AMAR Developments Ltd - Final Water Rates for Cambridge Park Estates February 9, 2021 - Alberta Utilities Commission
←
→
Page content transcription
If your browser does not render page correctly, please read the page content below
` Decision 25519-D02-2021
AMAR Developments Ltd.
Final Water Rates for Cambridge Park Estates
February 9, 2021Alberta Utilities Commission
Decision 25519-D02-2021
AMAR Developments Ltd.
Final Water Rates for Cambridge Park Estates
Proceeding 25519
February 9, 2021
Published by the:
Alberta Utilities Commission
Eau Claire Tower
1400, 600 Third Avenue S.W.
Calgary, Alberta T2P 0G5
Telephone: 310-4AUC (310-4282 in Alberta)
1-833-511-4AUC (1-833-511-4282 outside Alberta)
Email: info@auc.ab.ca
Website: www.auc.ab.ca
The Commission may, within 30 days of the date of this decision and without notice, correct
typographical, spelling and calculation errors and other similar types of errors and post the
corrected decision on its website.Contents
1 Summary............................................................................................................................... 1
2 Introduction .......................................................................................................................... 1
3 Legislation and public utilities ............................................................................................ 4
4 Position of the parties participating in the proceeding .................................................... 7
4.1 HOA .............................................................................................................................. 7
4.2 Tanis Nicholls ............................................................................................................... 9
5 Revenue requirement ........................................................................................................ 11
5.1 Operating and maintenance expenses ......................................................................... 13
5.1.1 Out-of-scope work .......................................................................................... 13
5.1.2 Water hauling .................................................................................................. 14
5.2 General and administrative expenses .......................................................................... 18
5.2.1 Insurance ......................................................................................................... 18
5.2.2 Professional fees ............................................................................................. 19
5.2.3 Office, management and administration ......................................................... 19
5.3 Approved revenue requirement................................................................................... 23
6 2021 rates ............................................................................................................................ 25
6.1 Billing determinants .................................................................................................... 25
6.1.1 Customers ....................................................................................................... 25
6.1.2 Consumption ................................................................................................... 26
6.2 Approved rates ............................................................................................................ 28
7 2022 rates ............................................................................................................................ 32
8 Order ................................................................................................................................... 34
Appendix 1 – Proceeding participants ...................................................................................... 35
Appendix 2 – Commission corrections to Table 5.3 and Table 5.4 combined ....................... 37
List of tables
Table 1. Actual and forecast operating and maintenance expenses .................................... 12
Table 2. Historic and forecast annual number of customers and usage ............................. 13
Table 3. Proposed rates ........................................................................................................... 13
Table 4. Summary of Exhibit 25519-X0091 .......................................................................... 17
Table 5. AMAR’s proposed office, management and administration expenses ................ 20
Table 6. Commission-approved revenue requirement for 2020 and 2021 ......................... 24
Decision 25519-D02-2021 (February 9, 2021) iTable 7. Proposed rates ........................................................................................................... 25 Table 8. Historic and approved consumption forecasts ....................................................... 28 Table 9. Approved management fee....................................................................................... 31 Table 10. Reconciliation and determination of 2021 rates ..................................................... 31 Table 11. 2021 approved rates .................................................................................................. 32 Table 12. Calculation of 2022 variable charge and consumption volumes .......................... 33 Table 13. 2022 approved rates .................................................................................................. 33 Decision 25519-D02-2021 (February 9, 2021) ii
Alberta Utilities Commission
Calgary, Alberta
AMAR Developments Ltd. Decision 25519-D02-2021
Final Water Rates for Cambridge Park Estates Proceeding 25519
1 Summary
1. In this decision, the Alberta Utilities Commission has considered the complaint by the
Cambridge Park Phase 1 and 2 Home Owners Association (HOA) against AMAR Developments
Ltd. (AMAR) and the related application by AMAR for the Commission to approve its proposed
rates for 2020, 2021 and 2022. Based on its findings below, the Commission has approved, on a
final basis, rates that were in effect from May 1, 2020, interim rates approved in Decision 25519-
D01-2020,1 and AMAR’s forecast rates for January and February 2021. Commencing March 1,
2021, the Commission has approved final rates for AMAR, consisting of a fixed charge of
$20.00/month, a variable charge of $3.495/m3 and a supplemental variable charge of $14.50/m3,
for greater than 1.1 m3/day average usage over the month. In setting these rates, the Commission
reconciled AMAR’s revenues and expenses for 2020, resulting in a refund to customers of
$45,302.
2. In the event that Rocky View County does not assume operations prior to 2022, the
Commission has approved rates for AMAR commencing January 1, 2022, consisting of a fixed
charge of $20.00/month, a variable charge of $4.234/m3 and a supplemental variable charge of
$14.50/m3, for greater than 1.1 m3/day average usage over the month.
2 Introduction
3. On April 17, 2020, Bhawandeep Samra filed a complaint with the Commission on behalf
of the Cambridge Park Phase 1 and 2 HOA, representing approximately 200 residents who reside
in Cambridge Park Estates (Cambridge Park), located in Rocky View County. The complaint
concerned a 20 per cent increase in their March 2020 water rates imposed by their water utility
service provider, AMAR. The HOA stated that details in support of the increase were not
provided, and attempts to obtain information from AMAR went unanswered. The HOA
considered that AMAR was overcharging for water services and making large profits, and the
HOA sought transparency into the increased rates. Further, the HOA considered that water rates
were unjust as water rates in similar communities were lower.
4. The Commission issued a filing announcement and letter on May 13, 2020. In its letter,
the Commission indicated that service providers such as AMAR should be prepared to provide
sufficient detail to its customers regarding any proposed or actual rate increases. Given that the
HOA sought greater transparency into the increased water rates, the Commission considered for
regulatory efficiency, that AMAR should work with the HOA and provide additional insight and
detail into the circumstances of the rate increase, by June 30, 2020.
5. AMAR filed a general rate application on June 29, 2020, setting out the additional insight
and details in support of its increased rates. The Commission invited a response from the HOA
1
Decision 25519-D01-2020: AMAR Developments Ltd., Interim Water Rates, Proceeding 25519, July 17, 2020.
Decision 25519-D02-2021 (February 9, 2021) 1Final Water Rates for Cambridge Park Estates AMAR Developments Ltd.
as to whether AMAR’s explanation satisfied the HOA’s request for greater transparency into
water rates. Alternately, should the HOA wish to pursue the complaint, it should provide reasons
in support of the complaint being heard by the Commission. The Commission requested this
information by July 29, 2020.
