Board members present: Dorothy Anderson, Peter Bartel, Susie Smith, Patrick Lanning, and Sandra Bishop.
Others present: Randy Berggren, Greg Armstead, Cathy Bloom, Tom Buckhouse, Terry Bequette, Chuck Dalton, Marty Douglass, Mike Logan, Mat Northway, Jim Origliosso, Laurie Power, Dick Varner, Pat Ventura, Jim Wiley, Stephen West, John Yanov, and Krista Hince of the EWEB staff; members of the public; and Kris Aanderud, City of Eugene Minutes Recorder.
President Anderson called the Work Session of the Eugene Water & Electric Board (EWEB) order.
ELECTRIC COSA (Cost of Service Analysis) AND RATE DESIGN ISSUES
John Yanov, Senior Rates/Financial Analyst, and Dick Varner, Fiscal Services Supervisor, updated the electric and water rate proposals. Mr. Yanov provided several handouts for EWEB members.
Bob Lorenzen, Energy Management Section Manager, provided a brief presentation on the Low Income Weatherization Services Assessment, outlined in a Memorandum dated June 21, 2001. He highlighted that EWEB has paid incentives for energy efficiency improvements in more than 6,000 dwelling units occupied by low-income residents.
Vice President Bartel asked if all of the low-income residential units had been included in the survey. Mat Northway, Energy Management Services Manager, said that some low-income property owners choose to participate and some choose not to participate. He said that if it was an issue with the occupants, then the survey may provide confirmation that there may not be many low income units which have not been weatherized.
Mr. Northway said that HACSA (Housing Authority) has suggested that lack of funding has been a bottleneck. He said that with additional funds, more low-income units would be weatherized. He added that it was important to make sure that offering money does not hinder addressing other barriers.
Commissioner Bishop arrived at 6:48 p.m.
Mr. Northway made a brief presentation on the Customer Conservation Activities for 2001, as outlined in a Memorandum dated June 25, 2001.
Mr. Lorenzen reviewed the statewide building code, information which was also included in a Memorandum dated June 21, 2001. He noted that State Building Codes recognizes that no local jurisdiction may adopt a code which is less stringent, nor more restrictive than the standard code adopted by the State. The code directs local governments to adopt and enforce the codes within their area of jurisdiction.
Chuck Dalton, Customer Relations Manager, presented an overview of low-income options contained in a Memorandum dated June 28, 2001. The four options were generally identified as 1) bill paying assistance, 2) conservation, 3) energy education, and 4) credit and collection policies. Mr. Dalton recommended that the energy share program donation be increased from $150 annually to $300 annually. He suggested that there be an energy conservation education class offered for those who qualify for the energy share program. In addition, he suggested that the income eligibility guide lines be increased from approximately 150 percent of the federal poverty line to 200 percent of the poverty guide line.
Mr. Dalton also reviewed the REACH program and Universal Service Plan guidelines. He noted that the funding for the REACH program was scheduled to run out at the end of the year, unless additional authorization and funding was provided by the federal government to subsidize the program. The cost per slot was calculated to be $877 annually. Mr. Dalton said that fewer households would benefit from this program.
Mr. Yanov asked for Board feedback on what level of assistance might be considered.
Commissioner Smith said that not withstanding the concerns associated with another rate schedule, it seemed that it would be an administrative cost savings to establish a separate rate structure for low-income households. Mr. Dalton responded that for many customers, the reduced rate structure was beneficial. However, he said that there were customers who need a higher level of "hand-holding." He acknowledged that other areas are using this tool, but that this change could be a decision that the Board could make.
Commissioner Smith said that she was not suggesting that there be a wholesale replacement of the existing programs with a discounted rate, but wanted to ensure that staff had discussed the option considering the funds required to administer the various programs. Mr. Dalton said that he felt that this would be a valuable discussion to have.
President Anderson asked if staff could estimate how many people needed extra attention, rather than those who would benefit from the rate reduction itself. She said it would be helpful to have some way to analyze the trade-off from having a lower rate versus maintaining current level of services. Mr. Dalton said that the "working poor" would be impacted fairly heavily by the rate increase. He said that the cadre of customers, from 150 percent to 250 percent, will struggle to pay the rate increase. This will be a new group of customers who have not sought services or assistance in the past, but may need assistance. From the customer's standpoint, Mr. Dalton said it seemed like a rate structure decrease for low-income customers would free up REACH and other program funds for the new group of customers who need assistance.
