8. Discussion
The issues argued in the hearing involved two primary areas: Suburban's relationship and cost allocations associated with its parent company, Southwest; and, the differences between DRA and Suburban for projected expenses and costs (for Southwest and Suburban).
Below is a discussion of key Southwest-related issues, followed by a discussion of Suburban-related issues. Included are discussions of the issues in dispute with respect to the calculations of expenses and costs. We do not discuss all issues related to expenses, as we generally find that DRA's arguments are not persuasive to the extent necessary to disallow any of Suburban's projected expense or cost data, and that most of the data presented by DRA was unsubstantial, and not fully analyzed with respect to Suburban's positions on the specific issues.
Moreover, in our view both parties spent an excessive amount of time and effort in their pleadings and briefs alleging unsubstantiated errors and attempting to discredit the other party's witnesses. In future proceedings, the parties are advised to limit these types of activities, and focus more time and effort on meaningful settlement discussion and a more objective argument of the facts.
8.1. Southwest (Parent Company) Issues
In its application, Suburban showed its relevant transactions with Southwest (and the Utility Group), and to the best extent possible made these transactions open and transparent.
Unlike the rules for electric utilities, however, the Commission currently does not have any general rules in place governing affiliate transactions with respect to water utilities. Many of DRA's objections in this proceeding are based on Suburban's relationship with Southwest, but also on scenarios, suppositions and implications of that relationship that may or may not actually exist.
We understand DRA's concerns. However, without specific rules in place we find it difficult to accept DRA's recommendations or arguments on these matters.
8.1.1. Affiliate Transaction Rules
In 1975, Southwest requested Commission authority to purchase Suburban (Application 55655). At the time, both Southwest and Suburban were regulated water utilities. In its application, Southwest stated its intention to consolidate its California water utility operations, and that Suburban would remain as a certificated utility. The Commission approved this transaction in Decision (D.) 84466 (1976), but the decision did not authorize Suburban or Southwest to form a holding company.
In view of the parent/subsidiary relationship between Southwest and Suburban that now exists, DRA recommends that the Commission direct Suburban to file an application for authority to establish a holding company, and consolidation of its California utilities, and further to institute affiliate transaction rules for Suburban. DRA cites other cases where similar rules have been required of other water companies.6
Suburban argues that the Southwest/Suburban transaction was approved over 30 years ago; that Suburban since has filed many formal requests for rate increases and other matters; and, that its parent/subsidiary relationship with Southwest has been transparent and known during this entire time. Suburban also argues that all of the similar affiliate cases involving water companies cited by DRA were the result of settlements; and, pursuant to Rule 12.5, that adoption of a settlement does not constitute approval or precedent in any future proceeding.
Lastly, Suburban argues that any effort to establish affiliate transaction rules for water utilities, other that case-specific settlements, should be the result of a rulemaking opened for that purpose.
Considering the above issues, we direct Suburban to file a formal application, within 120 days of the effective date of this order, requesting authority to establish a holding company, and related matters. We find, however, that it is unreasonable to direct Suburban to institute affiliate rules in this proceeding, and agree with Suburban that these issues are better suited for an industry-wide rulemaking proceeding. Accordingly, the Commission will open a rulemaking in the near future addressing California water utility affiliate transaction issues, along with the "excess capacity" issues discussed below.
The Commission established the "Four Factor Method" (FFM) in 1956 for the purpose of setting forth procedures to determine the allocation of expenses and common utility plant among "departments, districts and states."7 The four factors are: Direct Operating Expenses; Gross Plant; Number of Employees; and, Number of Customers.
Suburban used the FFM in determining the expense allocations for Suburban, itself, and for Southwest and the Utility Group. DRA argues that Suburban improperly calculated its expense allocations for Southwest by misapplying three of the four factors (Number of Customers, Number of Employees, and Gross Plant), and as a result Suburban's actual expenses were misstated. DRA further argues that in the past the Commission has modified the application of the four factors when found necessary.
Suburban argues that it followed the Commission's precedent and guidelines regarding the FFM by using all four of the expense elements, and as a result the data shown in its application related to the number of employees and number of customers reflects the actual numbers for each element for both Suburban and Southwest. Suburban further argues that the applicability of the FFM to "departments, districts and states" should be construed as including parent and affiliate companies.