6. On July 16, 2020, AMAR submitted a letter2 requesting approval of the following interim
water rates:
Fixed Rate (per connection) $20.00/month
Demand Rate (per m3) $5.00/m3
Over Demand Rate $14.50/m3
(>1.1 m3/day average over month)
7. Also on July 16, 2020, a customer advised the Commission that AMAR had delivered a
notice to all residents, advising that based on the June 29, 2020, rate application, new water rates
3
were effective July 1, 2020.
8. On July 17, 2020, the Commission approved the above-noted rates on an interim
refundable basis, and stated:
8. It appears to the Commission that the possibility exists wherein homeowners in
Cambridge Park may be left without a safe and reliable supply of water. Given the
ongoing viability and continued operation of the water utility being at risk, and in these
challenging times, the Commission considers that in order to maintain service for
customers, and to provide security for Albertans, urgency is required to implement an
interim water rate adjustment without delay. The approved interim water rates will
remain in effect until final rates are established in a process that provides registered
parties to this proceeding the opportunity to provide evidence in support of or in
opposition to AMAR’s proposed rates. 4
9. The Commission received the HOA’s response on July 29, 2020.5 Among other issues,
the HOA argued that the rate increase was not supported by historical data, and based on its cost
analysis, certain charges were questionable. Further, due to additional water capacity that was
available commencing September 27, 2020, water hauling costs seemed unreasonable. The
Commission also received a response from Ms. Tanis Nicholls.6
10. Given the concerns raised by both parties, the Commission established a process
schedule7 to test AMAR’s general rate application8 through information requests (IRs), followed
by final argument on rates by all parties.
11. Following the first round of IR responses, the HOA requested a second round of IRs for
further clarification and to gain a better understanding of the costs and expenses of providing
2
Exhibit 25519-X0017, AMAR interim rate request.
3
Exhibit 25519-X0018, Letter sent from AMAR Development to Residents.
4
Decision 25519-D01-2020, paragraph 8.
5
Exhibit 25519-X0031, Cambridge Park residents response 29 July.
6
Exhibit 25519-X0032, Additional comments.
7
Exhibit 25519-X0036, AUC process schedule.
8
Exhibit 25519-X0011, Cambridge Park rate review.
Decision 25519-D02-2021 (February 9, 2021) 2Final Water Rates for Cambridge Park Estates AMAR Developments Ltd.
water utility service to Cambridge Park residents.9 The Commission granted the second round of
IRs, followed by final argument on November 10, 2020.
12. By letter dated November 19, 2020, the HOA filed a motion.10 In its motion, the HOA
noted that AMAR had failed to provide certain information in its IR responses, and requested the
Commission to direct AMAR to provide this information. Following a brief process, the
Commission ruled on this matter on November 30, 2020. In its ruling, the Commission denied
the motion, stating:
12. The Commission does not share this view. As noted above, it is the
Commission’s responsibility to set rates and the Commission has determined that it does
not require the information sought in the HOA’s motion for further information. While
interested parties may provide their views and analysis of the costs and expenses to
operate the utility, ultimately it is up to the Commission to determine its information
requirements in order to set just and reasonable rates.
13. While proof of payment may provide strong support for historic actual amounts,
the Commission does not rely solely on historical information when determining whether
rates are just and reasonable. Rather, the Commission determines rates based on a
forecast test period as set out in Section 91 of the Public Utilities Act. On this basis, the
Commission considers that receiving proof of payment information as suggested by the
HOA will be of limited probative value and as such is not necessary in the circumstances.
14. The Commission has reviewed the information currently filed on the record of
this proceeding. Based on its review, the Commission is of the view that it does not
require any further information or supporting details in order for it to determine just and
reasonable rates. On this basis, the Commission finds that the additional information
requested by the HOA and Tanis Nicholls is not required. Accordingly, the Commission
denies the motion for additional information. 11
13. In its ruling, the Commission established December 7, 2020, as the deadline for final
argument. Final argument was received from the HOA, Ms. Nicholls and AMAR. Following
receipt of final argument, the HOA filed an unsolicited response to AMAR’s argument. In order
to be fair to the other parties, the Commission granted AMAR and Ms. Nicholls the opportunity
to file reply argument by December 11, 2020. The Commission considers December 11, 2020, to
be the close of record.
14. In reaching the determinations set out within this decision, the Commission has
considered all relevant materials on the public record of this proceeding. References in this
decision to specific parts of the record are intended to assist the reader in understanding the
Commission’s reasoning relating to a particular matter and should not be taken as an indication
that the Commission did not consider all relevant portions of the record with respect to that
matter.
9
Exhibit 25519-X0071, Request for 2nd round of questions.
10
Exhibit 25519-X0110, Missing information.
11
Exhibit 25519-X0115, AUC letter – Ruling on motion for further and better responses to information requests.
Decision 25519-D02-2021 (February 9, 2021) 3Final Water Rates for Cambridge Park Estates AMAR Developments Ltd.
3 Legislation and public utilities
15. The complaint raised by the HOA, and the resulting rate applications by AMAR, is the
first time that AMAR has appeared before the Commission seeking approval of its water rates.
The Commission must consider whether AMAR is an owner of a public utility in order to set
rates for AMAR and establish the date upon which it may set rates.
16. The Public Utilities Act applies to the public utilities that the Commission regulates,
including water utilities. Owners of public utilities are subject the Public Utilities Act and the
authority of the Commission. The specific provisions of the Public Utilities Act that apply to
definitions of an “owner of a public utility” and of “public utility” are found in Section 1:
Definitions
1 In this Act,
…
(h) “owner of a public utility” means
(i) a person owning, operating, managing or controlling a public utility and
whose business and operations are subject to the legislative authority of Alberta,
and the lessees, trustees, liquidators of the public utility or any receivers of the
public utility appointed by any court,…
(i) “public utility” means
…
(iv) a system, works, plant, equipment or service for the production,
transmission, delivery or furnishing of water, heat, light or power supplied by
means other than electricity, either directly or indirectly to or for the public, …
17. The Commission’s regulation of water utilities is conferred by statute and is triggered by
an application related to a requested approval of rates or a complaint application. Complaint
applications that involve private investor-owned water utilities are governed by the
Public Utilities Act. Section 2 of the Public Utilities Act specifies that, “an application to the
Commission includes a complaint made in writing to the Commission.”
