6. Comments on Alternate Proposed Decision

The alternate proposed decision of Commissioner Peevey was mailed to the parties in accordance with Section 311 of the Public Utilities Code and comments were permitted under Rule 14.3 of the Commission's Rules of Practice and Procedure. Comments were filed on May 12, 2011 by Californians for Renewable Energy, Inc. (CARE), IEP, EPUC, TURN, CAC and the Joint Utilities (PG&E, SCE and SDG&E), and reply comments were filed on May 17, 2011 by IEP, EPUC, CAC and the Joint Utilities.

A number of parties, IEP, EPUC and CAC in particular, requested clarifications to the restrictions on reviewing representatives so that there would not be any misinterpretation, and so the modifications the APD is making to D.06-12-030 expand the rights of parties for meaningful participation in Commission proceedings and make it possible for market participants to retain qualified Reviewing Representatives. We did adopt many of the recommendations for the Reviewing Representatives and those changes have been incorporated into this decision.

The Joint Utilities request clarifications they argue will ensure the protection of market-sensitive information. Specifically, the Joint Utilities request that EPUC be categorized as a market participant in all circumstances, rather than presuming it is not when it acts solely as a bundled purchaser of power to serve on-site and end-use utilities. After considering the arguments of the Joint Utilities and the reply of EPUC, we state that the presumption will remain that if EPUC is acting solely as a bundled purchaser of power to serve on-site and end-use customers it is not appearing as a market participant. This will be the case when EPUC appears in a general rate case or a rate design window proceeding. However, when EPUC appears in a utility procurement proceeding, including a proceeding for procurement of CHP, EPUC will be presumed to be a market-participant. Any party may challenge EPUC's categorization on a case-by-case basis. If the categorization of EPUC, or any other participant, as a market/non-market participant causes time-consuming and distracting litigation, this subject may be re-visited. It goes without repeating that EPUC must maintain an impermeable ethical wall to ensure that there is no leakage of sensitive material from EPUC as a non-market participant to EPUC as a market participant.

In addition, the Joint Utilities argue that an entire firm should be disqualified where any member of the firm consults with or advises market participants about energy marketing or related activities. While we appreciate the concern the Joint Utilities express for the protection of market-sensitive information, we are persuaded that the limiting language we proffer for Reviewing Representatives will protect the ratepayers. Reviewing Representatives will be required to execute a Nondisclosure Certificate in accordance with the Model Protective Order adopted in D.08-04-023 before they have access to market-sensitive information and we do not share the Joint Utilities' fear that the Reviewing Representatives will freely violate a Protective Order. As IEP cogently argues, the practitioners who have established reputations before this Commission for multiple decades will honor Commission orders as well as their contractual and ethical obligations, or they will lose the trust and confidence they worked so hard to build.

We are persuaded, however, that some of the suggestions advanced by the Joint Utilities for establishing standards for an effective ethical wall have merit and we have incorporated some of those suggestions into this decision.

1. The confidential nature of the information, the Legislature's mandate that this Commission ensure its confidentiality, the potential for economic misuse of market sensitive information by market participants and consequential adverse effects on ratepayers justifies the use of Reviewing Representatives, and the procedures adopted in D.06-12-030, as clarified herein.

2. Evidence that Modesto Irrigation District has disclosed procurement information similar to market sensitive information and its ratepayers have not been harmed is not proof that such disclosure will not result in ratepayer harm in all instances.

3. Under the CAISO Locational Marginal Pricing market structure, entities can bid supply at any price under the current bid caps; the market generally clears at the highest-priced supply bid to cover the bid-in system load. Therefore, bids as little as 1 MW, if they are the marginal awarded bid, can set the market clearing price for all suppliers at the relevant price point.

4. Because bids as little as 1 MW, if they are the marginal awarded bid, can set market clearing price for all supplies at the relevant price point, that constitutes a de minimis threshold for participation in the electricity market which may materially affect the market price of electricity.

5. The purpose of a market power test is to determine whether an entity has the ability to materially affect the market price of electricity on the basis of its market power. The test is not useful in determining whether an entity has the ability to materially affect the market price of electricity on the basis of its access to market sensitive information.

6. The modifications made to D.06-12-030 are minor and will provide the same protection to the confidential market sensitive information in the affected proceedings.

