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Case Background
Rules 25-6.097, 25-7.083, and 25-30.311, Florida
Administrative Code (F.A.C.), address customer deposits for the electric
utilities, gas utilities and water/wastewater utilities respectively. These
rules provide a minimum annual interest rate paid on deposits. The current
rates are 6 percent per year on deposits and 7 percent per year on
nonresidential deposits held after 23 months of continuous service.
Staff initiated rulemaking to reduce the minimum annual
interest on residential deposits from 6 percent to 2 percent per year and on
nonresidential deposits from 7 percent per year or 3 percent per year for
accounts held after 23 months of continuous service. Staff believes that the
rule change is necessary to reflect current market rates. A notice was
published in the March 2, 2012, edition of the Florida Administrative Weekly.
No requests for a rulemaking development workshop were received and none was
held.
This recommendation addresses whether the Commission
should propose the amendment of Rules 25-6.097, 25-7.083, and 25-30.311,
F.A.C., to reduce the interest rates of customer deposits. The Commission has
jurisdiction pursuant to Sections 120.54, 366.05, and 367.121, Florida
Statutes .
Discussion
of Issues
Issue 1:
Should the Commission propose the amendment of Rules
25-6.097, Customer Deposits, 25-7.083, Customer Deposits, and 25-30311,
Customer Deposits?
Recommendation:
Yes, the Commission should propose the amendment of
these rules as set forth in Attachment A. (Miller, Cicchetti)
Staff Analysis:
The current interest rate required on customer
deposits is higher than justified by current credit and capital market
conditions. Staff recommends that the interest rate to be applied to
customers’ deposits for Rules 25-7.083 (4)(a), 25-6.097(4)(a) and 25-30.322(4),
Florida Administrative Code, be changed to a minimum interest rate of 2 percent
per annum, and to 3 percent per annum on deposits of nonresidential customers
when the utility elects not to refund such a deposit after 23 months.
Currently, the minimum interest rate is set at 6 percent and 7 percent per
annum, respectively. A copy of the amended rules is appended as Attachment A.
Interest rates are reflected in utilities’ tariffs. In
implementing these revisions, the utilities will need to file tariffs to
reflect the changes.
For current customer deposits, the interest rate paid for
the period of time prior to the effective date of the rule amendments, shall be
at the higher rate. The interest rate paid for the period of time on the
effective date of the rule and after shall be at the lower rate.
Statement of Estimated Regulatory Cost (SERC)
The Statement of Estimated Regulatory Costs (Attachment B)
analyzes whether the draft rule pursuant to Subparagraph 120.541(2)(a)1, is
likely to have an adverse impact on economic growth, private sector job
creation or employment, or private sector investment in excess of $1 million in
the aggregate within 5 years after implementation. Also, the statute requires
consideration of whether the draft rule is likely to have an adverse impact on
business competitiveness, productivity or innovation in excess of the above
amount. Staff issued data requests to the utilities to determine the impact.
Each of the investor-owned electric utilities reported expected reductions in
the cost of capital, significant reductions in interest expense, and relatively
minor or no increase in administrative expense. The two investor-owned gas
companies reported expected reductions in cost of capital. One water and
wastewater company reported it expected a reduction in the cost of capital and
fourteen other water and wastewater companies reported minimal or no impact.
Staff believes that expected reduction in interest credit
to customers does not constitute an adverse impact on economic growth, private
sector job creation or employment, private sector investment or business
competitiveness. Instead, it is eliminating what is, in essence, an undue
benefit to customers. The rule amendments adjust the applied interest rates
to comport more closely with current market-based interest rates.
It is unlikely the rule amendments will increase
regulatory costs. The rule amendments will not require legislative
ratification.
Most electric IOUs expect their small business customers
will experience a reduction in interest credit. The first year impact for the
industry’s small business customers is at least $3.18 million for FPL and Gulf
combined. Over the longer term, reductions in the cost of capital may be
reflected in customers’ base rates. There should be no impact on small cities
or counties, since utilities do not require deposits from them.
Staff recommends that the Commission propose the amendment
of Rules 25-6.097, Customer Deposits, 25-7.083, Customer Deposits, and
25-30311, Customer Deposits as set forth in Attachment A.
Issue 2:
Should this docket be closed?
Recommendation:
Yes. If no requests for hearing or comments are
filed, the rules should be filed with the Department of State, and the docket
should be closed. (Miller)
Staff Analysis:
If no requests for hearing or comments are filed,
the rules should be filed with the Department of State, and the docket should
be closed.
25-6.097 Customer Deposits.
