XVII. Assignment of Proceeding
John A. Bohn is the assigned Commissioner and Robert Barnett is the assigned ALJ in this proceeding.
1. San Gabriel's forecast that its number of active service connections will increase at a rate of 1,350 new connections per year and its estimates of annual use by every customer class except for large industrial customers is adopted.
2. San Gabriel forecasts sales on a weather-normalized basis for most customer classes by applying the New Committee Method to recorded monthly sales over the last ten years. This forecast method is adopted.
3. DRA's estimate of test year sales to Cemex of 250,685 ccf is more reflective of Cemex's current and anticipated water use, and is adopted.
4. DRA's recommendation that sales to CSI be projected at 545,700 ccf, a level 283,140 ccf higher than San Gabriel's test year estimate, is adopted.
5. San Gabriel's approach to the allocation of the $116,909 received from US EPA is to amortize it over three years, increasing the water revenue account by $38,970 in the test year. San Gabriel's proposal is reasonable and is adopted.
6. A 6.2% unaccounted for water factor is adopted.
7. DRA has reached an agreement with San Gabriel that San Gabriel's proposed $8,509,500 water costs (177.88/AF) forecast for TY 2006-2007, is reasonable. However, as DRA has recommended an adjustment to increase the company's projected sales to CSI by 650 AF, DRA has also increased the projected purchase water costs by $115,622 (650 AF x $177.88/AF) to $8,625,122. DRA's recommendation is adopted.
8. Purchased power costs of $4,795,500, or $0.094782/kWh, forecast for TY 2006-2007 are reasonable and adopted. Purchased power costs go through a full cost balancing account.
9. An annual chemical expense of $637,410 for TY 2006-2007, is reasonable and adopted.
10. Using updated September 30, 2005 escalation factors, DRA's recommendations for materials and supplies expenses are: $142,300 for operations, $282,900 for maintenance and $40,300 for administrative and general expenses. These are adopted.
11. A TY 2006-2007 transportation expense of $619,323 is reasonable and adopted.
12. In projecting TY 2006-2007 postage expense, the company applied non-labor escalation rates as well as the 5.4% postage rate increase. It is adopted.
13. The maintenance expense element of outside services varies directly with the quantities of physical plant. San Gabriel increased to $187,100 the recorded year 2004 amount to reflect both increases in plant and non-labor escalation rates. San Gabriel's estimate is adopted.
14. San Gabriel estimated $287,795 in TY 2006-2007 for non-perchlorate related legal costs, based on a ten-year average expense level, inflated to 2004 dollars, then escalated to TY 2006-2007. To provide for the possibility of high fees we will adopt San Gabriel's estimate, but to also provide for the possibility of an average expense we require San Gabriel to create a memorandum account to record outside legal expenses, capped at $287,795 per year. Money not reasonably expended shall be returned to the ratepayers.
15. Perchlorate-related legal expenses are accounted for through the Water Quality Litigation Balancing Account and are not factored into base rates. This is reasonable and adopted.
16. San Gabriel has agreed to use the ECSB labor inflation rates, thereby reducing its proposed revenue requirement for TY 2006-2007 by about $330,000, while also agreeing to apply the September 2005 version of the ECSB escalation factors. We adopt the methodology and apply it throughout to our adopted expenses.
17. The 12 positions that were vacant as of November 14, 2005 shall be removed in determining TY 2006-2007 payroll expense as its normal to have some level of vacancies in any given period.
18. Of the 12 proposed new positions, we approve 11. We do not approve including in expenses one Water Treatment Operator III.
19. Step increase for employees shall be removed from expenses.
20. It is reasonable to substitute ECSB's September 2005 Labor Inflation Rates for San Gabriel's use of ECSB's June 2005 Compensation per Hour Index. This is adopted.
21. Vacation, holiday, and sick leave expenses are adjusted to reflect our adopted revision to payroll.
22. For 401(k) costs, we change the escalation factor from the Compensation per Hour Index to the Labor Inflation Rate and recalculate the expense based on our adopted revisions to payroll.
23. We modify the health and dental insurance expense to reflect the impact of our revisions to payroll.
24. San Gabriel's Business Property and Umbrella Liability Insurance expenses are adopted.
25. We modify San Gabriel's worker's compensation expense by adjusting for the payroll increase that we have adopted and by offsetting the expense by the three-year average of refunds received, $24,000 of which Fontana Division's portion is 38%. We will not adjust the Ex Mod factor.