Commissioner Bishop expressed concern that by providing a reduced rate structure requires others customers to subsidize the reduced rates. She said that she was not interested in adopting a subsidized rate structure. She added that the current programs seem to be working well.
Vice President Bartel agreed that it was important to stay in the "hands on" programs, rather than provide subsidized rates. He said that it seemed that the customers who were served by the various programs also needed assistance with managing their funds and their energy costs. Mr. Dalton said that the majority of customers who were being served by the various programs were catching up on their bills.
Commissioner Smith said that there was $9.5 million on the table and that if energy share contributors give the same amount, then it would be the rate increases which then would subsidize the various programs. Commissioner Bishop said that she felt there was an opportunity to get additional funds through the City of Eugene. She suggested that a structured proposal be prepared for presentation to the City Council.
Marty Douglass, Public Affairs Manager, reported that there will be another memorandum distributed to EWEB members in the next week which would address potential scenarios. He said that customer service provisions and staff activities would also be included. He said that from the list of programs and costs associated with each, the Board could decide at what level it would like to approach the City Council.
Vice President Bartel said that he felt that a structured proposal seemed appropriate. He added that even if individual Board members speak with individual City Councilors and were told that there was not support for the proposal, it was important to get this on the City Council agenda and to have the public discussion. Commissioner Bishop added that this was a partnership and that a program could be structured which would be beneficial for both the City and the low income programs.
Mr. Douglass said that the initial projections show that the increase will be approximately $5 million in the first year, $4 in the second and $2.5 - $3 million in the third year. Mr. Varner added that the additional revenue was already anticipated and built into the current year budget and financial plan, which will be an obstacle.
Commissioner Lanning said that it will be important to provide information for questions which could be predicted to be asked. Mr. Dalton noted that many of the programs provide one-time assistance.
Mr. Douglass reviewed a proposed public relations and communications program, included in a detailed handout entitled, "Communication Actions for Upcoming Rate Change" provided for Board members. He added that there would be opportunities to talk with civic groups and clubs and invited Board members to become involved with those meetings.
Vice President Bartel said that the content of the public relations program looked good, but expressed concern with the timeline to have a public hearing in August and a second public hearing on Tuesday immediately following Labor Day. He suggested that the second public hearing be pushed back a week, if the constraints could be accommodated. Mr. Varner said that the latest date that the Board could take action to impact rates in November, would be the September 18 Board meeting.
President Anderson asked about scheduling a Special Board Meeting to hold a Public Hearing on September 11. Mr. Varner said that if the Board requests staff to make revisions or provide additional information, staff needs time to adequately prepare. He said that staff needs two weeks if the Board requests a change. Commissioner Smith suggested that there be one public hearing, with the opportunity for the record to be held open.
Mr. Yanov said that the Board has currently adopted guidelines (Public Utility Regulatory Policy Act - PURPA) which calls for two public hearings. Commissioner Smith asked if an emergency waiver could be accommodated. President Anderson said she would be concerned with this suggestion. Commissioner Bishop said she felt it was important to have two public hearings. Vice President Bartel said he liked the concept of having one public hearing, with the opportunity to keep the record open. He suggested that through public access television, there might be an opportunity to show the first Public Hearing on more than one occasion.
President Anderson noted that she was not going to be here in August. Commissioner Lanning said that he would not available on August 7. Commissioner Smith said that she did not want to have the Public Hearing with only three Board members present.
Commissioner Lanning asked why the first Public Hearing could not be held on July 17. Mr. Varner said that the rate design would not be completed until July 20-25. Commissioner Smith said that pressing staff did not seem doable. Vice President Bartel said that he would not be available on August 7, which creates a quorum problem. He said he was available on July 31, Aug. 1 or 2. Commissioner Smith said that she would not be here at that time. Commissioner Smith again asked what the benefit would be of having two public hearings.
Commissioner Bishop said that the public may not make much distinction between the public meetings and public hearings. She suggested that one of the public meetings be declared as a Public Hearing. Vice President Bartel said that it was customary for absent Board members to read the materials and listen to tapes of the meetings. President Anderson said that she felt that the public wants to testify before the decision makers. Vice President Bartel said that it was the information that was important.