(1) Deposit required; establishment of credit. Each company’s
tariff shall contain their specific criteria for determining the amount of
initial deposit. Each utility may require an applicant for service to
satisfactorily establish credit, but such establishment of credit shall not
relieve the customer from complying with the utilities’ rules for prompt
payment of bills. Credit will be deemed so established if:
(a) The applicant for service furnishes a satisfactory guarantor
to secure payment of bills for the service requested. For residential
customers, a satisfactory guarantor shall, at the minimum, be a customer of the
utility with a satisfactory payment record. For non-residential customers, a
satisfactory guarantor need not be a customer of the utility. Each utility
shall develop minimum financial criteria that a proposed guarantor must meet to
qualify as a satisfactory guarantor. A copy of the criteria shall be made
available to each new non-residential customer upon request by the customer. A
guarantor’s liability shall be terminated when a residential customer whose
payment of bills is secured by the guarantor meets the requirements of
subsection (2) of this rule. Guarantors providing security for payment of
residential customers’ bills shall only be liable for bills contracted at the
service address contained in the contract of guaranty.
(b) The applicant pays a cash deposit.
(c) The applicant for service furnishes an irrevocable letter of
credit from a bank or a surety bond.
(2) Refund of deposits. After a customer has established a
satisfactory payment record and has had continuous service for a period of 23
months, the utility shall refund the residential customer’s deposits and shall,
at its option, either refund or pay the higher rate of interest specified below
for nonresidential deposits, providing the customer has not, in the preceding
12 months.
(a) Made more than one late payment of a bill (after the
expiration of 20 days from the date of mailing or delivery by the utility).
(b) Paid with a check refused by a bank.
(c) Been disconnected for nonpayment, or at any time.
(d) Tampered with the electric meter, or
(e) Used service in a fraudulent or unauthorized manner.
(3) New or additional deposits. A utility may require, upon
reasonable written notice of not less than thirty (30) days, a new deposit,
where previously waived or returned, or additional deposit, in order to secure
payment of current bills. Such request shall be separate and apart from any
bill for service and shall explain the reason for such new or additional
deposit, provided, however, that the total amount of the required deposit shall
not exceed an amount equal to twice the average charges for actual usage of
electric service for the twelve month period immediately prior to the date of
notice. In the event the customer has had service less than twelve months, then
the utility shall base its new or additional deposit upon the average actual
monthly usage available.
(4) Interest on deposits.
(a) Each electric utility which requires deposits to be made by
its customers shall pay a minimum interest on such deposits of 2 6
percent per annum. The utility shall pay an interest rate of 3 7
percent per annum on deposits of nonresidential customers qualifying under
subsection (2) when the utility elects not to refund such deposit after 23
months.
(b) The deposit interest shall be simple interest in all cases
and settlement shall be made annually, either in cash or by credit on the current
bill. This does not prohibit any utility paying a higher rate of interest than
required by this rule. No customer depositor shall be entitled to receive
interest on his deposit until and unless a customer relationship and the
deposit have been in existence for a continuous period of six months, then he
shall be entitled to receive interest from the day of the commencement of the
customer relationship and the placement of deposit. Nothing in this rule shall
prohibit a utility from refunding at any time a deposit with any accrued
interest.
(5) Record of deposits. Each utility having on hand deposits from
a customer or hereafter receiving deposits from them shall keep records to
show:
(a) The name of each customer making the deposit;
(b) The premises occupied by the customer;
(c) The date and amount of deposit; and
(d) Each transaction concerning the deposits such as interest
payments, interest credited or similar transactions.
(6) Receipt for deposit. A non-transferable certificate of
deposit shall be issued to each customer and means provided so that the
customer may claim the deposit if the certificate is lost. Where a new or
additional deposit is required under subsection (3) of this rule, a customer’s
cancelled check or validated bill coupon may serve as a deposit receipt.
(7) Refund of deposit when service is discontinued. Upon
termination of service, the deposit and accrued interest may be credited
against the final account and the balance, if any, shall be returned promptly
to the customer but in no event later than fifteen (15) days after service is
discontinued.
Specific Authority 366.05(1),
350.127(2) FS. Law Implemented 366.03, 366.041(1), 366.05(1), 366.06(1) FS.
History–New 7-29-69, Amended 5-9-76, 7-8-79, 6-10-80, 10-17-83, 1-31-84,
Formerly 25-6.97, Amended 10-13-88, 4-25-94, 3-14-99.
25-7.083 Customer Deposits.