18. In terms of public utilities, the Commission has broad authority with respect to a public
utility’s rates, tolls and charges, terms and conditions of service (T&Cs), and the nature and
quality of service. In particular, sections 78 and 78.1 of the Public Utilities Act give the
Commission jurisdiction and power to deal with public utilities and the owners of public utilities:
Application of Part
78(1) This Part applies
(a) to all public utilities owned or operated by or under the control of a company
or corporation that is subject to the legislative authority of Alberta or that has, by
virtue of an agreement with a municipality, submitted to the jurisdiction and
control of the Commission;
Decision 25519-D02-2021 (February 9, 2021) 4Final Water Rates for Cambridge Park Estates AMAR Developments Ltd.
(b) subject to subsection (2), to every person owning or operating a public utility
to which the jurisdiction of the Legislature extends;
(c) to all public utilities owned or operated by or under the control of the Crown,
or an agent of the Crown, in right of Alberta;
(d) to all utilities and other matters dealt with in Divisions 3 to 6 of this Part to
the extent set out in those Divisions.
…
Jurisdiction and powers
78.1(1) The Commission has all the necessary jurisdiction and power
(a) to deal with public utilities and the owners of them as provided in this Act;
(b) to deal with public utilities and related matters as they concern suburban areas
adjacent to a city, as provided in this Act.
19. Section 80 of the Public Utilities Act allows for the investigation of charges that are
unjust or unreasonable:
Investigation of utilities and rates
80 When it is made to appear to the Commission, on the application of an owner of a
public utility or of a municipality or person having an interest, present or contingent,
in the matter in respect of which the application is made, that there is reason to
believe that the tolls demanded by an owner of a public utility exceed what is
just and reasonable, having regard to the nature and quality of the service
rendered or of the commodity supplied, the Commission
(a) may proceed to hold any investigation that it thinks fit into all matters
relating to the nature and quality of the service or the commodity in question,
or to the performance of the service and the tolls or charges demanded for it,
(b) may make any order respecting the improvement of the service or commodity
and as to the tolls or charges demanded, that seems to it to be just and reasonable,
and
(c) may disallow or change, as it thinks reasonable, any such tolls or charges that,
in its opinion, are excessive, unjust or unreasonable or unjustly discriminate
between different persons or different municipalities, but subject however to
any provisions of any contract existing between the owner of the public utility
and a municipality at the time the application is made that the Commission
considers fair and reasonable.
20. Section 89(a) of the Public Utilities Act describes the Commission’s rate-setting function:
Fixing of rates
89 The Commission, either on its own initiative or on the application of a person having
an interest, may by order in writing, which is to be made after giving notice to and
hearing the parties interested,
(a) fix just and reasonable individual rates, joint rates, tolls or charges, or
schedules of them, as well as commutation, mileage or kilometre rate and other
Decision 25519-D02-2021 (February 9, 2021) 5Final Water Rates for Cambridge Park Estates AMAR Developments Ltd.
special rates, which shall be imposed, observed and followed subsequently by
the owner of the public utility;
21. The Commission’s purpose and functions relate to rate-setting and utility regulation of
certain investor-owned natural gas, electric utilities and water utilities. As stated by the Court of
Appeal of Alberta, “There can be little argument that the Commission is expert in the area of
rate-setting and utility regulation. It is assigned the task of working with its constitutive
legislation and with the same industry participants to regulate a complex area of economic policy
and fulfill its legislative mandate which is, ultimately, to set just and reasonable rates for utility
services balancing the interests of ratepayers and the shareholders of corporate utilities in the
process.”12
22. In terms of establishing the date upon which the Commission may set rates, the Alberta
Court of Appeal in Calgary (City) v Alberta (Energy and Utilities Board), 2010 ABCA 132,
defined retroactive rate-making and the authority of the Commission, as follows:
Retroactive ratemaking “establish[es] rates to replace or be substituted to those which
were charged during that period”: Bell Canada v Canada (Canadian Radio-Television
and Telecommunications Commission), 1989 CanLII 67 (SCC), [1989] 1 SCR 1722 at
1749 (“Bell Canada 1989”). Utility regulators cannot retroactively change rates (Stores
Block at para. 71) because it creates a lack of certainty for utility consumers. If a
regulator could retroactively change rates, consumers would never be assured of the
finality of rates they paid for utility services. 13
23. One of the leading cases with respect to an administrative tribunal’s authority to set rates
is the Stores Block14 decision from the Supreme Court of Canada. In this case, the court describes
the ability of the Commission to remedy past overcompensation or “rates”:
From my discussion above regarding the property interest, the Board was in no position
to proceed with an implicit refund by allocating to ratepayers the profits from the asset
sale because it considered ratepayers had paid excessive rates for services in the past. As
such, the City’s first argument must fail. The Board was seeking to rectify what it
perceived as a historic overcompensation to the utility by ratepayers. There is no power
granted in the various statutes for the Board to execute such a refund in respect of
an erroneous perception of past over-compensation. It is well established
throughout the various provinces that utilities boards do not have the authority to
retroactively change rates (Northwestern 1979, at p. 691; Re Coseka Resources Ltd.
and Saratoga Processing Co. (1981), 126 D.L.R. (3d) 705 (Alta. C.A.), at p. 715, leave to
appeal refused, [1981] 2 S.C.R. vii; Re Dow Chemical Canada Inc. (C.A.), at pp. 734-
35). But more importantly, it cannot even be said that there was over-compensation: the
rate-setting process is a speculative procedure in which both the ratepayers and the
shareholders jointly carry their share of the risk related to the business of the utility (see
MacAvoy and Sidak, at pp. 238-39).15 [emphasis added]
24. The above case law provides that there is a general rule against retroactively adjusting
final rates or to remedy past overcompensation issues.
12
FortisAlberta Inc v Alberta (Utilities Commission), 2015 ABCA 295, paragraph 91.
13
Calgary (City) v Alberta (Energy and Utilities Board), 2010 ABCA 132, paragraph 47.
14
ATCO Gas and Pipelines Ltd. v Alberta (Energy and Utilities Board), 2006 SCC 4, referred to as Stores Block.
15
Stores Block, paragraph 71.
Decision 25519-D02-2021 (February 9, 2021) 6Final Water Rates for Cambridge Park Estates AMAR Developments Ltd.