26. San Gabriel's Regulatory Commission expense and amortization is adopted.
27. DRA's proposed uncollectible factor of 0.1951% is adopted, modified to reflect our projected revenue.
28. San Gabriel's incorporated franchise fee expenses based on a five-year recorded average franchise fee rate of 0.8091% is adopted.
29. The general office allocation costs are allocated between the Los Angeles Division and the Fontana Division based on a four-factor allocation formula. It is adopted.
30. The American Jobs Creation Act of 2004 provides for a deduction equal to 3% qualified production activities income in 2005 and 2006 and 6% of qualified production activities income in 2007 and 2008. As the applicable deduction is 3% for 2006 and 6% for 2007, we shall utilize an average deduction rate for TY 2006-2007 of 4.5%. San Gabriel has estimated the percentage of its net income applicable to production activities to be 51.9%, which we find reasonable and adopt.
31. San Gabriel shall compute its income tax expense to reflect the impacts of the 2004 Act.
32. Taxes Other Than Income include property and payroll taxes. San Gabriel and DRA agree on the amount for Other Taxes except for payroll. We adopt their recommendation but will use our independent findings on payroll.
33. The Fontana Division is confronted with increased demand throughout its service area as the result of rapid new development. Recognizing the need for an updated plan to address the growing demands on its water supply and distribution system, in October of 2003, San Gabriel prepared a comprehensive Water Master Plan.
34. The Master Plan addressed the rapid growth in the undeveloped northerly portions of Fontana Division's service area and additional industrial growth in the southerly areas, both of which will require new wells along with new reservoirs (for fire flow requirement and peak demand), booster pumps, and transmission and distribution pipelines to provide necessary flows at appropriate pressures.
35. The Master Plan estimates that approximately 25 mgd of additional groundwater supply is needed by the year 2010 in order to meet increased demands and to increase the reliability of the system. This estimate is reasonable.
36. The Master Plan recommends that the Company have redundant well capacity for at least three 2,000 gpm wells. The Master Plan recommends a total of eight new groundwater production wells (including three wells to provide redundant well capacity), each with a capacity of approximately 2,000 gpm, for a total capacity of approximately 16,000 gpm, be installed prior to 2010. This recommendation is reasonable.
37. The Master Plan concluded that the Fontana Division has a current deficiency of 19 mgd under drought conditions, requiring construction of new and replacement wells that will produce at least 25 mgd as well as construction of a seven mgd perchlorate treatment facility that will treat three contaminated wells, in order to overcome the current deficiency, meet year 2010 maximum day demands under drought conditions, and provide sufficient redundancy during emergency interruptions. We find this conclusion to be reasonable.
38. The Sandhill Surface Water Treatment Plant began operation in 1965. The plant relies on surface water diversions from Lytle Creek but often must be shut down when Lytle Creek has high levels of turbidity that exceed the current treatment capability of the Sandhill plant. The other source of supply for the Sandhill plant is State Water Project (SWP) water that must be blended with Lytle Creek surface water before it can be treated. These blending requirements restrict the capacity of the Sandhill plant to the availability of useable Lytle Creek surface flow. The required shutdown of surface water processing through the Sandhill plant has deprived the Fontana Division of thousands of acre feet of low-cost surface water, including over 25,000 acre feet just in the first five months of 2005.
39. The planned upgrades and pretreatment facilities will permit the Sandhill plant to treat 100% Lytle Creek surface water, 100% SWP water, or any blend of the two. This will restore the full usefulness of the Sandhill plant even when Lytle Creek surface water is unavailable or too muddy, because the plant will be able to process SWP water.
40. The Commission adopted a Water Action Plan on December 15, 2005, which contained various objectives expected to be implemented by the investor-owned water utilities.
41. The Sandhill plant upgrade project is expected to cost approximately $35 million, to which must be added staffing and maintenance. San Gabriel's TY 2006-2007 rate base includes $12 million already expended on the Sandhill plant.
42. The Sandhill plant is cost effective and it is reasonable to construct it. The cost of construction shall be reviewed in the next GRC or by application, whichever occurs sooner.