7. The prohibition of access to market sensitive information by attorneys, consultants or experts who simultaneously represent market and non-market participants is unnecessary and redundant. The intent of the limits on market participant Reviewing Representative is to prohibit the simultaneous engagement in wholesale power contract negotiations with a utility while accessing that utility's confidential procurement data.

8. When EPUC files in a Commission proceeding solely as a bundled purchaser of power to serve on-site and end-use customer load, EPUC is presumed to be a non-market participant. This presumption would be true for general rate cases and rate design window applications. When EPUC participates in a procurement proceeding as a market participant it is presumed to be a market participant. The presumption is subject to challenge on a case-by-case basis.

9. Under the California Independent System Operator's (CAISO) Locational Marginal Pricing market structure, entities can bid supply at any price under the current bid caps; the market generally clears at the highest-priced supply bid to cover the bid-in system load. Therefore, bids as little as 1 MW, if they are the marginal awarded bid, can set the market clearing price for all suppliers at the relevant price point.

10. In no case shall the designation of information as market sensitive information, pursuant to D.06-06-066 as modified by D.07-05-032 and subsequent decisions, exceed three years.

11. D.08-04-023 adopted a Model Protective Order for use with confidential market sensitive information. Parties to the Resource Adequacy , Procurement, Renewables Portfolio Standard, and offshoot or successor proceedings are required to abide by the confidentiality protections in the Model Protective Order. Parties to other proceedings, and in industries other than the electric sector, may find the Model Protective Order useful, although they are not obligated to use it. There have been no previous decisions or orders modifying D.08-04-023.

12. Modifications made by this decision to D.06-12-030 necessitate conforming changes to the Model Protective Order adopted by D.08-04-023.

13. The Commission also encourages the use of bilateral Nondisclosure Agreements between parties, as an alternative to a Protective Order. To that end, the Commission will direct the parties to develop a Model Nondisclosure Agreement, along with an updated version of the Model Protective Order.

14. HEI's motion to become party should be granted.

15. The confidentiality procedures we have adopted herein and in the underlying rulemaking, including modifications to D.06-06-066 as modified by D.07-05-032, D.06-12-030, and D.08-04-023, provide all parties in the affected proceedings with due process.

16. The confidentiality procedures adopted in D.06-12-030, as clarified herein, provide for meaningful public participation and open decisionmaking, consistent with SB 1488, in all proceedings in which the rules adopted in this rulemaking apply.

17. The categorization of market participants and non-market participants is necessitated by the Legislature's mandate that we protect confidential market sensitive information. Thus, in order to protect electric customers, we are mandated to ensure confidentiality of that information from those engaged in market activities or commercial negotiations.

18. Our rules, as clarified herein, provide all parties in the affected Commission proceedings with a process to access the same information, and so there is no prospect that these rules will restrict any party's right to petition the Commission.

19. The confidentiality procedures adopted in D.06-12-030, as modified herein, particularly regarding clarifying the restrictions on Reviewing Representatives, are the least restrictive means to achieve the Commission's competing statutory obligations to ensure the confidentiality of market sensitive information by protecting against the possible misuse of that information by market participants and to ensure meaningful public participation and open decisionmaking in the affected proceedings.

20. . A 1 MW de minimis of energy threshold reasonably identifies entities whose participation in the electricity market may materially affect the market price of electricity.

21. There is no basis to determine what constitutes de minimis participation in the natural gas market, warranting modification of D.06-12-030.

22. D.08-04-023 should be limited to market sensitive information that is the focus of § 454.5(g) and this rulemaking.

23. D.06-12-030 provides that employees of market participants, whether the market participant is a trade association, an investor-owned utility, or an electric service provider, may not serve as Reviewing Representatives.

24. Members or employees of a consulting or legal firm whose clients include market participants should be permitted to serve as Reviewing Representatives to other market participants, so long as the Reviewing Representatives are separated by an ethics wall from members and employees of the firm who are engaged in knowingly providing electricity or gas marketing consulting or advisory services to others in connection with the purchase, sale or marketing at wholesale of electric energy or capacity or natural gas.

25. A market participant's Reviewing Representatives shall not participate in (a) a transaction for the purchase, sale, or marketing at wholesale of electrical energy or capacity or natural gas (or the direct supervision of any employee(s) whose duties include such activities), (b) the bidding on or purchasing of power plants (or the direct supervision of any employee(s) whose duties include such activities), or (c) knowingly consulting with or advising others in connection with any activity set forth in subdivisions (a) or (b) above (or the direct supervision of any employee(s) whose duties include such activities or consulting).