25. Subject to the above legislative framework, the Commission will exercise its jurisdiction
to review the complaint from the HOA together with the rates proposed by AMAR, and any
other issues concerning the public utility, as necessary.
Commission findings
26. AMAR operates “a system, works, plant, equipment or service” for the delivery or
furnishing of water directly or indirectly to customers. AMAR processes water through a water
treatment facility and provides water delivery to customers. Water service is directly provided
using AMAR’s distribution system to residential customers in Cambridge Park. The Commission
is satisfied that AMAR meets the definitions of a “public utility” and an “owner of a public
utility” as defined in the Public Utilities Act. An owner of a public utility, such as AMAR, is a
monopoly provider of an essential public service. It is subject to regulation to ensure that
customers receive safe and reliable service at just and reasonable rates.
27. Given the statutory framework and the relevant case law, the Commission finds that its
authority to assess complaints, and to change rates, tolls or charges, commences the date the
complaint application was submitted. This is in line with the Commission’s previous
determination that if a change to a rate, toll or charge is required, the object of the complaint may
be adjusted only back to the date the complaint was first made, on the understanding that the
complaint is in the nature of an application.16 Accordingly, the Commission’s authority to
address the customer complaint and set AMAR’s rates was engaged at the time of the HOA
complaint, which was filed consistent with Section 2 of the Public Utilities Act, on April 17,
2020. Accordingly, the Commission has authority to set the rates that were in effect from
April 17, 2020. However, given that the evidence proffered by the parties is based on monthly
data, the Commission’s findings will not take into account the remainder of the month of April
2020, but will consider rates from May 1, 2020, onwards.
4 Position of the parties participating in the proceeding
28. Before dealing with the determination of rates, the Commission considers it would be
helpful to address some of the submissions by explaining the role and jurisdiction of the
Commission.
4.1 HOA
29. The HOA pointed out that details, such as proof of payments for office expenses, water
hauling and other information requested by the HOA, 17 would be helpful in determining the
actual cost to operate the water utility. Proof of payment was of utmost importance in
determining the completeness and validity of any transaction. As AMAR did not provide any
proof of payments, the HOA submitted that the information provided in AMAR’s Excel
spreadsheets could have been manipulated and does not reflect the actual amounts spent.
16
Decision 790-D02-2015: Milner Power Inc., Complaints regarding the ISO Transmission Loss Factor Rule and
Loss Factor Methodology, ATCO Power Ltd., Complaint regarding the ISO Transmission Loss Factor Rule and
Loss Factor Methodology, Proceeding 790, Applications 1606494-1, 1608563-1 and 1608709-1, January 20,
2015, paragraph 206.
17
Exhibit 25519-X0118, Final argument CPE, PDF pages 5-7.
Decision 25519-D02-2021 (February 9, 2021) 7Final Water Rates for Cambridge Park Estates AMAR Developments Ltd.
30. The HOA claimed the information provided by AMAR in support of its proposed rate
increase was misrepresented and/or manipulated. Further, there was forgery of the February 2020
water rate increase notification, and there was either illegal well usage or false statements
regarding AMAR’s well licence status for May 2020. 18 The HOA also noted certain differences
in actual costs as shown on Table 5.1,19 and differences in net revenue amounts as shown on
Table 5.3 and Table 5.4 combined.20
31. The HOA submitted that AMAR failed to provide any engineering report or analysis to
ensure adequate water supply was available for all three phases of Cambridge Park. AMAR
stated in the media that there was sufficient water for Cambridge Park; however, the HOA
argued that the need to haul water for five months of the year suggested otherwise.
32. The HOA stated that lots in Cambridge Park were sold as fully serviced lots with city
water. Given AMAR’s supply of water, the HOA considered this was false advertising. In
addition, the HOA considered there was a conflict of interest between Sim-Flo Systems Inc.21
and Rocky View Utilities Corp (RVUC), which supplies billing, water hauling, engineering and
water utility operational services to AMAR.
33. The HOA also noted landscaping guidelines are contrary to AMAR’s suggestion to use
drought-tolerant plants.
34. The HOA argued that the average water usage volumes provided by AMAR were not
reflective of the actual consumption per household. AMAR has reported higher than average
usage in summer months but has failed to provide monthly meter reading logs for the
connections to provide a clear picture on consumption. Further, the 1.1 m3/day consumption limit
proposed by AMAR was not justified; if there was to be a limit, it should be set at 60 m3/month.
35. The HOA considered that a water shortage was the root cause of water issues at
Cambridge Park. Noting that water systems need to be sized to provide capacity for peak hour
demand and the maximum daily demand plus fire flow, the HOA argued that the distribution
system was not designed for these two characteristics. An engineering study or assessment was
not completed for the Phase 3 development; instead, the Phase 2 pre-design report was used for
approval. Further, in support of its development agreement, AMAR proposed 115,914 m3/year
for 207 end-use customers; however, the current licensed water volume is only 96,000 m3/year,
with system capability of only 79,000 m3/year. The HOA considered that AMAR ran out of
water in 2018 and that continued development will put further strain on the system and water
supply.
36. The HOA argued there was no contingency built into the system, and losses of 12-15 per
cent were not accounted for in the system design. Due to well performance issues, and the wells
being drilled close together, AMAR is not able to utilize its licensed volume of 96,000 m3/year.
18
The HOA based this on 390 m3 of water being hauled in May 2020 while there was a reported 6048 m3 of raw
water usage and only 19 m3 remaining capacity on well #1, with no licence being granted for well #2.
19
The HOA calculated this difference by comparing the August 2020 (in Exhibit 25519-X0044) with the October
2020 (in Exhibit 25519-X0093) versions of Table 5.1.
20
The HOA calculated this difference by comparing the August 2020 (in Exhibit 25519-X0044) with the October
2020 (in Exhibit 25519-X0093) versions of Table 5.3 and Table 5.4 Combined.
21
Sim-Flo prepared the report on water availability, and is a related company to RVUC.
Decision 25519-D02-2021 (February 9, 2021) 8Final Water Rates for Cambridge Park Estates AMAR Developments Ltd.
The system would be able to support more connections if the wells were able to produce the
licensed volumes.
37. The HOA argued that AMAR has not operated and managed the water facility in the best
interests of residents. Adequate licences were not obtained and water licences expired, resulting
in excessive water hauling requirements in 2020. Despite these water shortages, AMAR
continued to issue new connections, causing additional water shortages. As a utility operator, it is
AMAR’s responsibility to fulfill all of the regulatory, licensing and maintenance requirements.