We agree with Suburban in this regard. Absent specific rules, we find that Suburban correctly applied the FFM, and further that DRA did not demonstrate why the entire FFM should not be used in this case.
8.1.3. Domestic Production Activities Deduction
The DPAD is part of the American Jobs Creation Act of 2004,8 which amended the Internal Revenue Code to allow certain tax deductions for income attributable to domestic production activities. It includes income from sales of potable water. However, the DPAD cannot be taken if the company experiences a loss for tax purposes.
Suburban files a consolidated joint tax return with Southwest. They have not claimed a DPAD as they have shown an overall loss on their recent returns. DRA argues that if Suburban were a stand-alone company it would realize a profit, and therefore be eligible for a DPAD; and, that any benefits from a DPAD could be passed along to customers.
In D.84-05-036, the Commission determined certain policies with respect to the impacts on ratemaking of the income tax expenses of affiliated entities. DRA argues the Commission concluded in that decision that using a stand-alone method is appropriate. Suburban argues that DRA misinterprets D.84-05-036 in this regard as the decision states:
The consolidated tax return of the utility and its affiliates is measured by the algebraic sum of the taxable income that each member contributes to the consolidated return. If any member has negative taxable income, the taxes paid by the consolidate group will result in an effective tax rate less than the statutory rate.
Suburban concludes that in determining the stand-alone taxable income for a utility (such a Suburban), the Commission should not consider any deductions or income from which the parent company can never benefit. Here, we agree with Suburban and find it is unnecessary to direct the imputation of a supposed, non-existent deduction. However, we also note here that the policies the Commission established in 1984 (20 years prior to the DPAD) are not entirely clear in this regard, and that updating and clarifying these issues may be necessary.
8.1.4. Southwest and Utility Group Expenses
DRA and Suburban argue over various issues with respect to the expenses of Southwest and of the Utility Group.
The only Utility Group issue is computer costs. Suburban argues that DRA failed to account for a Microsoft licensing agreement that began in May, 2007. We agree with Suburban in this regard and find the expense reasonable.
The parties disagree on several issues with respect to Southwest expenses. Suburban asserts these differences generally are the result of it switching its RCP from a fiscal-year to a calendar-year basis, and that many of its forecasts were based on actual expenses through July 2007, and estimates for the remainder of the year.
One of these expense matters is the allocation of costs of performing audits required by the Sarbanes-Oxley Act (SOX), the Public Company Accounting Reform and Investor Protection Act of 2002 enacted in response to the collapse of Enron and other public companies. SOX established standards and reporting requirements for all public companies. It does not apply to privately held companies. The parties argue over the allocation of expenses related to SOX compliance, particularly since Suburban is a private company and Southwest is public. DRA asserts that SOX compliance costs should be disallowed for Suburban. Suburban argues that SOX compliance benefits the utility and its customers, as well as the parent company.
We generally allow rate recovery of SOX compliance expenses.9 We agree with Suburban and will allow its expenses attributable to SOX compliance. Other matters with respect to Southwest expenses include:
Southwest payroll: Suburban based its payroll on actual expenses through July 2007, and estimated the difference for the remainder of the year. Both DRA and Suburban found minor errors in their initial calculations. Suburban satisfactorily corrected these errors at the EH. As a result of these corrections, the authorized overall rate increase for 2009 was reduced from 11.08%, the increase Suburban requested pursuant to the settlement agreement, to 11.01%.
Payroll taxes: The differences in payroll taxes are related to the payroll estimates discussed above.
Employee Welfare: For Test Year 2009, Suburban requests $264,254 for employee welfare expense, while DRA recommends $86,093. DRA removes all employee welfare expenses except vacation, while Suburban includes additional elements such as transit reimbursement, parking, and educational expenses. We agree with Suburban and adopt its estimates for employee welfare expenses.
Worker's Compensation: Suburban did not include any estimates for Southwest's worker's compensation as Southwest allocates this expense through it operating companies. DRA recommends that $45,160 be included for worker's compensation for Test Year 2009. DRA's recommendation would result in a double-allocation of these costs, and we therefore agree with Suburban that it should not include this expense in its estimate.
Pension Expense: For Test Year 2009, Suburban estimates $195,000 and DRA $121,265 for pension expenses. Suburban's estimate is based on calendar year 2007, while DRA bases its estimate on 2006 data. Suburban's data is more recent, and we therefore adopt it here.
