,423
s8,301
s2,580
Saoo
(s2,302)
(s17,136)
(s34,602)
(s1,053)
(s1,285)
(Szsa1
(Ssal
s1,151
567,28o
So
57,370
S7,016
52,322
s768
5t42,64L ($56,734)s85,907
S11,023
Attachment F
Case No. GPW-W-17-01
Staff Comments
08117117
Grouse Point Water Company, LLC
Depreciation Expense
CYE 2015
Company
Wells
15 HP Pump - 2009
15 hP Repl Pump
su btota I
Attachment G
Audit
subtotal Adjustmt
s4,599
$3,s72
$1,027
Amount
52,449
S1,730
Sqzt
Staff
Meters
Well#3
15 HP Pump - 2009
1"5 hP Repl Pump -2013
Reclass -Firepump/Well
Reclass- Chem Pump
Reclassified - VFD
subtotal
Difference
s11s
52,448
SO
5421.
541s
s 130
s43
Attachment G
Case No. GPW-W-17-01
Staff Comments
08117117
Grouse Point Water Company, LLC
Amortization of Rate Case Expenses
cYE 2015
Company
Attachment H
Yrs Amount AnnAmtz
7 525,944 53,706
(s1,647)
(s17,000)
(s18,647)
522,64s
s3,998 s800
Staff
201,5 - Acctg Expenses
2017- Estimates
subtotal
Adjust to SLE
su btota I
Difference
5
Audit
Adjstmt
S2,9062
Attachment H
Case No. GPW-W-17-01
staff comments
08lt7lt7
Grouse Point Water Company, LLC
Rate Base
CYE 2015
Plant in Service
Accumulated Depr
su btota I
CIAC
subtotal
Working Capital
Total
Working Capital Calculation
Total Expenses
less non-cash: Depr Expense
subtotal
Divisor, 1/8th Rule
Working Capital
Attachment I
Staff GPW Difference
5142,641. 51.27,441
(ss6,734) (s30,511)
s15,200
$26,223)
S85,907
So
s96,930
So
(s11,023)
So
s85,907
S1,868
s96,930
52,126
(s 11,023)
(Szsa1
587,775 599,056 (511,281)
S18,518
(Sg,szz)
5t4,946
8
s1,868
Attachment I
Case No. GPW-W-17-01
Staff Comments
08/17/17
Grouse Point Water Company, LLC
Revenue Requirement
CYE 2015
Rate Base
Rate of Return
Return on lnvestment
Net Operating Loss
Net Operating lncome Deficiency
Net Operating Loss
Deficiency not subject to Gross Up
Deficiency Subject to Gross Up
Gross Up Factor
Grossed Up Deficiency
Operating Revenue Deficiency
Rate Case Expenses
5 Year Amortization
Total Revenue Deficiency
Test Year Revenue at Current Rates
Total Revenue Requirement
Gross Up Calculation
Net Deficiency
PUC Fees
Bad Debts
su btotal
State Tax at8.O%
FederalTaxable
Federal Taxable aIt5%
Net After Tax
Net to Gross Multiplier
Attachment J
587,775
1,1,.00%
S9,655
s9,061
S18,716
s9,061
s9,655
128.22%
s4,000
100.oo%
0.27%
0.00%
99.73%
7.98%
91.75%
1,3.76%
77.99%
128.22%
s9,061
S i.2,380
$2t,441,
S8oo
5zz,24L
56,732
528,973
A$achment J
Case No. GPW-W-17-01
staff comments
08lt7lr7
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Case No. GPW-W-17-01
Staff Comments
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CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS ITTH DAY OF AUGUST 2017,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN
CASE NO. GPW-W-I7-01, BY MAILING A COPY THEREOF, POSTAGE PREPAID,
TO THE FOLLOWING:
TIM FARRELL, P.E.
LISA WANNER
GROUSE POINT WATER COMPANY, LLC
PO BOX 9906
BOISE ID 83707
E-MAIL: [e-mail]
SECRETARY
CERTIFICATE OF SERVICE