26. A Reviewing Representative of a market participant may not be an employee of a market participant, except, if in the course of a particular proceeding before the Commission, a market participant party believes that its employees must be given access, on a confidential basis, to market sensitive information, and that its right of full participation somehow will be unduly constrained by the general rule limiting access to outside counsel, consultants and experts, then such a party can file a motion with the decision-maker and seek an exemption from the general rule

27. The prohibition of access to market sensitive information by attorneys or consultants who simultaneously represent market and non-market participants is unnecessary for purposes of protecting against the disclosure of market sensitive information to an individual who engages in market activities, because a Reviewing Representative may not engage in wholesale market activities.

28. Until a new Model Protective Order is approved by the Commission, the terms of the Model Protective Order adopted by D.08-04-023, for use with market sensitive information, as defined by the process adopted in D.06-06-066 as modified by D.07-05-032 and subsequent decisions, in proceedings including Resource Adequacy , Procurement, Renewables Portfolio Standard, and offshoot or successor proceedings shall comply with this decision.

ORDER

IT IS ORDERED that:

29. Paragraph 2 of Section VI.B. of Decision 06-12-030, at pages 17-18, is deleted, and replaced with the following:

Market participants may designate as Reviewing Representatives outside experts, consultants or attorneys who meet the following criteria:

· Reviewing Representatives may not currently be engaged in (a) a transaction for the purchase, sale, or marketing at wholesale of electrical energy or capacity or natural gas (or the direct supervision of any employee(s) engagement in such a transaction),
(b) the bidding on or purchasing of power plants (or the direct supervision of any employee(s) engagement in such a transaction), or (c) knowingly providing electricity or gas marketing consulting or advisory services to others in connection with a transaction for the purchase, sale, or marketing at wholesale of electrical energy or capacity or natural gas or the bidding on or purchasing of power plants (or the direct supervision of any employee(s) engagement in such a transaction or consulting).

· Reviewing Representatives may not be an employee of a market participant. If the market participant chooses to retain outside attorneys, consultants, or experts in the same law firm or consulting firm to provide advice in connection with marketing activities, then the attorney, consultant, or expert serving as a reviewing representative under our confidentiality rules must be separated by an ethics wall (of the kind used by law firms to manage conflict-of-interest situations among different clients) from those in the firm who are involved in wholesale commercial dealings.

· Reviewing Representatives shall use market sensitive data only for the purpose of participating in an affected Commission proceeding, and Reviewing Representatives are permitted to participate in regulatory proceedings on behalf of market participants.

· Reviewing Representatives shall abide by these confidentiality rules.

30. Decision 06-12-030 is further modified as follows:

a. The third sentence in the third paragraph on page 31 in Section IX.E.2 entitled "Discussion" is deleted so the paragraph is modified as follows:

"It is true that EPUC's members are large energy consumers, but many of them are also active in the natural gas market. Many categories of data relating to natural gas are deemed confidential in the Matrix accompanying D.06-06-066."

b. The first word in the first sentence of the subsequent paragraph ("Moreover") on page 31 is deleted and the final three sentences of the paragraph are deleted, and the modified paragraph is as follows:

"EPUC, represents the interests of bundled purchasers of power to serve on-site and end-use customers, and is not presumed to be a market participant."

c. The first full paragraph on page 32 is modified as follows:

"Moreover, an association representing cogenerators or customer generation interests of oil and gas companies as a whole may have more ability to materially affect the market price of electricity than an individual company acting alone."

d. Section VII ("Attorneys and Consultants Who Work for Both Market Participants and Non-Market participants") beginning on page 18, is deleted in its entirety.

e. Section XII.F ("Attorneys/Consultants") beginning on page 45, is deleted in its entirety.

f. Conclusion of Law 5 is deleted in its entirety.

g. Conclusion of Law 6 is modified to delete subsections (b) and (c) and add in their place:

"and, b) an association representing cogeneration or customer cogeneration interests of oil and gas companies as a whole may have more ability to materially affect the market price of electricity than an individual company acting alone."

h. Ordering Paragraph 5 is deleted in its entirety, and replaced as follows:

"Market participants may designate as Reviewing Representatives outside experts, consultants or attorneys who meet the following criteria:

· Reviewing Representatives may not currently be engaged in (a) a transaction for the purchase, sale, or marketing at wholesale of electrical energy or capacity or natural gas (or the direct supervision of any employee(s) engagement in such a transaction),
(b) the bidding on or purchasing of power plants (or the direct supervision of any employee(s) engagement in such a transaction), or (c) knowingly providing electricity or gas marketing consulting or advisory services to others in connection with a transaction for the purchase, sale, or marketing at wholesale of electrical energy or capacity or natural gas or the bidding on or purchasing of power plants (or the direct supervision of any employee(s) engagement in such a transaction or consulting).

· Reviewing Representatives may not be an employee of a market participant. If the market participant chooses to retain outside attorneys, consultants, or experts in the same law firm or consulting firm to provide advice in connection with marketing activities, then the attorney, consultant, or expert serving as a reviewing representative under our confidentiality rules must be separated by an ethics wall (of the kind used by law firms to manage conflict-of-interest situations among different clients) from those in the firm who are involved in wholesale commercial dealings.

· Reviewing Representatives shall use market sensitive data only for the purpose of participating in an affected Commission proceeding, and Reviewing Representatives are permitted to participate in regulatory proceedings on behalf of market participants.

· Reviewing Representatives shall execute the nondisclosure agreement adopted in this proceeding, and shall be at all times in compliance its provisions.

i. Ordering Paragraph 6 of Decision 06-12-030 is deleted in its entirety.

31. Hydrogen Energy International LLC's July 13, 2009, motion to become a party is granted.

32. In circumstances where a Reviewing Representative is an employee or member of a firm that is also advising clients on energy marketing at wholesale and related services, the firm is to establish an ethics wall that incorporates the following standards:

· When reviewing or discussing any market sensitive data, the Reviewing Representative and those working with him/her shall employ all reasonable steps to ensure a physical separation from firm personnel who are not authorized Reviewing Representatives;

· The Reviewing Representative shall be responsible for informing all firm personnel about the existence and terms of the Commission's confidentiality rules, and in particular the prohibition against sharing market sensitive information with market participants; and

· The Reviewing Representative shall take all reasonable steps necessary to ensure that market sensitive information and files, including electronic files, are not accessible to firm personnel who are not authorized Reviewing Representatives.

33. The Model Protective Order adopted by Decision 08-04-023 should be amended to conform with the modifications adopted by this decision.

34. The parties shall convene a collaborative process designed to achieve consensus versions of an updated version of the Model Protective Order, as well as a Model Nondisclosure Agreement for use with confidential documents governed by this proceeding. The utilities thereafter shall submit these documents via joint Advice Letter for Commission approval by Resolution.

35. This order is effective today.

Dated July 14, 2011, at San Francisco, California.

I abstain.

APPENDIX A

BEFORE THE PUBLIC UTILITIES COMMISSION

OF THE STATE OF CALIFORNIA

Order Instituting Rulemaking to Implement Senate Bill No. 1488 (2004 Cal. Stats., CH. 690 (Sept. 22, 2004)) Relating to Confidentiality of Information

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)

Docket No. 05-06-040

MODEL NONDISLOSURE AGREEMENT

REGARDING MARKET SENSITIVE INFORMATION

A. The term "Market Sensitive Information" means market sensitive information as determined by the Disclosing Party in accordance with the provisions of D.06-06-066 and subsequent decisions, or (ii) any other materials that are made subject to this Nondisclosure Agreement by agreement of the parties or by order of the Assigned ALJ, Law and Motion Administrative Law Judge ("Law and Motion ALJ"), Assigned Commissioner, the Commission, or any court or other body having appropriate authority. Market Sensitive Information also includes memoranda, handwritten notes, spreadsheets, computer files and reports, and any other form of information (including information in electronic form) that copies, discloses, or compiles other Market Sensitive Information or from which such materials may be derived (except that any derivative materials must be separately shown to be Market Sensitive Information). Market Sensitive Information does not include: (i) any information or document contained in the public files of the CPUC or any other state or federal agency, or in any state or federal court; or (ii) any information that is public knowledge, or which becomes public knowledge, other than through disclosure in violation of this Nondisclosure Agreement or any other nondisclosure agreement or protective order.