43. For new construction the most equitable way to provide recovery in rates is to continue the solution found reasonable in D.04-07-034 to limit rate base growth to 10% per year, excluding the ratebase additions caused by the Sandhill plant upgrade. We are not disposed to dictate to San Gabriel which plant will be constructed in which order; that is a management decision.
44. New wells are needed to meet the demands of new customers; new customers should be contributing to provide the plant necessary to serve them.
45. The cost of the treatment facility at Plant F-25 should be treated as CIAC, if the company recovers funds from its contamination lawsuits.
46. San Gabriel has not emphasized developer funds to provide new facilities for new customers. The need for plant arises not only to serve current ratepayers, but also to serve new customers. New customers should contribute new facilities. We need not decide at this time which facilities will serve new customers.
47. San Gabriel should install a replacement 10,000 gpm CVWD interconnection to maximize deliveries during emergencies.
48. To construct a new office/warehouse, San Gabriel acquired 4.81 acres for the new facility, on December 30, 2004 for $1,102,233 from Rosemead Properties Inc. (Rosemead), an affiliate company of San Gabriel. The acquired parcel was part of an 8.72 acres parcel originally acquired by Rosemead on July 8, 2003 for $1,075,000.
49. Rosemead is owned by United Resources, Inc. (United Resources.) United Resources also owns San Gabriel. Rosemead purchased the property during the time that San Gabriel was seeking land on which to construct a new office building. The land was expected to go into rate base. When the land was sold by Rosemead to San Gabriel in December 2004 it occurred without any negotiation regarding price.
50. We will allow $591,250 in rate base calculated on the ratio of the size of the parcel Rosemead sold to San Gabriel to the size of the larger parcel of which it was part. We find that San Gabriel should have been charged 55% of $1,075,000, or $591, 250 for the land. This abuse of an affiliate transaction is particularly egregious.
51. In regard to the new office/warehouse, San Gabriel should remove the facilities that are to be replaced from ratebase immediately upon the occupation of a new headquarters building.
52. We would expect a higher CWIP for TY 2006-2007 because of the major projects under construction. We find that the Company's CWIP estimate is probably low, but reasonable. We specifically allow up to $4.9 million to be included in CWIP for the new headquarters building.
53. We find reasonable San Gabriel's forecast method for materials and supplies, reflecting plant growth as well as general inflation (using updated inflation factors).
54. The additions to the advance for construction account for the past five years averaged $3 million. The additions projected for 2005-2008 average $2 million. The growth that creates the need for additional plant should be either advanced or contributed by developers. The advance estimate is low but reasonable.
55. The additions to the CIAC for the past five years averaged $1.3 million. The Company's additions projected for 2005-2008 average $850,000. Historically, the $1.3 million represented approximately 11% of the $11.677 million average of gross plant additions. The difference between the actual and the estimates suggests that San Gabriel understated the projected contributions. We adopt the historical average for contributions of $1.3 million.
56. We adopt San Gabriel's working cash estimating method. It was done in accordance with Standard Practice U-16.
57. We adopt San Gabriel's methodology in determining the depreciation expense based upon our adopted estimates of utility plant.
58. San Gabriel and DRA stipulated to the capital structure, cost of debt, ROE and overall rate of return for purposes of this GRC, agreeing on an ROE of 9.90%, and overall rate of return of 9.33% for TY 2006-2007 and 9.35% for TY 2007-2008. The stipulation is reasonable and is adopted.
59. DRA and San Gabriel proposed an imputed capital structure, consisting of 40% long-term debt and 60% common equity, an equity ratio approximately half way between the average equity ratio of a group of small water utilities and San Gabriel's actual equity ratio. This capital structure of 40% long-term debt and 60% common equity is reasonable and is adopted.
60. The stipulation between the DRA and San Gabriel results in a cost of long-term debt for each year, 2006-2008, based on the amounts proposed by San Gabriel. The agreed upon long-term debt rates are: 8.44% for 2006, 8.49% for 2007, and 8.54% for 2008. These debt rates are reasonable and are adopted.
61. Consistent with a 9.9% ROE, the overall rate of return for TY 2006-2007 at 9.33% and for TY 2007-2008 at 9.35% is reasonable and adopted.