Commissioner Smith suggested that the staff proposal be accepted, but allow the staff to address the scheduling issue. Commissioner Bishop asked if the direction was for one or two public hearings. President Anderson said two were required. Vice President Bartel concurred. There was no objection to this suggestion.
Greg Armstead, Data Manager, spoke about bill system preparations which would be necessary. He said that with the testing which has been completed, any of the options can be accommodated with the current system. He said that the goal would be to keep the bills to one sheet of paper, but with additional data. He said that a new banner system was anticipated to be updated next week. He added that they have run into a resource crunch, in terms of reprogramming, and noted that staff may need to come back to the Board to ask for more resources from Bill Print, a contractor. He said the software has been tested on the system, but was not in production at this time.
Mr. Varner provided information on the cost driver update, as outlined in a PowerPoint presentation, a copy of which was provided to EWEB members. He noted that the BPA increase has been announced at 46 percent. He noted that to get the increase down to 46 percent, EWEB has given BPA 25 MW of entitlement for one year at below market cost. This will impact the financials by approximately $10 million, which equates to a 65 to 70 percent increase. He said that there was also additional costs to buy services for load shaping and load regulation, which EWEB does not currently buy from BPA. The BPA power contract totals $36.1 million. Additional cost drivers included:
|
• New Wheeling Rates |
$2.0 million |
|
• Relicensing Debt Service |
2.5 million |
|
• Bad Debts |
1.0 million |
|
• 5% Conservation on Above |
2.1 million |
|
• CILT |
2.8 million |
The preliminary revenue requirements total $46.5 million increase or 36 percent of current retail revenues. Mr. Varner noted two additional issues: 1) low income mitigation and 2) power reserve replenishment. He spoke to the Federal Energy Regulatory Commission (FERC) mitigation which has turned the market "upside-down." He said that EWEB has 25 to 40 megawatts which were being held through the end of the year, and EWEB was forced to purchase this through the risk management policies. Power was purchased at $200 per megawatt, but under the FERC mitigation, EWEB cannot sell this power for more than $100 per megawatt though September, 2002. This would take a power reserve of approximately $35 million to zero or a negative position. He said that the FERC price mitigation order has impacted EWEB significantly. These caps have essentially collapsed the market. Mr. Varner spoke about some of the reactions to the market changes in the last week. He noted that the price was below the non-critical hour price, somewhere around $80 per megawatt hour.
Mr. Varner said that companies were afraid to trade, concerned about what the price cap might be. He said that in the late fall or early winter, there will be a high probability of drawing the power operating reserves to zero or draw a line of credit for cash flow needs. He said that the Board has two options, 1) put an "adder" on this rate increase or 2) use the power cost recovery adjustment and adjust rates after the first of the year, which would likely require borrowing a large amount of money. Mr. Berggren noted that it may be possible that EWEB would also have to borrow money under the first option.
President Anderson asked if there was any opportunity for FERC to make changes to the mitigation order. Mr. Berggren said that this was the worst possible position to be in. He said that EWEB has survived the crisis and positioned itself accordingly, only to have a price cap put in place after the portfolio position has been established above market rate. Mr. Varner said that Portland General Electric has a similar problem.
Mr. Varner noted that the Board should discuss these two alternatives and give staff further direction. In addition, he discussed the current power cost recovery adjustment adopted in 2000. He noted that the BPA power cost adjustment could be adjusted every six months. Mr. Varner recommended that there be a short-cut process which would allow for an "adder" or "subtractor" from the rates to accommodate the BPA rate adjustments, using a single public hearing with affirmative action by the Board.
Vice President Bartel asked when this proposal goes into effect. Mr. Varner said that the first time it would be exercised would be in the first quarter of 2002, anticipating that BPA will announce its rates by February 15 with an anticipated rate increase on April 1, 2002.
Commissioner Smith asked if the power adder was adopted as an automatic provision. Mr. Varner said it would follow the same process as was implemented previously, that staff would bring a proposal to the Board for an affirmative action to implement a change in the rates. This would include a Public Hearing and was not designed to be an administrative action.
Mr. Varner said that the power cost recovery adjustment should be left in place, but added that a floor be established in the $10 million to $15 million range, with a ceiling of $20 million to $25 million. He said that this, with the additional borrowing authority will give EWEB the cash flow flexibility to weather any circumstance.
President Anderson noted that the lower BPA rate did not make any difference. Mr. Berggren said that it could be worse, but that the utilities had to take some additional risk.