(1) Deposit required; establishment of credit. Each company’s
tariff shall contain their specific criteria for determining the amount of
initial deposit. Each utility may require an applicant for service to
satisfactorily establish credit, but such establishment of credit shall not
relieve the customer from complying with the utilities’ rules for prompt
payment of bills. Credit will be deemed so established if:
(a) The applicant for service furnishes a satisfactory guarantor
to secure payment of bills for the service requested. For residential
customers, a satisfactory guarantor shall, at the minimum, be a customer of the
utility with a satisfactory payment record. For non-residential customers, a
satisfactory guarantor need not be a customer of the utility. Each utility
shall develop minimum financial criteria that a proposed guarantor must meet to
qualify as a satisfactory guarantor. A copy of the criteria shall be made
available to each new non-residential customer upon request by the customer. A
guarantor’s liability shall be terminated when a residential customer whose
payment of bills is secured by the guarantor meets the requirements of
subsection (6) of this rule. Guarantors providing security for payment of
residential customers’ bills shall only be liable for bills contracted at the
service address contained in the contract of guaranty.
(b) The applicant pays a cash deposit.
(c) The applicant for service furnishes an irrevocable letter of
credit from a bank or a surety bond.
(2) Receipt for deposit. A non-transferable certificate of
deposit shall be issued to each customer and means provided so that the
customer may claim the deposit if the certificate is lost. When a new or additional
deposit is required under subsection (3) of this rule a customer’s cancelled
check or validated bill coupon may serve as a deposit receipt.
(3) New or additional deposits. A utility may require, upon
reasonable written notice of not less than 30 days, such request or notice
being separate and apart from any bill for service, a new deposit, where
previously waived or returned, or an additional deposit, in order to secure
payment of current bills; provided, however, that the total amount of the required
deposit shall not exceed an amount equal to the average actual charges for gas
service for two billing periods for the 12-month period immediately prior to
the date of notice. In the event the customer has had service less than 12
months, then the utility shall base its new or additional deposit upon the
average actual monthly billing available.
(4) Record of deposit. Each utility having on hand deposits from
customers or hereafter receiving deposits from them shall keep records to show:
(a) The name of each customer making the deposit;
(b) The premises occupied by the customer;
(c) The date and amount of deposit; and
(d) Each transaction concerning the deposit such as interest
payments, interest credited or similar transactions.
(5) Interest on deposits.
(a) Each gas utility which requests deposits to be made by its
customers shall pay a minimum interest on such deposits of 2 6
percent per annum. The utility shall pay a minimum interest rate of 3 7
percent per annum on deposits of nonresidential customers qualifying under
subsection (6) below when the utility elects not to refund such a deposit after
23 months.
(b) The deposit interest shall be simple interest in all cases
and settlement shall be made annually, either in cash or by credit on the
current bill. This does not prohibit any utility paying a higher rate of
interest than required by this rule. No customer depositor shall be entitled to
receive interest on his deposit until and unless a customer relationship and
the deposit have been in existence for a continuous period of six months, then
he shall be entitled to receive interest from the day of the commencement of
the customer relationship and the placement of deposit.
(6) Refund of deposit. After a customer has established a
satisfactory payment record and has had continuous service for a period of 23
months, the utility shall refund the residential customer’s deposits and shall,
at its option, either refund or pay the higher rate of interest specified above
for nonresidential deposits, provided the customer has not, in the preceding 12
months:
(a) Made more than one late payment of a bill (after the
expiration of 20 days from the date of mailing or delivery by the utility);
(b) Paid with check refused by a bank;
(c) Been disconnected for nonpayment, or at any time;
(d) Tampered with the gas meter; or
(e) Used service in a fraudulent or unauthorized manner. Nothing
in this rule shall prohibit the company from refunding at any time a deposit
with any accrued interest.
(7) Refund of deposit when service is disconnected. Upon
termination of service, the deposit and accrued interest may be credited
against the final account and the balance, if any, shall be returned promptly
to the customer but in no event later than fifteen (15) days after service is
discontinued.
Specific Authority 366.05(1),
350.127(2) FS. Law Implemented 366.03, 366.05(1) FS. History–Repromulgated
1-8-75, Amended 6-15-76, 6-10-80, 1-31-84, Formerly 25-7.83, Amended 10-13-88,
4-25-94, 3-14-99.
25-30.311 Customer Deposits.