62. San Gabriel seeks to phase into rates by advice letter filings the capital costs for its planned new headquarter complex ($3 million in the 2005 capital budget and $3 million in the 2006 capital budget) and for the post-2005 portion of the Sandhill Plant upgrade project ($18 million in 2006 and $4 million in 2007). An advice letter filing for a major addition to plant is not routine. It will have to be reviewed by the Water Division, DRA, possible protestants, and the Commission. Our three-year rate case plan can be seriously adversely impacted. A charge to CWIP will adequately protect San Gabriel. San Gabriel's advice letter proposal is approved for the Sandhill Plant upgrade, but denied for its planned new headquarters project.
63. San Gabriel's proposal to amortize the balance recorded in the Water Quality Litigation Memorandum Account as of June 30, 2006 is reasonable but outdated. We will authorize a 24-month amortization of the February 28, 2007 balance in the account.
64. San Gabriel shall continue to maintain a Water Quality Memorandum Account.
65. San Gabriel's proposed net-to-gross multiplier is 1.800324. DRA proposed 1.77286, the difference being DRA's use of an uncollectibles rate of 0.1951% and a deduction for qualified production activities under the Jobs Act. We find reasonable a net-to-gross multiplier of 1.772805 based on the resolution of those issues.
66. In accordance with the RCP, TY 2007-2008 is a test year for items related to rate base and an escalation year for all other revenue requirement components, and TY 2008-2009 is an attrition year for rate base items and an escalation year for other components. We have followed the RCP requirements for test year, escalation, and attrition factors to produce the reasonable and adopted revenue requirement and rate increase calculations for escalation years 2007-2008 and 2008-2009.
67. A facilities fee minimum of $5,000 for a 5/8" x 3/4" meter is reasonable and will be authorized. Other water purveyors in the region charge between $5,000 and $7,000 per new home connected to the system and use those funds to pay for additional capacity needed to serve new customers. San Gabriel has presented persuasive evidence that their customer base is growing by about 2-½% per year with concomitant growth in water usage. It proposes upgrades to its Sandhill plant, new wells, new reservoirs, and equipment to meet this growth. It is not unreasonable to require those requesting new connections, such as developers, builders, and new customers to assist in paying for these new facilities through a facilities fee paid prior to connection. Higher meter sizes will pay according to the schedule in Table 2, above.
68. Given the uncertainty and volatility of real estate development, the revenue that a facilities fee would generate is highly uncertain both in amount and timing. Facilities fee revenues should be taken into account for ratemaking purposes once they have been received, through an advice letter.
69. The following procedures for facilities fees are adopted:
1. All fees collected must be credited to CIAC at the time the fees are spent for additional plant.
2. The utility shall show the balances in its annual report to the Commission. Fund balances should be listed as debits to Account 121-3, miscellaneous special deposits, and as credits to Account 242, other deferred credits.
3. Interest should also be debited to Account 121-3, miscellaneous special deposits, and credited to Account 265, CIAC.
4. When plant is replaced using funds from these fees, a debit should be made to the appropriate plant account, a credit made to Account 121-3, miscellaneous special deposits, a debit made to Account 242, other deferred credits, and a credit made to Account 265, CIAC.
5. The fee is applicable to all applicants for installation of service connections by the utility in the territory served for premises not previously connected to its distribution mains, for additional service connections to existing premises, and for increases in size of service connections to existing premises the customer's request.
6. An estimate of the Facilities Fees shall be included in any deposit required of the applicant under Rules 15 and 16, or otherwise. The tariff sheet in effect at the time the statement of actual construction costs is provided to the applicant under Rules 15 and 16, or otherwise, shall determine the applicable amount of the Facilities Fees.
70. To modify the monthly service charge to equalize it for new residences would be a change which would benefit occupants of recently constructed homes at the expense of customers with older residences. Such a rate change would run counter to a facilities fee. San Gabriel's monthly service charge is in compliance with the Commission's Water Rate Design Policy set forth in D.86-05-064. It is reasonable and is adopted.
71. San Gabriel's CARW program is reasonable and is adopted.
72. San Gabriel's Fontana Division received $13,775,746 in proceeds from various transactions during the years 1996 to 2004 from:
Fontana Division | |
Water contamination |
$ 8,559,863 |
Service duplication |
$ 2,314,538 |
Sale on condemnation |
$ 2,421,727 |
Sale to private property owners |
$ 431,004 |
Condemnation order |
$ 22,500 |
Contamination (more) |
$ 26,114 |
Total |
$ 13,775,746 |
73. The 24 sales to private parties in the Fontana Division during years 1996 to 2004 mainly involved release of easements or rights of way with lines damaged, threatened, or rendered unusable or hazardous by grading and construction operations. Those properties are no longer necessary or useful and the $431,004 gain San Gabriel received from property sales to private owners is governed by Section 790.