Vice President Bartel said that it was important to tell the public that the actual increase would amount to 75 - 80 percent, not the 46 percent publicized by BPA. He said that customers need to be prepared for the increases which will be the actual increase due to the BPA position. He suggested that the Board and EWEB should insulate itself as best it can. Mr. Berggren said that it was important to note that the utilities helped BPA get to the 46 percent number, but that there were additional costs associated with the negotiations. Vice President Bartel said that it seemed important to formalize the presentation to educate the public. Mr. Berggren asked if this was something staff should do. Vice President Bartel said yes. Commissioner Lanning concurred, but asked how the Board missed this. Mr. Varner said that the changes have come about during the last two months and Mr. Berggren added that until the last day, EWEB was not sure if it would join the consortium. President Anderson agreed that it was important to get information out to the public.
Mr. Douglass suggested that the visit with the Register Guard Editorial Board could be moved up in the timeline.
Mr. Varner noted that the staff presentations had taken longer than anticipated and asked how the Board would like to proceed.
President Anderson noted that the Board still needed to make a decision on which of the options to pursue. She noted that there was also a full agenda for the regular meeting, but added that she hated to disrupt the current discussion. Commissioner Smith asked if the audit letter from PricewaterhouseCoopers, which had been allotted 30 minutes could be deleted from the Regular Session agenda. Commissioner Bishop said that she had questions on the audit, but that she could speak with staff individually. Commissioner Lanning said that he had asked for the presentation, as a new Board Member. He said that he could take care of this individually.
The Board agreed to withdraw the PricewaterhouseCoopers Management Letter of the annual audit from the regular meeting agenda and to delay the Regular Board meeting until 8 p.m. Board members were provided with a letter and an additional five pages of the management letter from PricewaterhouseCoopers. A short recess was taken at 7:15 p.m.
The EWEB meeting reconvened at 7:20 p.m.
Mr. Yanov reviewed the electric rate proposal/tiered rate options design considerations, as outlined in a Memorandum dated June 15, 2001, with an attached Memorandum from Dick Varner regarding Rate Options and Low-Income Data, dated June 20, 2001. In addition, EWEB members were provided with a Memorandum dated June 15, 2001 from John Yanov regarding Electric Rate Information, including four attachments: 1) survey of Northwest public utilities' residential rates, 2) survey of selected California public utilities' rates, 3) examples of residential tiered rates schedules and 4) new California PUC mandated residential rate schedules, and a separate Memorandum from Dick Varner dated June 26, 2001, regarding Rate Option Impacts.
The presentation reviewed the following:
Commissioner Smith asked that as the options were discussed, that the justification be reviewed for each block. Mr. Yanov said that 10 percent was an arbitrary number. He said that staff tried to be mindful of low-income customers. Commissioner Smith said that as an observation of other tiered rate proposals, EWEB was starting at a much lower increase which caused the dispersion to be much greater. Mr. Yanov said that the gap could be decreased, but that it would mean increasing the 10 percent base.
Commissioner Lanning said that low-income was considered in setting the 10 percent. He asked what the low-income designation was based upon. Mr. Varner said that the profile for low-income residents were not much different than other residences, except for apartment-dwellers. Mr. Yanov said that the agencies were favoring the tiered rate for low-income customers. Mr. Berggren said that it was more of a perception issue than a mathematical calculation. He said that there was no science to this, but was a "rate guess."
Mr. Yanov reviewed the Residential Rate Design, Alternatives 1, 2, 3 and 4 (noted as REL1 - ALT 1, 2, 3, and 4), provided both in statistical and graphical representation for each alternative.
Vice President Bartel asked what percentage of the rate payers were represented in the "Power Charge - over 1700" grouping. Mr. Varner said that it was five percent of the consumption, not customers. Vice President Bartel said that it would be helpful to have a representation of the current rate with the added rate comparison. Mr. Yanov said that the curve would be representative of approximately 40 percent above the current rate level. Mr. Varner drew an approximation of the anticipated combined rate onto the overhead, using Alternative 1 as an example.
Mr. Yanov asked if the Board members favored any one of the proposals. President Anderson said that she was leaning toward Alternatives 2 and 3, which favored the lower income. Commissioner Smith said that while she agreed with the alternatives in principle, there was going to be a sticker shock moving into the rate structure. Commissioner Smith said that she was interested in moderating the sticker shock and implementing a 15 percent increase initially.