SFAS No. 123 Compensation Expense: DRA recommends that Suburban's request for Southwest's SFAS No. 123 stock compensation be disallowed. DRA states the SFAS program solely benefits executives involved in implementation of SOX compliance, and that Suburban excluded this expense in its previous GRC. Suburban agues that at the time of the prior GRC filing, SOX compliance was a relatively new regulation; and, that since SOX compliance has been fully implemented it now should be considered as an ordinary cost of doing business. Suburban further argues that stock awards and incentive programs apply to many levels of management, not just those involved in SOX compliance; that stock-based compensation is an essential part of overall executive compensation; and, that ratepayers benefit when executives attempt to reach performance objectives. We agree with Suburban and will allow allocation of Southwest's stock compensation expenses to Suburban.
ESPP Expense: The ESPP is available to all employees. Suburban requests $42,747 for ESPP expenses, while DRA recommends the expense be disallowed altogether. The program benefits customers by increasing employee retention and by raising equity capital. As with other expense items, Suburban developed its Test Year 2009 estimate based on actual expenses from January through July of 2007, and forecasted expenses for the remainder of the year. Also as with other expense items, we find that Suburban's approach is reasonable here and adopt its estimate of $42,747 for Test Year 2009.
Legal Fees: Suburban estimates $631,603 for legal fees for Test Year 2009, while DRA's estimate is $191,828. DRA based its estimate on Suburban's previous GRC from 2005 which was adopted as a result of a settlement between the parties. Suburban argues that the legal fees have increased due to the increased costs of being a public company, and other new developments such as the implementation of SOX; and, that Commission rules prohibit the use of settled matters, such as the 2005 GRC, to apply in subsequent rate cases. We agree with Suburban and adopt its estimate for legal fees.
Audit/Accounting Fees: Suburban estimated $1,421,106 for Test Year 2009. DRA used the same method in its estimate here as it did for legal fees, above. We adopt Suburban's estimate for the same reasons.
Annual Report: Suburban estimated $162,111 for Annual Report expenses, while DRA estimated $134,741. DRA did not provide any testimony on the issue in support of its position. We adopt Suburban's estimate.
Annual Meeting / 10-K Filing: Suburban estimated $134,732, while DRA estimated $63,582. DRA used a five-year average, and also compared Suburban's current estimate to its 2005 GRC filing. Suburban's estimate is more current, and therefore more accurate, and we adopt it here.
Shareholder Relations: Suburban estimated $100,004 for this expense, while DRA estimated $37,788. Similar to Annual Report expenses, DRA did not justify its estimate, and we therefore adopt Suburban's estimate.
Computer and IT Services Fees: Suburban estimates $798,777 for this expense, while DRA estimates $199,717. DRA argues that Suburban is violating affiliate transaction rules, and also disagrees with Suburban's cost methodology. We addressed the affiliate transaction issue earlier. With respect to cost methodology, DRA based its estimate on Suburban's 2005 GRC and also did not consider the increased costs associated with SOX compliance. We agree with Suburban and adopt its estimate.
Rent: Suburban estimated $191,446 for rent expense, while DRA estimated $152,405. DRA developed its estimate from forecasts from the 2005 GRC. Suburban's estimate reflects actual contracted rental amounts, considered its move from Covina to Los Angeles, and further adjusted on the ratio of Southwest parent company employees requested in this proceeding. We agree with Suburban's methodology and adopt its estimate.
Machine Rental: Suburban estimates $88,424 for machine rental for Test Year 2009, while DRA estimates $7,257. Similar to previous expense issues, DRA based its estimate on forecasted amounts from the 2005 GRC, while Suburban's estimate reflected actual expenses. We adopt Suburban's estimate
Property Taxes: Suburban estimated $28,422 for property taxes for Southwest, while DRA recommends $8,251. DRA based its recommendation on a five-year average. Suburban showed that the actual property tax expense for the first seven months of 2007 was approximately $16,000, and, unlike DRA, accounts for Southwest's new office location. We adopt Suburban's estimate.