B. The term "redacted" refers to situations in which Market Sensitive Information in a document, whether the document is in paper or electronic form, has been covered, blocked out, or removed. The term "unredacted" refers to situations in which the Market Sensitive Information in a document, whether in paper or electronic form, has not been covered, blocked out, or removed.

C. The term "Disclosing Party" means a party who initially discloses any specified Market Sensitive Information in this proceeding.

D. The term "Market Participant" ("MP") refers to a party that is:

1) A person or entity, or an employee of an entity, that engages in the wholesale purchase, sale or marketing of energy or capacity, or the bidding on or purchasing of power plants, or bidding on utility procurement solicitations, or consulting on such matters, subject to the limitations in 3) below.

2) A trade association or similar organization, or an employee of such organization,

a) whose primary focus in proceedings at the Commission is to advocate for persons/entities that purchase, sell or market energy or capacity at wholesale; bid on, own, or purchase power plants; or bid on utility procurement solicitations; or

b) a majority of whose members purchase, sell or market energy or capacity at wholesale; bid on, own, or purchase power plants; or bid on utility procurement solicitations; or

c) formed for the purpose of obtaining market sensitive information; or

d) controlled or primarily funded by a person or entity whose primary purpose is to purchase, sell or market energy or capacity at wholesale; bid on, own, or purchase power plants; or bid on utility procurement solicitations.

3) A person or entity that meets the criteria of 1) above is nonetheless not a market participant for purpose of access to market sensitive data unless the person/entity seeking access to market sensitive information has the potential to materially affect the price paid or received for electricity if in possession of such information. An entity will be considered not to have such potential if:

a) the person or entity's participation in the California electricity market is de minimis in nature. In the resource adequacy proceeding (R.05-12-013) it was determined in D.06-06-064 § 3.3.2 that the resource adequacy requirement should be rounded to the nearest megawatt (MW), and load serving entities (LSEs) with local resource adequacy requirements less than 1 MW are not required to make a showing. Therefore, a de minimis amount of energy would be less than 1 MW of capacity per year, and/or an equivalent of energy; and/or

b) the person or entity has no ability to dictate the price of electricity it purchases or sells because such price is set by a process over which the person or entity has no control, i.e., where the prices for power put to the grid are completely overseen by the Commission, such as subject to a standard offer contract or tariff price. A person or entity that currently has no ability to dictate the price of electricity it purchases or sells under this section, but that will have such ability within one year because its contract is expiring or other circumstances are changing, does not meet this exception; and/or

c) the person or entity is a cogenerator that consumes all the power it generates in its own industrial and commercial processes, if it can establish a legitimate need for market sensitive information.

E. A Market Participant's Reviewing Representatives are limited to persons designated by the Market Participant who meet the following criteria:

· Reviewing Representatives may not currently be engaged in (a) a transaction for the purchase, sale, or marketing at wholesale of electrical energy or capacity or natural gas (or the direct supervision of any employee(s) engagement in such a transaction),
(b) the bidding on or purchasing of power plants (or the direct supervision of any employee(s) engagement in such a transaction), or (c) knowingly providing electricity or gas marketing consulting or advisory services to others in connection with a transaction for the purchase, sale, or marketing at wholesale of electrical energy or capacity or natural gas or the bidding on or purchasing of power plants (or the direct supervision of any employee(s) engagement in such a transaction or consulting).

· Reviewing Representatives may not be an employee of a market participant. If the market participant chooses to retain outside attorneys, consultants, or experts in the same law firm or consulting firm to provide advice in connection with marketing activities, then the attorney, consultant, or expert serving as a Reviewing Representative under our confidentiality rules must be separated by an ethics wall (of the kind used by law firms to manage conflict-of-interest situations among different clients) from those in the firm who are involved in wholesale commercial dealings.

· Reviewing Representatives shall use market sensitive data only for the purpose of participating in an affected Commission proceeding, and Reviewing Representatives are permitted to participate in regulatory proceedings on behalf of market participants.

· Reviewing Representatives shall execute the NDA adopted in this proceeding, and shall be at all times in compliance its provisions.

F. Persons or entities that do not meet the definition of market participant are non-market participants ("NMPs"), and may have access to market sensitive information through their designated Reviewing Representatives.

H. All Reviewing Representatives are required to execute a non-disclosure agreement and are bound by the terms of this Nondisclosure Agreement.