President Anderson said that she would be interested in selecting a random customer in the higher end to demonstrate what the actual cost increase might be. Vice President Bartel suggested that something with 5 mil might be helpful. Mr. Varner suggested that the annual impact on a customer might be more helpful than the monthly bill impact provided. Vice President Bartel suggested that it would be valuable to look at five random bills to analyze the impact on each. Mr. Varner suggested five strategically selected customers be used to demonstrate how each would be impacted. Mr. Yanov said that for the general services increase, the impact was calculated for every customer. Board members did not indicate support for this last option.
Commissioner Lanning asked for more detail on the impact on low income customers. Mr. Varner said the rate may be skewed on the low end, but added that there were not a large number of customers who use 10,000 Kwh.
Commissioner Lanning asked what the expected sustained conservation result might be as a result of the rate increase. Mr. Varner said that there were no empirical studies on electrical utilities and conservation. Commissioner Lanning said that staff needs to develop principals on which to base the tiers. Commissioner Smith noted in the Wisconsin and California cases, there was a presumption for conservation. Commissioner Lanning said that decisions were being made on assumptions, which may not be true. He said that he was not comfortable that the constituents he represented wanted him to make decisions on assumptions.
Commissioner Smith responded that there were several factors which were included in the rate structure, including incentive for conservation and the rate-making equity structure. She said that there were a lot of policy pieces which impact a rate making structure. She said that there were a number of conclusions which could be reached given that there was a deficit mode environment. She said that there was not a different type of rate structure which was being implemented elsewhere to achieve the same outcomes, but that this was the one that was being used.
President Anderson asked for clarification of what the staff requests included. Mr. Varner said that staff needs direction on three issues:
Commissioner Bishop said that she did not want a separate low income rate - but wanted dollars dedicated to programs.
Commissioner Lanning asked why the power cost recovery rate increase could not included in the pursuit of a tiered rate increase. Mr. Varner said he needed one tiered rate increase option, but that the additional rate increase could be accomplished at the same time.
President Anderson asked for feedback on the power reserve replenishment. Commissioners Smith and Bishop both expressed an interest to wait. Commissioner Lanning said that there has been an increase of four times in power and that increasing the rate correspondingly seemed appropriate. Mr. Varner said the question was: Does the Board want to slow the slide in cash or does the Board want to wait until the end of the year to assess its position and take action at that time to replenish cash? The Board agreed to wait on this issue.
President Anderson said that she was at one time interested in the low-income rate structure, but currently favored the services for low-income families. She said that she concurred with Commissioner Bishop on this point. Vice President Bartel said that he could support a comparable increase for low-income programs as was anticipated for the total increase. For example, if $10 million was the total increase, $3.5 million could be targeted for low-income projects. Mr. Varner said that with a specific level of support, Mr. Dalton could bring a recommendation back to the Board.
Jim Origliosso, Treasurer, said that the average residential customer currently pays $650 and will be increased to $900 annually. He said that $3 million would equal $200 per customer for 15,000 customers. Vice President Bartel said that this was one way to utilize the $3 million, however, he asked that Mr. Dalton also provide additional information recommendations.
Commissioner Bishop suggested that $2 million to $3 million be considered for low-income subsidies and programs. The Board expressed an interest in getting more information on $2.5 million to $3 million. The final suggestion was that the staff develop a plan for $2.5 million.
The Board's third issue was to identify which design option was preferred. Commissioner Smith said that she liked alternative 2. President Anderson said that she favored Alternative 2 or Alternative 3. Commissioner Bishop noted that these two alternatives appeared to impact a smaller number of customers.
Commissioner Lanning asked which of the three options sent the best conservation message. Mr. Varner said that Alternative 1 sends the conservation message to the most customers, although Alternative 3 sends the message to the high energy users.
Mr. Varner asked if the Board wanted to stay with the 10 percent initial increase. Commissioner Lanning asked which plan most closely aligns with Seattle. Mr. Varner said that all of the options have more consumption in the first block than Seattle does, but that Alternative 2 most closely represents the Seattle model.
President Anderson suggested that staff start with 15 percent, using alternatives 2 and 3. Vice President Bartel said that he favored 2.8. Mr. Varner said that the updated information would be presented at the August 7 meeting.