74. The ten Fontana Division sales on condemnations addressed in the Audit Report were sales under threat of condemnation. San Gabriel, as the selling party, admits that it was motivated to avoid the cost and confrontation of a pointless condemnation trial; in the light of that threat San Gabriel did enter into sales transactions.
75. On November 10, 1998, San Gabriel entered into a settlement with the County of San Bernardino where the County agreed to pay San Gabriel compensation for damaging San Gabriel's property by contamination from the County's Mid-Valley Sanitary Landfill. San Gabriel's received, for the period 1998 to 2004, $8,559,863 from the County.
76. San Gabriel's contamination lawsuit was a claim for damages; the settlement damage payment was not a sale of real property nor did it result in a sale. Section 790 requires a sale by the utility. We will deduct the litigation costs of $208,554 from the proceeds of the contamination award of $8,559,863 for net proceeds of $8,351,309. We will allocate the net gains of $8,351,309, 67% to ratepayers and 33% to shareholders. This will assure and encourage the utility to vigorously pursue polluters.
77. The $26,114 contamination award dollars are not Section 790 proceeds, and will be allocated 67% to ratepayers and 33% to shareholders.
78. The gain allocated to ratepayers of $5,613,208 should be reduced by the cost of Plant F-10, $2,618,291, which is already in CIAC.
79. The $2,994917 balance of gain allocated to ratepayers will be accounted for by reducing rate base by increasing CIAC by that allocation.
80. San Gabriel has maintained detailed records necessary to document its investment in utility plant of the net proceeds of property sales, contamination recovery, and involuntary conversion.
81. San Gabriel should not be required to amend its general ledger and prior years' financial statements because neither accounting changes would have any ratemaking consequences but would impose costs on the Company.
82. The records San Gabriel kept were adequate to show the receipt of funds and the expenditure of funds. However, we will require a memorandum account to record all transactions that result in gains from sale of real property, or gains from condemnations, service duplication, or contamination claims.
83. Water quality issues have been adequately resolved.
84. San Gabriel should set-up a separate centrally located file for bill inquiries beginning January 1, 2006.
85. The rate base for this decision is $85,367,300 (Appendix A, p. 1.) The rate base for D.04-07-034 will be recomputed to reduce it by $2994917 (Appendix E, p. 2). The revenue requirement for D.04-07-034 will be recomputed to reduce it by $522,200 annually. (Appendix E, p. 2.) The amount of the refund should be calculated to reflect this lower revenue requirement for the relevant time period.
86. The failure of San Gabriel to adequately disclose material facts regarding the affiliate transaction sale by Rosemead to San Gabriel of a parcel of land to be used for a new headquarters complex merits a penalty. Management involvement in this breach of trust was 100%; at the very top level of the utility and the holding company.
87. San Gabriel knowingly provided misleading information to the Commission regarding issues that are material to this proceeding. The submittal of misleading information causes substantial harm to the regulatory process, which cannot function effectively unless participants act with integrity at all times.
88. We find the company in violation of Rule 1 for three acts of omission: 1) San Gabriel did not disclose that the land they were seeking to include in ratebase was purchased from an affiliate, 2) San Gabriel did not disclose that the purchase price of the land they were seeking to place in ratebase was not based on a market price but rather based on an appraisal performed by an appraiser hired and paid for by the company, and 3) San Gabriel did not disclose the fact that the price paid by the utility was significantly above the price paid by the affiliate when it purchased this land only a year and a half earlier. For each of the three violations of Rule 1 of the Commission's Rules of Practice and Procedure we impose a fine of $20,000 for a total of $60,000.
1. The ALJ Division shall offer a mediation service to assist the parties in achieving a solution to providing San Gabriel with the City's recycled water.
2. San Gabriel shall set up a memorandum account to record outside legal expenses to be capped at $287,795 per year, the form of the account to be approved by the Water Division.
3. Determination as to the disposition of proceeds that result from condemnation, sale under threat of condemnation, and inverse condemnation are deferred to the policy determination in R.04-09-003.
4. The settlement of a groundwater contamination claim is not a sale of real property, and is not within the purview of Section 790.