Insurance (Auto): Southwest is self-insured and provides insurance to Suburban. Suburban also purchases additional auto insurance for coverage below the $150,000 deductible amount provided by Southwest. Suburban pays a premium to Southwest for the additional coverage. For 2007-2008, the premium is $191,625. DRA recommends the premium be treated as a credit, arguing that Suburban's estimates for insurance have been higher than its actual expenses, and that Southwest allocated premiums to its various affiliates based on the alleged over estimates. We disagree with DRA regarding the treatment of this expense and adopt Suburban's estimate.
Broker Fee: as part of its auto insurance coverage, Suburban paid an additional $19,800 to Southwest as a broker fee. DRA similarly recommends this be treated as a credit. We adopt Suburban's estimate.
Tax Deductible Travel and Entertainment: Suburban estimates $275,970 for this expense, while DRA recommends $166,420. Similar to other expense items, DRA uses a five-year average while Suburban uses 2007 expenses. Suburban's estimate is more current and we adopt its estimate.
Outside Services: Suburban estimates $924,245 for outside services, while DRA estimates $493,344. DRA used a three-year average while Suburban used 2007 expenses. We adopt Suburban's estimate.
Recruiting: Suburban estimates $236,851, while DRA estimates $66,130 for recruiting expenses. Suburban used 2007 expenses, and also reflected the hiring of new and replacement staff. DRA's estimate is lower than any actual expense level for this category recorded since 2002. Unless there is proof that expenses are going down, or that limited hiring of people in the test year is reasonable, DRA's position makes no sense. Suburban's estimate better reflects future costs and we adopt it here.
Line of Credit Fees: Suburban estimates $105,267, while DRA estimates $59,966. DRA use a four-year average, and Suburban used 2007 expenses. The most recent data will provide the most accurate forecast. We adopt Suburban's estimate.
8.2. Suburban Issues
The following issues pertain to Suburban (wholly, or for the most part).
Project Cornerstone is a future project that will unify the information systems of Suburban and Southwest, and also allow Suburban to institute an on-line customer billing process. Southwest is coordinating the project, but both entities, and Suburban's customers, will realize benefits.
Suburban estimates the project will be in place within the next two years, before its next general rate case is filed in 2011. Currently, design and costs estimates for the project are still being developed and Suburban has no useful data to include in this proceeding. Here, Suburban is requesting authorization to track the costs related to the project in a memorandum account, then file a Tier-3 Advice Letter at a later date for recovery of the costs.
DRA objects to the Advice Letter process for the project alleging that Suburban: has not established the need for the project; may be unwilling to allow the necessary level of discovery in an Advice Letter process; already has included project related costs in the subject proceeding; and, made no witnesses on the subject available for cross-examination at the EH held in this matter. DRA instead recommends that Suburban be required to file a new formal application at the time all the details and data have been developed, allowing for a more thorough review of the matter as compared to an abbreviated review associated with an Advice Letter. DRA also states this issue is outside the scope of this proceeding. The Scoping Memo indicates the issue is within the proceeding scope.
Commission General Order (GO) 96-B governs the filing of Advice Letters. Section 3.1 of the GO defines an Advice Letter as "... an informal request by a utility for Commission approval, authorization, or other relief, including an informal request for approval to furnish service under rates, charges, terms or conditions other than those contained in the utility's tariffs then in effect..." Section 3.7 further defines an informal matter as "...either an uncontested matter or a matter for which a hearing is not required in order to resolve the contested issues."
Though we do not agree necessarily with all of DRA's contentions regarding the use of an Advice Letter in this case, it is clear the matter is not "uncontested." Further, because no meaningful data for the project is yet available, it is difficult to determine whether a hearing will be required to approve the project for ratemaking purposes.
Suburban is directed here to track Project Cornerstone costs in a memorandum account. However, we find that the matter is premature, and will not authorize Suburban to utilize the Advice Letter process at this time to recover those costs. Instead, Suburban and DRA are directed to meet and confer informally on this issue prior to the filing of any request to recover these costs. The parties may meet/confer themselves, or request a mediation conference through the Commission's ADR program. If the parties agree, Suburban may file a request to recover these costs through an Advice Letter. If no agreement is reached, Suburban shall file a formal application for that purpose.
Suburban is requesting authorization in this proceeding to add four new positions (named below) to its payroll. DRA argues that all four positions are unwarranted. After considering Suburban's request and DRA's opposition, we find that all four positions are necessary, for the reasons discussed below, and authorize Suburban to add these positions to its payroll.
Water Quality Conservation Coordinator.