(1) Deposit required; establishment of credit. Each company’s
tariff shall contain their specific criteria for determining the amount of
initial deposit. Each utility may require an applicant for service to
satisfactorily establish credit, but such establishment of credit shall not
relieve the customer from complying with the utilities’ rules for prompt
payment of bills. Credit will be deemed so established if:
(a) The applicant for service furnishes a satisfactory guarantor
to secure payment of bills for the service requested. A satisfactory guarantor
shall, at a minimum, be a customer of the utility with a satisfactory payment
record. A guarantor’s liability shall be terminated when a residential customer
whose payment of bills is secured by the guarantor meets the requirements of
subsection (5) of this rule. Guarantors providing security for payment of
residential customers’ bills shall only be liable for bills contracted at the
service address contained in the contract of guaranty.
(b) The applicant pays a cash deposit.
(c) The applicant for service furnishes an irrevocable letter of
credit from a bank or a surety bond.
(2) Receipt for deposit. A non-transferrable certificate of
deposit shall be issued to each customer and means provided so that the
customer may claim the deposit if the certificate is lost.
(3) Record of deposits. Each utility having on hand deposits from
customers shall keep records to show:
(a) The name of each customer making the deposit;
(b) The premises occupied by the customer when the deposit was
made;
(c) The date and amount of deposit; and
(d) A record of each transaction concerning such deposit.
(4) Interest on deposit.
(a) Each public utility which requires deposits to be made by its
customers shall pay a minimum interest on such deposits of 2 6
percent per annum. The utility shall pay an interest rate of 3 7
percent per annum on deposits of nonresidential customers qualifying under
subsection (5) below when the utility elects not to refund such a deposit after
23 months.
(b) The deposit interest shall be simple interest in all cases
and settlement shall be made annually, either in cash or by credit on the
current bill. This does not prohibit any public utility paying a higher rate of
interest than required by this rule. No customer depositor shall be entitled to
receive interest on his deposit until and unless a customer relationship and
the deposit have been in existence for a continuous period of six months, then
he shall be entitled to receive interest from the day of the commencement of
the customer relationship and the placement of deposit.
(5) Refund of deposits. After a customer has established a
satisfactory payment record and has had continuous service for a period of 23
months, the utility shall refund the residential customer’s deposits and shall,
at its option, either refund or pay the higher rate of interest specified above
for nonresidential deposits, providing the customer has not, in the preceding
12 months, (a) made more than one late payment of a bill (after the expiration
of 20 days from the date of mailing or delivery by the utility), (b) paid with
check refused by a bank, (c) been disconnected for nonpayment, or at any time,
(d) tampered with the meter, or (e) used service in a fraudulent or
unauthorized manner. Nothing in this rule shall prohibit the company from
refunding at any time a deposit with any accrued interest.
(6) Refund of deposit when service is discontinued. Upon
termination of service, the deposit and accrued interest may be credited
against the final account and the balance, if any, shall be returned promptly
to the customer but in no event later than fifteen (15) days after service is
discontinued.
(7) New or additional deposits. A utility may require, upon
reasonable written notice of not less than 30 days, such request or notice
being separate and apart from any bill for service, a new deposit, where
previously waived or returned, or an additional deposit, in order to secure
payment of current bills; provided, however, that the total amount of the required
deposit should not exceed an amount equal to the average actual charge for
water and/or wastewater service for two billing periods for the 12-month period
immediately prior to the date of notice. In the event the customer has had
service less than 12 months, then the utility shall base its new or additional
deposit upon the average monthly billing available.
Specific Authority 367.121,
350.127(2) FS. Law Implemented 367.081, 367.111, 367.121 FS. History–Amended
6-1-63, 4-1-69, 9-12-74, 6-10-80, 1-31-84, Formerly 25-10.72, 25-10.072,
Amended 10-13-88, 4-25-94.
State of Florida
Public Service Commission
Capital Circle Office Center ● 2540 Shumard Oak Boulevard
Tallahassee, Florida 32399-0850
-M-E-M-O-R-A-N-D-U-M-
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DATE:
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April 26, 2012
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TO:
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Cindy Miller, Senior Attorney,
Office of the General Counsel
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FROM:
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William B. McNulty, Economic
Analyst, Division of Economic Regulation
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RE:
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Statement of Estimated Regulatory
Costs for Proposed Rule Amendment to Rule 25-6.097, F.A.C., Customer
Deposits; Rule 25-7.083, F.A.C., Customer Deposits; and Rule 25-30.311,
F.A.C., Customer Deposits
|
Summary of Rule
Rule 25-6.097, Florida
Administrative Code (F.A.C.), Customer Deposits; Rule 25-7.083, F.A.C.,
Customer Deposits; and Rule 25-30.311, F.A.C., Customer Deposits establish the
requirements for collecting, recording, and refunding customer deposits for
electric, gas, and water/wastewater utilities. They also establish the minimum
annual interest rate paid on deposits and other terms applied to interest on
deposits.