Any costs related to water shortages due to these issues should be the operator’s responsibility.
38. The HOA also considered that certain revenue amounts were not accounted for in
AMAR’s analysis. Specifically, flat rates received from the residents were not accounted for,
amounts paid for water hauling for the 12 additional connections approved by Alberta
Environment and Parks (Alberta Environment) were not shared, and profits of more than
8-10 per cent were not carried forward and used to adjust future water rates.
4.2 Tanis Nicholls
39. Ms. Nicholls stated during both IR rounds that AMAR submitted documents, invoices
and spreadsheets with inaccurate numbers and false statements. Further, proof of payments,
timesheets and paystubs were not provided. Ms. Nicholls submitted that AMAR has a history of
using whatever numbers it feels justifies or benefits its position. The AUC should not trust
AMAR’s forecasted numbers, as these amounts do not match the invoices and documents
supplied by its vendors and suppliers.
40. Noting the current COVID-19 pandemic, AMAR stated that additional water usage
would be short lived, and that attempts were being made at all levels to return to a more normal
existence.22 Ms. Nicholls considered this statement was opposite of the instructions from Alberta
Health Services (AHS), the Alberta government and the federal government for almost nine
months, and argued that if the homeowners in Cambridge Park stayed home and followed public
health orders, they could not afford their water bills because of the rate increases.
41. Ms. Nicholls also challenged AMAR’s statement that “average normal household water
usage is approximately 20 m3/month.”23 Given the high percentage of multigenerational families
in Cambridge Park, there are more people in each home and more water usage than an average
household. While AMAR indicated that basement suites are not allowed based on the zoning of
the development, according to Rocky View County’s Building, Planning and Development
Department, basement suites can be approved if a homeowner files a site-specific Bylaw
Amendment and the amendment is approved.
42. Ms. Nicholls also expressed concern regarding AMAR’s temporary diversion licence and
its appeal to Alberta Environment, stating:
… it was alarming to read that AMAR admitted to not following the directions provided
by Alberta Environment. Please explain how AMAR can state that no more than (12)
connections occurred from March 2019 through to January 2020, when the monthly
connections invoices from RVUC state otherwise?24
22
Exhibit 25519-X0117, Nicholls.T-Final argument, PDF page 2.
23
Exhibit 25519-X0117, Nicholls.T-Final argument, PDF page 2.
24
Exhibit 25519-X0117, Nicholls.T-Final argument, PDF page 21.
Decision 25519-D02-2021 (February 9, 2021) 9Final Water Rates for Cambridge Park Estates AMAR Developments Ltd.
43. Ms. Nicholls noted that “the development agreement for Phase 1, 2 and 3 of the
development specifies that no water from the distribution system is to be used for watering
outdoors. Residents will be informed of this water use restriction by have [sic] delivered notices
to each home.”25 The guidelines given to all homeowners in Cambridge Park contradict this
information. Further, homeowners were not informed of this when purchasing their home and
landscaping their property.
Commission findings
44. The Commission notes that the submissions raised by parties relate to the following:
• Requirement for proof of payment information.
• Forecast rate design is not fair.
• Information that was misrepresented and/or manipulated, forged or false.
• Illegal well usage.
• False advertising, conflicts of interest and integrity of the owners.
• Landscaping guidelines.
• Lack of reports or analysis to ensure adequate water supply, the correct sizing of the
system and the allowance for contingencies.
• Water utility was not being operated in the best interests of customers, and conditions of
the development agreements not being fulfilled.
• Regulatory, licensing and maintenance requirements and any costs related to water
shortages should be the responsibility of the utility.
• Certain revenues were not accounted for.
45. The Commission dealt specifically with the issue of proof of payment, when it issued its
ruling on the HOA’s motion for further and better responses to IRs. In the ruling, 26 the
Commission clarified that while proof of payment may provide support for historical costs, the
Commission determines rates based on a forecast test period as set out in Section 91 of the
Public Utilities Act. For this reason, proof of payment information is of limited value to the
Commission.
46. When a private, investor-owned water utility is determined to be a “public utility” under
the Commission’s jurisdiction, the Commission considers forecast costs and expenses to set rates
on a go-forward basis, absent certain exceptions such as a reconciliation of prior interim rates
approved by the Commission. Thus, all costs to provide water to a utility’s customers may be
included and considered in the rate-setting process. Regulatory, licensing and maintenance
expenses are all considered costs of providing service and are typically included in determining a
utility’s revenue requirement. While actual or historic costs may assist in showing the
reasonableness of increases or decreases to forecast rates proposed by a utility, setting rates
based only on historic costs generally results in a utility being underfunded and may place water
25
Exhibit 25519-X0117, Nicholls.T-Final argument, PDF page 22.
26
Exhibit 25519-X0115, AUC letter – Ruling on motion for further and better responses to information requests.
Decision 25519-D02-2021 (February 9, 2021) 10Final Water Rates for Cambridge Park Estates AMAR Developments Ltd. service and quality at risk. One example of why this is a general premise, is because cost increases are expected over time, such as cost increases due to inflation. 47. Further, in the rate-setting process, utilities are allowed to earn a return. The approved return is typically calculated based on a utility’s rate base, providing a return on the utility’s invested capital. In certain circumstances, the Commission may consider alternatives to return. Further, in setting rates for subsequent periods, the approved return is not used to offset the proposed revenue requirement of a utility. 48. Both the HOA and Ms. Nicholls made submissions alleging that AMAR misrepresented and/or manipulated data, illegally used wells, made false statements and forged a water rate increase notification. The Commission notes that in some cases errors were made in the submissions and these were corrected. It appears from the various submissions, many of which are out of scope for this proceeding, that there are longstanding issues between AMAR and its customers. However, based on its experience, the Commission finds that the application submitted by AMAR is not atypical of applications it would expect from a small water utility. The Commission is of the view that there is no persuasive evidence of malfeasance on AMAR’s part. 49. Submissions were also made regarding the design, capacity and approval of the water system and subdivision approvals, including issues related to the marketing of Cambridge Park. The Commission’s jurisdiction in this proceeding is focused on setting rates that cover the period from May 1, 2020, to December 31, 2022, as determined by the Commission in Section 3 above, and as set out in AMAR’s application. In this regard, the Commission considers the proposed costs and expenses, and billing determinants for these time periods. On this basis, the Commission finds that issues relating to matters outside of the rate-setting function and this time period are not in scope of this proceeding, such as the issue regarding the connection of 12 additional homes in 2019. 50. Further, issues identified pertaining to the design, capacity and approval of the water system and subdivision approvals are granted by other governmental organizations. Once these approvals are given, the developer and the utility are allowed to operate under these approvals. To the extent there are contraventions to these approvals, these matters must be dealt with by the applicable governing authority. 5 Revenue requirement 51. Cambridge Park is a residential subdivision in Rocky View County, located east of the city of Calgary. The developer, AMAR, has completed the first three development phases, consisting of 181 homes. As part of its subdivision approval, Rocky View County required AMAR to construct a water treatment plant. The initial system, commissioned in 2010, consisted of one water well, a raw water transmission pipeline, a water treatment system, a potable water reservoir and a distribution pumping system. 52. Currently, the water supply for Cambridge Park is provided by two water wells, each with permanent diversion licences. Each well has an annual diversion limit of 48,000 m3 and Decision 25519-D02-2021 (February 9, 2021) 11
Final Water Rates for Cambridge Park Estates AMAR Developments Ltd.