5. The rates and charges set forth in Appendix D to this decision are just and reasonable for the test year and escalation years set forth.
1. San Gabriel Valley Water Company (San Gabriel) shall file within 30 days after the effective date of this order, in accordance with General Order 96-B, and make effective on not less than five days' notice, the revised tariff schedules for its Fontana Division included as Appendix D to this order. The revised tariff schedules shall apply to service rendered on and after their effective date.
2. Not later than May 15, 2007 and May 15, 2008, for escalation years 2007/2008 and 2008/2009 respectively, San Gabriel shall file advice letters in conformance with General Order 96-B proposing new revenue requirements (and corresponding revised tariff schedules) for the Fontana Division. San Gabriel advice letters shall follow the escalation procedures set forth in the Commission's Rate Case Plan for Class A Water Utilities, and shall include appropriate supporting workpapers. San Gabriel shall reduce the escalation year revenue requirement for Fontana to the extent its rate of return on rate base for the 12 months ending March 31, 2007 and March 31, 2008, taking into account the rates then in effect and normal ratemaking adjustments, exceeds the rate of return found reasonable in this order. The revised tariff schedules shall take effect on July 1, 2007 and July 1, 2008, respectively, and shall apply to service rendered on or after their effective dates. The proposed revised revenue requirements and rates shall be reviewed by the Commission's Water Division. Water Division shall inform the Commission if it finds that the revised rates do not conform to the Rate Case Plan, this order, or other Commission decisions, in which case all revenues collected under the revised rates shall be subject to refund until the Commission has decided the matter.
3. Not later than November 15, 2007, and each succeeding year until San Gabriel's next GRC decision, San Gabriel shall file an advice letter in conformance with GO 96-B, proposing new revenue requirements (and corresponding revised tariff schedules) for the Fontana Division based on a new rate base reflecting: (i) inclusion in utility plant of all investment recorded during the then-current calendar year in the Sandhill Surface Water Treatment Plant Upgrade Project; and (ii) inclusion in CIAC of all revenues recorded in the facilities fee memorandum account during said calendar year. The advice letter shall include appropriate supporting workpapers. The revised tariff schedules shall take effect on January 1 of the succeeding calendar year and shall apply to service rendered on or after their effective dates. The proposed revised revenue requirements and rates shall be reviewed by the Commission's Water Division, which shall inform the Commission if it finds that the revised rates do not conform to the Rate Case Plan, this order, or other Commission decisions, in which case all revenues collected under the revised rates shall be subject to refund until the Commission has decided the matter.
4. San Gabriel shall refund to its ratepayers for the period July 17, 2004 to July 1, 2006, $573,278, plus the amount accrued from July 1, 2006 to the date its revised tariff schedules set forth in Ordering Paragraph 1 are effective. The refund shall be based on cents per ccf. No later than October 1, 2007, San Gabriel shall file an advice letter effective January 1, 2008 to be approved by the Water Division setting forth the amount and method of the refund.
5. To amortize its Water Quality Litigation Memorandum Account San Gabriel shall file an advice letter setting forth a detailed description of the services provided by San Gabriel's outside counsel. The amount approved by the Water Division shall be recovered by surcharge.
6. San Gabriel shall continue to track the costs of the CARW program and annually report to the Director of the Water Division the costs of such a program. San Gabriel may seek to have the costs recovered via a surcharge rather than in rates by filing an advice letter filed no later than October 1, 2007, to be effective January 1, 2008.
7. San Gabriel's Fontana Division shall file an application with the Commission within 120 days after the effective date of this decision requesting approval for the implementation of the Water Action Plan objectives.
8. For three separate violations of Rule 1 of our Rules of Practice and Procedure, San Gabriel shall pay a fine to the State of $20,000 for each violation for a total of $60,000.
9. Application 05-08-021 and Investigation 06-03-001 shall remain open to resolve the issues related to the proceeds from condemnations, sales under threat of condemnations and from inverse condemnations once the broader policy determinations have been made in R.04-09-003. San Gabriel's rates shall remain subject to refund to allow implementation of any resulting order.
This order is effective today.
Dated April 12, 2007, at San Francisco, California.
MICHAEL R. PEEVEY
President
DIAN M. GRUENEICH
JOHN A. BOHN
RACHELLE B. CHONG
TIMOTHY ALAN SIMON
Commissioners