Commissioner Bishop asked what examples of customer bills the Board might see. Mr. Varner outlined the variety of customers which might represent typical housing stock in the area. Commissioner Bishop suggested that the information be provided sooner, rather than later.
Mr. Varner recapped the actions to be taken by staff:
Commissioner Smith noted that she had several studies on price structure relative to consumption and cost, which she offered to share with other Board members.
WATER COSA AND RATE DESIGN ISSUES
Pat Ventura, Senior Financial Analyst, and Dick Varner, Fiscal Services Supervisor, reviewed the preliminary 2002 COSA results for water utilities. Mr. Ventura presented detailed information on the various rate blocks under consideration, including rates, results, and assumptions, all of which was provided in writing to Board members in a Memorandum dated June 28, 2001 and supplemental materials.
Mr. Varner suggest that a three tier rate would potentially increase Tier 1 by 77 cents, and something near $2 for tier 3. Mr. Ventura added that using these models, given the assumptions, indicates a slight decrease in the base rate, based on COSA. He said that this indicates that there has been a seasonal subsidy in the current rate structure. Mr. Ventura also illustrated changes for the general service rate class.
Vice President Bartel said it would be helpful to see the graphs which demonstrate the peaks for residential and commercial customers. Mr. Varner responded that residential peaks at 2.5 times the average, while commercial peaks at 1.5-2. He added that to the extent that there was less difference between winter and summer usage, peaking factors have less of an impact on rates. Mr. Ventura said he would try to provide the requested information.
Mr. Ventura then reviewed elevation zones, which include 26 distinct elevation zones. This material was also included in the materials distributed to members.
Vice President Bartel asked for justification of the assumptions used. Mr. Ventura said that season rates would complicate the decision. The materials provided isolate the impact of elevation zones itself. Mr. Varner used the Residential Winter/Summer Rates to demonstrate Mr. Ventura's point, which would lower the .778 rate slightly, with the elevation zones being added on top. The winter rates would .75, .83, .91, .99 rates, and the summer rates might be $1.10, $1.18, $1.26 and $1.34. He noted that there would be a layering effect. For the base elevation, the rates would be slightly lower, but for higher elevations, the rates would be higher.
Mr. Ventura said that the alternatives for cost allocations include: 1) power for pumping cost only, 2) O & M Costs, and 3) O & M plus capital costs. He said the alternatives for cost allocation were presented in order of progression. Mr. Varner added that the alternatives were developed based on which items had the strongest justifications.
Mr. Ventura asked for the Board to consider the following questions:
Vice President Bartel said he liked the winter/summer rate for both residential and general service plans. He suggested that the elevation study be continued.
Commissioner Smith said that she preferred the flat general service structure with no winter/summer rate. She could support the residential winter/summer but was nervous about residential elevation zone, although they may have merit and legitimate cost drivers.
President Anderson said she too favored the flat general service rate, but also was in support of the three tiered structure with an inverted block rate. She said that the testimony suggested that customers who were low-income often grow food for themselves and they needed a certain amount of water to support their crops. She added that a summer/winter rate structure made sense for residential with an inverted rate in consideration for low-income customers. She said that she did not know if 25 was too high. Mr. Varner said that the 25 leaves 25 percent of the consumption in the peak summer months in the third block (option 3 in residential). She added that she was willing to look at the elevation zone.
Commissioner Lanning asked what portion of the 9.1 percent increase was electrical. Mr. Varner said it was half or better. Commissioner Lanning asked how replacement and maintenance was charged for various areas. Mr. Varner said that there was no difference in charges.
Commissioner Lanning said he was interested in getting more information on the winter/summer rates, with inverted summer rates. He said he had no interest in winter/summer rates for general service and would be interested in looking at elevation rates.
Commissioner Bishop said that she was not sure what to think about a summer inverted block rate, but was willing to look at this more carefully. She said that it does not make sense to use summer/winter rates for general service.
Mr. Ventura noted that there was consensus to look further at elevation zones and a flat general service rate. Mr. Berggren asked what it would take for staff to develop the two alternatives for a winter/summer rate and a winter/summer with an inverted summer rate. Mr. Ventura said that he did not think it was unmanageable. Mr. Varner suggested that the winter/summer structure and the three tier, summer inverted structure could be developed. Board members found this to be acceptable.
Mr. Varner thanked the Board members for their hard work.
The meeting was adjourned at 8:35 p.m.
_____________________________________ ______________________________________
Assistant Secretary President