a maximum daily diversion limit of 230 m3.27 Water demand in excess of the available limits is
trucked into the potable water reservoir.
53. On July 14, 2020,28 AMAR received approval for Phase 4 development. This approval
was conditioned on phases 1 to 4 of Cambridge Park being connected to the Rocky View County
regional water system. Once the pipeline connecting Cambridge Park to the regional water
system is complete, the water wells at Cambridge Park will be abandoned, and Rocky View
County will take over operations and the provision of potable water to Cambridge Park residents.
At that time, new water rates will be implemented pursuant to Rocky View County’s bylaws.
AMAR stated that the pipeline is to be in place by the end of 2021, and noted the completion
data for final designs and tender documentation is set for June 2021.29
54. Based on historical operational costs, AMAR forecasted costs for 2020, 2021 and 2022,
as shown below:
Table 1. Actual and forecast operating and maintenance expenses30
2018 2019 2020 2021 2022
Actual Actual Forecast Forecast Forecast
($)
Utilities:
Electricity 17,097 18,848 20,640 20,888 21,139
Natural Gas 3,731 2,172 2,745 2,778 2,812
Diesel Fuel 200 202 205
Sanitary Sewage 19,308 18,553 15,889 16,079 16,272
Subtotal 40,136 39,573 39,474 39,947 40,428
Operating and maintenance expenses:
Operator Contract 56,464 58,415 59,240 59,951 60,671
Water Testing 2,599 2,966 4,971 5,030 5,091
Maintenance and Repairs 31,464 6,879 2,185 2,211 2,238
Meter Reading and Billing Costs 34,239 39,488 34,951 35,370 35,795
Out-of-Scope Work 5,475 6,192 4,923 4,982 5,042
Water Hauling 17,072 70,649 137,139 189,000 191,268
Chemicals 4,337 3,043 4,698 4,754 4,811
Water Well 19,333 29,522
Subtotal 170,983 187,632 277,629 301,298 304,916
General and administrative expenses:
Insurance 3,000 3,036 3,072
Professional Fees 53,339 15,027 13,100 13,257 13,416
Office, Management and Administration 24,000 24,000 35,002 47,002 47,566
Legal 2,363 4,000 4,048 4,097
Bad Debts 616 1,000 1,012 1,024
Subtotal 77,339 42,006 56,102 68,355 69,175
Total Water Treatment System 288,458 269,211 373,205 409,600 414,519
Note: the Commission has displayed whole values only, and adjusted the rounding.
27
Exhibit 25519-X0116, AMAR final argument, PDF page 6.
28
Exhibit 25519-X0017, AMAR interim rate request, PDF page 1.
29
Exhibit 25519-X0123, AMAR reply argument, PDF page 2.
30
Exhibit 25519-X0093, IR R2 Attachment to AMAR-CPR-2020-OCT13-001(1), Table 5.1 tab.
Decision 25519-D02-2021 (February 9, 2021) 12Final Water Rates for Cambridge Park Estates AMAR Developments Ltd.
55. AMAR also provided the following forecast of customers31 and usage. Forecast usage for
2020 was based on nine months of actuals from January to September, and three months of
forecasts from October to December:
Table 2. Historic and forecast annual number of customers and usage
2018 2019 2020 2021 2022
Actual Actual Forecast Forecast Forecast*
Customers 140 163 186 201 208
Average monthly customer usage (m3) 29.9 27.6 29.8 30.4 27.2
*Source: Exhibit 25519-X0093.
56. Based on these forecasts, AMAR proposed the following water rates:
Table 3. Proposed rates
Supplemental variable charge
Period Fixed rate Variable charge
(> 1.1 m3/day average over month)
($) ($/m3)
2020 20.00 5.000 14.50
2021-2022 20.00 4.650 14.50
57. In reaching its determinations on the rates to be charged by AMAR to its customers, the
Commission has undertaken a review of AMAR’s forecast expenses for 2020, 2021 and 2022,
based on the submissions and historic values provided by AMAR. Both the HOA and
Ms. Nicholls have made submissions on the quantum of these amounts, which the Commission
will review in the following sections. Given that for 2020, the Commission will be only
considering revenue requirement amounts for the period from May 1, 2020, to December 31,
2020, the Commission will also consider the manner in which these expenses will be pro-rated
for this period.
58. In considering the operating and maintenance expenses, the Commission has not
specifically dealt with each line item category listed above in Table 1. The Commission notes the
forecast amounts proposed by AMAR as filed except to the extent that they are otherwise
addressed below.
5.1 Operating and maintenance expenses
5.1.1 Out-of-scope work
59. In Section 7.1 of its argument, the HOA included a value of $4,698 for out-of-scope work
in 2020. In contrast, AMAR forecasted the amount as $4,923. The Commission understands that
out-of-scope work is for services provided by RVUC that are not included as part of the basic
services under AMAR’s service agreement with RVUC.32 The Commission notes that for 2021,
both the HOA and AMAR propose the same amount of $4,982 for out-of-scope work. Given the
slight difference, in the amounts proposed for 2020, the Commission is of the view that this
difference may be a typographical error. On this basis, and the fact that the HOA has not
31
In this decision, the terms “customers,” “connections” and “service connections” are used interchangeably to
refer to each site that is connected to AMAR’s water distribution system.
32
Exhibit 25519-X0055, Service Agreement.