All materials so designated shall be treated as Market Sensitive Information unless and until (a) the designation is withdrawn pursuant to Paragraph 16 hereof, or (b) an ALJ, Commissioner or other Commission representative makes a determination pursuant to Paragraph 4 hereof changing the designation.

All documents containing Market Sensitive Information that are tendered for filing with the Commission shall be placed in sealed envelopes or otherwise appropriately protected and shall be tendered with a motion to file the document under seal pursuant to Rule 11.4 of the Commission's Rules of Practice and Procedure. All documents containing Market Sensitive Information that are served on parties shall be placed in sealed envelopes or otherwise appropriately protected and shall be endorsed to the effect that they are served under seal pursuant to this Nondisclosure Agreement. Such documents shall be served upon Reviewing Representatives, and persons employed by or working on behalf of the Commission. Service upon the persons specified in the foregoing sentence may either be (a) by electronic mail in accordance with the procedures adopted in this proceeding, (b) by facsimile, or (c) by overnight mail or messenger service. Whenever service of a document containing Market Sensitive Information is made by overnight mail or messenger service, the Assigned ALJ shall be served with such document by hand on the date that service is due.

(a) 11. Return or Destruction of Market Sensitive Information. Market Sensitive Information shall remain available to Reviewing Representatives until the later of the date that an order terminating this proceeding becomes no longer subject to judicial review, or the date that any other Commission proceeding relating to the Market Sensitive Information is concluded and no longer subject to judicial review. If requested to do so in writing after that date, the Reviewing Representatives shall, within fifteen days of such request, return the Market Sensitive Information (including Notes of Market Sensitive Information) to the Participant that produced them, or shall destroy the materials, except that copies of filings, official transcripts and exhibits in this proceeding that contain Market Sensitive Information, and Notes of Market Sensitive Information may be retained, if they are maintained in accordance with Paragraph 8. Within such time period each Reviewing Representative, if requested to do so, shall also submit to the Disclosing Party an affidavit stating that, to the best of its knowledge, all Market Sensitive Information and all Notes of Market Sensitive Information have been returned or have been destroyed or will be maintained in accordance with Paragraph 8. To the extent Market Sensitive Information is not returned or destroyed, it shall remain subject to the Nondisclosure Agreement. In the event that a Reviewing Representative to whom Market Sensitive Information is disclosed ceases to be engaged to provide services in this proceeding, then access to such materials by that person shall be terminated. Even if no longer engaged in this proceeding, every such person shall continue to be bound by the provisions of this Nondisclosure Agreement and the Non-Disclosure Certificate.

REQUESTING PARTY

By: _____________________________ Title: __________________________ _

Representing: _____________________

Date: __________________________ _

DISCLOSING PARTY

By: _____________________________

Title: __________________________ _

Representing: _____________________

Date: __________________________ _

_____

ATTACHMENT TO MODEL NONDISCLOSURE AGREEMENT

BEFORE THE PUBLIC UTILITIES COMMISSION

OF THE STATE OF CALIFORNIA

Order Instituting Rulemaking to Implement Senate Bill No. 1488 (2004 Cal. Stats., CH. 690 (Sept. 22, 2004)) Relating to Confidentiality of Information

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)

Docket No. 05-06-040

NON-DISCLOSURE CERTIFICATE

I hereby certify my understanding that access to Market Sensitive Information is provided to me pursuant to the terms and restrictions of theNondisclosure Agreement between [REQUESTING PARTY] and [DISCLOSING PARTY] in this proceeding, that I have been given a copy of and have read the Nondisclosure Agreement, and that I agree to be bound by it. I understand that the contents of the Market Sensitive Information, any notes or other memoranda, or any other form of information that copies or discloses Nondisclosure Agreement shall not be disclosed to anyone other than in accordance with that Nondisclosure Agreement. I acknowledge that a violation of this certificate constitutes a violation of an order of California Public Utilities Commission.

By: _____________________________

Title: __________________________ _

Representing: _____________________

Date: __________________________ _

Signed: _______________________

Name ________________________

Title: _________________________

Organization: __________________

Dated: ________________________

(END OF APPENDIX A)

APPENDIX B

Title:_______________________

Representing:________________

Date_______________________

Title:______________________

Representing:_______________

Date:______________________

(END OF APPENDIX B)

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