Suburban requests this position for the following reasons:
· One of the primary objectives of the Water Action Plan is to strengthen water conservation programs. This position, in part, will assist Suburban in achieving its objectives.
· Order Instituting Investigation (OII) 07-01-022 was opened to consider policies designed to achieve conservation objectives for Class A water utilities. In Phase 1 of that proceeding, Suburban and DRA developed a complex rate design to encourage water conservation, which the Commission approved in D.08-02-036. The ongoing second phase of this proceeding will address non-rate design conservation measures. The conservation coordinator will allow Suburban to continue work in this area at the necessary levels.
· The Commission urges all Class A water companies to become members of the California Urban Water Conservation Council (CUWCC) - and to comply with the council's "Best Management Practices" (BMP), and the BMP directs that each utility designate a Water Conservation Coordinator.
· In Executive Order S-06-08, the Governor declared a statewide drought, and further encouraged water agencies and districts to work cooperatively at the regional and state level to take immediate action to reduce water consumption in 2008 and 2009. Suburban states the coordinator position is necessary in order to respond to current and possible future drought conditions.
DRA argues that some of this work can be performed by outside sources. However, we agree with Suburban for the reasons stated above and authorize this position.
Supplier Diversity Coordinator
In 2004, Suburban and other water utilities signed a Memorandum of Intent to voluntarily commit to improving supplier diversity. In its 2006 report to the legislature on supplier diversity, the Commission noted that by statute, water utilities are not required to participate in a supplier diversity program, but nonetheless commended the voluntary efforts of the water utilities and urged those utilities to increase their efforts in this regard. Suburban states the coordinator position is necessary to continue this work.
DRA argues that Suburban should make use of the Commission's Diversity Clearinghouse10 to assist in these functions. Suburban argues that the primary purpose of the clearinghouse is to verify that potential suppliers actually qualify as Women Minority Disabled Veteran Business Enterprises, and not to assist utilities contracting vendors. We agree with Suburban, and authorize this position.
Information Technology (IT) Support Technician II
Suburban requests this position for the following reasons:
· Necessary support for personal computers.
· Support for Suburban's new automatic reading and updated mapping systems.
· Database maintenance of Suburban's geographical information system (GIS) and financial software systems, integration of the GIS with its customer information system, and other facilities maintenance.
Generally, the number of users of Suburban's system has increased only slightly. Suburban's justification of this position is not based on the number of additional users, but instead on the type and complexity of uses of the system. We agree with Suburban and authorize this position.
Benefits Analyst
Here, Suburban's request is not to add a new position, but to reassign a full-time position from Southwest to a three-quarter time position at Suburban. Suburban currently has no benefits analyst for its 100-plus employees. Transferring this partial position will allow Suburban employees to have face-to-face contact for benefit related matters. We also note that, for ratemaking purposes, Suburban will not be responsible for any of the costs that Southwest will incur to outsource this function at the parent company. We agree with Suburban and authorize this position.
Suburban Health Insurance: Suburban estimates its medical/dental insurance to be $1,063,891 for Test Year 2009. DRA's estimate is $855,780. The difference primarily is due to minor adjustments based on a headcount of employees estimated by Suburban. We agree with Suburban's adjustment and adopt its expense estimate.
Vacancy Rate: Suburban and DRA disagree on the utility's vacancy rate. In computing its vacancies, Suburban analyzed the number of positions, whether or not these positions were filled, and the salary trends of the people filling these positions at the end of 2007. DRA used the number of people employed, not positions, in its estimate. Suburban showed that it was fully employed (no vacancies) at the end of 2007 (all of its 111 authorized positions were filled). We adopt Suburban's estimate.
Water Quality Technicians: Suburban and DRA agreed on the need and number of these positions in the settlement, but disagreed on how the positions would be funded. DRA argument is based on its position, discussed above, that Suburban is under-hiring. We did not find that Suburban under-hired, and therefore adopt its expense estimate with respect to this category.
8.2.4. Residential Houseline Program
The RHP is an optional maintenance program for service and repairs on the customer property-side of Suburban's water meter. Suburban began this program in 2001. The customer typically owns the line, and the service includes monthly houseline inspections by meter-readers. Suburban now charges approximately $5/month for this service, and estimates the program will generate approximately $356,000/year, with 10%, or $35,600, being allocated to customers.