Decision 25519-D02-2021 (February 9, 2021) 13Final Water Rates for Cambridge Park Estates AMAR Developments Ltd.
provided any support for its proposed amount, the Commission will include $4,923 in revenue
requirement for 2020, and approves the 2021 amount of $4,982, for out-of-scope work.
5.1.2 Water hauling
60. In its proposed revenue requirement, AMAR included water hauling expenses for 2020
and 2021 of $137,139 and $189,000, respectively.33 AMAR submitted that these expenses result
from the need to haul water from offsite in order to ensure uninterrupted supply during shortfalls,
caused by the inadequacy of the well diversion licences to meet the needs of Cambridge Park.
Water hauling is required when the maximum daily licensed diversion or well capability is
exceeded and when forecast water usage may require water hauling. Taking this into account,
and using historical data, AMAR calculated a hauled water forecast of 10,601 m3 for 2020,34 and
13,500 m3 for 2021.35 AMAR forecasted these amounts by multiplying an average monthly
consumption of 34.6 m3 per home during the summer months,36 by AMAR’s projection of the
number of homes (or connections).
61. AMAR’s water hauling expenses were calculated using rates of $13.00/m 3 for 2020 and
$14.00/m3 for 2021.37 These unit costs include supervision, monitoring, operations and delivery
of potable water to the Cambridge Park reservoir. AMAR explained that its calculation of water
hauling costs on a per cubic metre basis was developed using actual invoices and volumes,38 and
based on conversations with its water hauler, Alberta Water Services (AWS), the water hauling
rate for 2021 could increase by $1.00/m3 to $14.00/m3. AMAR based its cost estimates for 2021
on this forecast.39
62. The HOA did not agree with AMAR’s water hauling costs. In previous submissions,
AMAR had used $20.54/m3 for water hauling costs instead of the actual costs for 2020. Based on
the HOA’s calculations, the actual water hauling cost for 2020 should have been $10.72/m3.40
The HOA indicated that its calculations were based on the total trucked water volume that was
filed by AMAR as part of its response on water diversion volumes, 41 which was different from
the volume filed by AMAR in response to the Commission’s request for a summary of water
deliveries up to and including September 2020.42 Further, the HOA argued that AMAR was
intentionally hiding information when it failed to provide per household usage.
63. The HOA recommended that water hauling expenses for 2020 be set at $107,870. The
HOA considered that 2,683 m3 of excess water was treated by AMAR, based on its analysis of
the difference between AMAR’s treated water volumes and customer water volumes. The HOA
argued that the amount of excess water being treated and the corresponding volume of water that
33
Exhibit 25519-X0093, IR R2 Attachment to AMAR-CPR-2020-OCT13-001(1), Table 5.1 tab.
34
Exhibit 25519-X0106, IR R2 Attachment to AMAR-CPR-2020-OCT13-001(b).
35
Exhibit 25519-X0105, IR R2 Attachment to AMAR-CPR-2020-OCT13-013(9).
36
Exhibit 25519-X0043, IR response, AMAR-AUC-2020AUG21-002(e).
37
Exhibit 25519-X0116, AMAR final argument, PDF page 9.
38
Exhibit 25519-X0123, AMAR reply argument, PDF page 2.
39
Exhibit 25519-X0083, IR response Round 2 Main Document, AMAR-AUC-2020OCT13-002.
40
Exhibit 25519-X0120, CPE response to Amar’s final argument.
41
Exhibit 25519-X0083, IR Response Round 2 Main Document, AMAR-CPR-2020-OCT13-004, and
Exhibit 25519-X0099, IR R2 Attachment to AMAR-CPR-2020-OCT13-004(3).
42
Exhibit 25519-X0083, IR response Round 2 Main Document, AMAR-AUC-2020OCT13-002, and
Exhibit 25519-X0091, IR R2 Attachment to AMAR-AUC-2020OCT13-002.
Decision 25519-D02-2021 (February 9, 2021) 14Final Water Rates for Cambridge Park Estates AMAR Developments Ltd.
needed to be hauled by AMAR should have been lower. As a result, the “Cost for excessive
water hauled should [be] absorbed by AMAR due to mismanagement of the facility.” 43
64. For 2021, the HOA provided three scenarios. The first scenario was based on the water
wells operating at maximum available capacity resulting in no water hauling for 2021,44 with
water hauling expenses being set at $0. Under the second scenario, if the wells were operated
efficiently and no new water connections were made in 2021, the HOA estimated 1,521 m3 of
water would need to be hauled, at a cost of $15,210.45 Under the worst-case scenario, well #2
would perform at a lower capacity (179 m3/day), resulting in 5,000 m3 of water being hauled.
With water hauling costs of $14.00/m3, the annual costs would be $70,000.46 Based on 2021
water hauling costs between $0 and $70,000, the HOA recommended the variable water rate that
should be charged to customers was between $2.50/m3 and $3.40/m3.
65. While the HOA accepted AMAR’s 2021 proposed water hauling costs of $14.00/m3, it
stated:
We believe that this cost is very high and can be reduced further if the requirement of
operator is removed or minimized and/or a lower per hour rate is negotiated. 47
66. Ms. Nicholls submitted that the cost of hauling water could be lower if AMAR used
Cal-Portisan rather than AWS. Comparing the weekly cost of purchasing 24 loads of
supplemental water, at $239.70 per tank load, from Cal-Portisan, to the cost of purchasing
30 loads, at $195 per load, and five loads, at $97.50 per load, from AWS, resulted in an
estimated difference of $3,740.95 (46.7455 per cent) between the two providers. This difference
was mainly due to additional expenses associated with the lower capacity of AWS’s trucks,
requiring more deliveries and additional hourly services that are billed by RVUC, which is the
well operator.48
67. In addition, Ms. Nicholls raised health and safety concerns with respect to AWS. In
particular, Ms. Nicholls referred to one of AWS’s water trucks having no AHS certification, the
use of a hose that did not meet safety guidelines, and improper operating standards associated
with water deliveries over a 10-day period.49 AMAR submitted, on behalf of AWS, that these
issues had been resolved and would not occur again.50
Commission findings
68. The Commission has reviewed the HOA’s recommendation that water hauling expenses
for 2020 be reduced to $107,870, on the basis of 2,683 m3 of excess treated water. In calculating
the volume of excess treated water, the HOA has subtracted customer volumes from treated
water volumes from January to August 2020.51 There is a difference between raw water, treated
43
Exhibit 25519-X0118, Final argument CPE, PDF page 28.