In D.00-07-018, in Rulemaking (R.) 97-10-049, the Commission determined that water utilities may use excess capacity for non-tariffed services, and split the revenues generated from "active" services 90-10 between the shareholders and the ratepayers. As defined in that decision, "active" projects include "customer facility related services, including maintenance contracts." Suburban argues the 90/10% split is appropriate here as the RHP is an "active" non-tariffed service.
DRA argues that the ratemaking treatment of all of the RHP revenues should be changed from the treatment of the last eight years. The argument is based upon their interpretation of D.07-12-055. They argue that this recent decision eliminates the ability of utilities to provide this service and receive the 90-10 sharing. Instead, DRA argues that RHP no longer qualifies as a "non-tariffed" service. DRA also has concerns with Suburban's cost-sharing methodology, reporting of annual and incremental costs associated with the RHP, and whether the RHP qualifies as an "active" project, as defined in D.00-07-018.
DRA asserts the RHP is more of an "insurance" service than a maintenance contract, as Suburban's customers are paying the monthly charge to insure against breakage, leaks, etc. Suburban argues that "maintenance" involves actions to prevent damage, while "insurance" involves payment for damage. D.00-07-018 defined maintenance contracts as a non-tariffed service eligible for the 10/90 sharing mechanism. DRA cites the language from D.07-12-055 which defined "maintenance" as "the upkeep, repair, and preservation of existing facilities" as justification for the change in authority.
In administering the RHP, Suburban defends its service as distinguishable from the "insurance" analogy when it claims that for this service offering it performs an initial analysis of the line; performs upkeep, repair and preservation of the line; repairs any breaks in the line; and, conducts a monthly status check.
DRA also argues that D.07-12-055 should apply here because Cal Water's ESP and Suburban's RHP are similar. DRA argues that both services are voluntary, assess an approximate $5/month fee, cover the water line on the customer property-side of the meter, and generally use utility personnel and equipment to provide the service.
Suburban argues that D.07-12-055 should not apply for two reasons: first, that the Commission limited the applicability of the Cal Water decision by stating "based on the record evidence in this proceeding, we are doubtful that an ESP-type service could ever satisfy the requirements of the excess-capacity rules"; and, second, that Suburban's RHP is different than Cal Water's ESP in that Cal Water was offering its ESP through contracts with its parent company, an un-regulated affiliate that administered the program, while Suburban would offer its RHP directly to its customers without involvement by its parent.
While DRA raises some valid points, the parallels with D.07-12-055 are not perfect. DRA's and Suburban's arguments do, however, raise questions about the relationship between the RHP program and the affiliate transaction issues discussed above.
Given the lack of affiliate rules for Suburban, we will allow Suburban to continue its RHP as "excess capacity" until greater clarity can be given to the excess capacity rules. We find that it is reasonable and timely to open a new rulemaking to revisit the rules on the use of regulated assets, for both tariffed and non-tariffed utility operations, by regulated water utilities. We anticipate that the scope of such rulemaking would include both "excess capacity" rules, and rules related to affiliate transactions, discussed earlier.
In view of the upcoming rulemaking, and the potential impacts of new rules, we direct Suburban to maintain a memorandum account to track the RHP until further notice.
Suburban and DRA settled most rate-base issues. Working Cash is the only issue remaining. Suburban's estimate for 2009 is $1.64 million, and DRA's estimate is $1.37 million. Though DRA adopted Suburban's calculation methodology in the settlement, the difference here is based on the other ancillary issues, such as Payroll, that have an impact on Working Cash. Since we agree with Suburban regarding the ancillary issues (previously discussed), we likewise agree with Suburban's estimates on Working Cash.
6 D.97-12-001, California Water Service Company; D.98-06-068, Southern California Water Company; and, D.02-12-068, California-American Water Company.
7 Subject Reference Memorandum H 32, Allocation of Administrative and General Expenses and Common Utility Plant, issued July 26, 1956.
8 H.R 4520 (2004), Section 102.
9 D.07-11-037, Golden State Water Company, 2007 Cal PUC Lexis, 648; and,
D.05-07-044, San Gabriel Valley Water Company, 2005, Cal PUC Lexis 295.
10 As defined in GO 156, Section 3, The Women Minority Disabled Veteran Business Enterprise (WMDVBE) Clearinghouse.