44
Exhibit 25519-X0118, Final argument CPE, PDF page 30.
45
Exhibit 25519-X0118, Final argument CPE, PDF page 32.
46
Exhibit 25519-X0118, Final argument CPE, PDF page 33.
47
Exhibit 25519-X0118, Final argument CPE, PDF page 33.
48
Exhibit 25519-X0117, Nicholls.T- Final argument, PDF pages 12-13.
49
Exhibit 25519-X0117, Nicholls.T- Final argument, PDF page 14.
50
Exhibit 25519-X0083, IR Response Round 2 Main Document, AMAR-T.NICHOLLS-OCT13-008(b).
51
Exhibit 25519-X0118, Final argument CPE, PDF page 26.
Decision 25519-D02-2021 (February 9, 2021) 15Final Water Rates for Cambridge Park Estates AMAR Developments Ltd.
water and customer water volumes. AMAR explained these differences to the Commission in the
following IR response:
Water losses in the distribution system can be attributed to the following:
(1) Water meter accuracy/registration of flow at low flows
(2) Modified piping internal to homes to bypass some or all of the water flow around
the flow meter.
(3) Leakage in the customer service pipe to the house.
(4) Leakage at the curb stop
(5) Leakage at the corporation cock
(6) Leakage within the water distribution system
The accuracy of the water meter at the home can under read the quantity of water
delivered to the home. Some literature suggests that the measured flow rate can be as low
as 98.5% of the actual flow.
Meters are inspected by Rocky View County at the time that the home is initially
occupied. Modifications of the flow meter or bypassing of the flow meter by the owner
could account for lower water usage measured at the customer point of delivery.
Leakage occurs in all distribution systems. Most of the leaks are small and undetectable.
A number of small leaks within the distribution system can add up to a higher volume of
water that does not reach the customer. In 2019 the difference in the water volume
measured at the customer homes as compared to the distribution flow meter represents
approximately 14 L/min. If we were to assume that every home service leaked equally
this would amount to .08 L/min each. This level of leakage is undetectable.
Other distribution systems that have differences in distributed water and water measured
at the customers point of delivery are:
AMAR Water System: 89% (Average 2016-2019)
Langdon Waterworks: 82%
Lakes of Muirfield: 75%
Carmek Park: 95%52
69. The Commission is of the view that excess water was not treated, but rather the
differences can be attributed to water losses as explained by AMAR. On this basis, the
Commission rejects the HOA’s position regarding excessive water being treated, and the
proposed water hauling expenses of $107,870.
70. For water hauling costs in 2021, the Commission notes that while the HOA has used
AMAR’s 2021 forecast water hauling costs of $14.00/m3,53 its position is that water hauling
expenses can be reduced if the use of an operator during the water unloading process is
minimized or not required, or a lower rate is negotiated. The requirement for an operator was
also explained in the IR responses:
There is a requirement to ensure that the water system is providing potable water with
sufficient chlorine residual. Receiving of hauled water, supervising unloading, testing for
52
Exhibit 25519-X0043, IR response, AMAR-AUC-2020AUG21-010(b).
53
Exhibit 25519-X0118, Final argument CPE, PDF page 33.
Decision 25519-D02-2021 (February 9, 2021) 16Final Water Rates for Cambridge Park Estates AMAR Developments Ltd.
chlorine residual and making adjustment to the water treatment plant is necessary. Note
that while water deliveries are being made, the water treatment plant continues to treat
water from the wells. A blend of hauled and locally treated water occurs. Treatment
efficiencies and chlorine residuals must be monitored and adjusted during this period of
time.54
71. AMAR’s responsibility is to provide safe water for residents. The Commission finds that
monitoring and adjusting chlorine levels during the unloading process is reasonable to ensure the
safety of the water supply. Further, Alberta Environment stated that it was “best practice that
each truckload of water be tested for chlorine residual and some be tested for bacteriological
quality.”55 Accordingly, the Commission is of the view that these expenses are reasonable and
should be included in revenue requirement.
72. Ms. Nicholls argued that due to tanker size, fewer deliveries would be required from
Cal-Portisan, and hence the operator expense associated with deliveries would be lower. The
Commission has tested this argument by examining Exhibit 25519-X0091, which shows the
volumes and cost of water delivered in 2020, including supervision cost by water hauler. The
Commission has summarized this information and calculated the unit costs in the table below:
Table 4. Summary of Exhibit 25519-X0091
Volume Water Supervision Total Water Supervision Total
(m3) ($) ($/m3)
Cal-Portisan 5,910 60,150.00 18,562.50 78,712.50 10.18 3.14 13.32
AWS 4,691 32,613.75 25,812.50 58,426.25 6.95 5.50 12.45
Total 10,601 92,763.75 44,375.00 137,138.75
73. Based on this information, the Commission agrees with Ms. Nicholls that the supervision
costs are less per cubic metre with Cal-Portisan. However, the Commission notes that the total
cost of hauling water on a cubic metre basis is less with AWS. The Commission finds that
AMAR has acted in the best interests of its customers by sourcing water from the most
competitively priced supplier.
74. In its forecast of hauled water for 2021, AMAR has taken into account historical data on
water consumption patterns, as well as increased water requirements due to an increase in
customer connections. Considering that 10,601 m3 of water was hauled in 2020, with a mid-year
customer base of 186,56 and with a higher mid-year forecast of 201 customers for 2021, AMAR
forecasted 13,500 m3 of hauled water will be required in 2021.57
75. Under the HOA’s most favourable hauled water forecast, it suggested that no water
hauling would be required for 2021. Under its other two scenarios, forecast water hauling was
1,521m3 and 5,000 m3, with the number of customers capped at 195. Given AMAR’s most recent
actual consumption volumes, customer numbers and projections of water usage and the number
of customers in 2021, which exceeds 195, the Commission finds the HOA’s proposed water
hauling volumes to be unreasonable.
54
Exhibit 25519-X0083, IR Response Round 2 Main Document, AMAR-CPR-2020-OCT13-007(2).
55
Exhibit 25519-X0118, Final argument CPE, Appendix 2.
56
Exhibit 25519-X0106, IR R2 Attachment to AMAR-CPR-2020-OCT13-001(b).
57
Exhibit 25519-X0105, IR R2 Attachment to AMAR-CPR-2020-OCT13-013(9).
Decision 25519-D02-2021 (February 9, 2021) 17You can also read