Each of the draft
rule amendments would reduce the minimum annual interest paid on deposits from
6 percent per year to 2 percent per year. The rule amendments would also
reduce the minimum annual interest paid on nonresidential deposits from 7
percent per year to 3 percent per year for all accounts held after 23 months of
continuous service. For simplicity, the rule amendments are herein referred to
as the electric rule amendment (Rule 25-6.097, F.A.C.), the gas rule
amendment (Rule 25-7.083, F.A.C.), and the water/wastewater rule amendment
(Rule 25-30.311, F.A.C.)
Economic Analysis Showing Whether the Rule Is Likely to
Have an Adverse Impact on Either Economic Growth or Business Competitiveness In
Excess of $1 Million Within 5 Years.
Subparagraph 120.541(2)(a)1, F.S., requires an
economic analysis showing whether the draft rule directly or indirectly is
likely to have an adverse impact on economic growth, private sector job
creation or employment, or private sector investment in excess of $1 million in
the aggregate within 5 years after the implementation of the rule. Similarly,
Section 120.541(2)(a)2 requires an economic analysis showing whether the draft
rule directly or indirectly is likely to have an adverse impact on business
competitiveness, productivity, or innovation in excess of $1 million in the
aggregate within 5 years after the implementation of the rule.
Staff issued data requests to the
utilities to determine the impact of the rule amendments. Each of the four
large investor-owned electric utilities (electric IOUs), including Florida
Power and Light Company (FPL); Progress Energy Florida, Inc. (PEF), Tampa
Electric Company (TECO), and Gulf Power Company (Gulf), reported an expected
reduction in the cost of capital based on the electric rule amendment. Each of
these utilities reported expected significant reductions in interest expense
and relatively minor or no increase in administrative expense. The two
investor-owned gas companies (gas IOUs) which responded to staff’s data request
(Peoples Gas Systems and Sebring Gas System, Inc) reported expected reductions
in the cost of capital. One water and wastewater company reported that it
expected a reduction in the cost of capital (Peoples Water Service of Florida,
Inc), and fourteen other water and wastewater companies reported either minimal
impact, no impact, or “not applicable” to our question about the expected impacts
of the water/wastewater rule amendment.
According to FPL and Gulf, small
businesses operating in these utilities’ service territories for the five year
period after the implementation of the electric rule amendment are expected to
experience a combined reduction in bill credits in the amount of $24,796,002
due to the rule amendment. TECO indicated that a reduction in interest to
small businesses would be expected, but did not quantify the amount, and PEF
stated there would be no meaningful impact. The gas IOUs indicated a smaller
bill credit would be provided to their customers with the implementation of
the gas rule amendment compared to the existing rule. For instance, Peoples
Gas indicated that its bill credit associated with deposit interest would be
reduced by $8.5 million over the five year period. Only one water/wastewater
company indicated a specific impact of the implementation of the rule on bill
credits provided to customers. Peoples Water Service Company of Florida, Inc.
reported reduced bill credits of $3,750 for the five year period after
implementation of the water/wastewater rule amendment.
The expected reduction in bill
credits to customers associated with draft rule changes does not constitute an
adverse impact on economic growth, private sector job creation or employment,
or private sector investment. The rule amendments adjust the applied interest
rates to comport more closely with current market-based interest rates, to
improve equity to customers, and to promote efficient pricing of utility
services.
Based on this analysis, the rule
amendments are not likely to have an adverse impact on economic growth, private
sector job creation or employment, or private sector investment in excess of $1
million in the aggregate within 5 years after the implementation of the rule.
Likewise, the rule amendments are not likely to have an adverse impact on
business competitiveness, productivity, or innovation in excess of $1 million
in the aggregate within 5 years after the implementation of the rule
amendments.
Economic Analysis Showing Whether the Rule Is Likely to
Increase Regulatory Costs In Excess of $1 Million Within 5 Years
Subparagraph 120.541.(2)(a)3, F.S., requires an
economic analysis showing whether the draft rule directly or indirectly is
likely to increase regulatory cost, including any transactional costs, in
excess of $1 million in the aggregate within 5 years after the implementation
of the rule. Based on the responses to staff’s data requests, the proposed
reductions in interest rates are expected to yield a slightly lower cost of
capital, so regulatory costs, including transactional costs, are expected to be
slightly lower for electric IOUs and gas IOUs under each of the draft rule
amendments. There may be some level of reduced capital costs for some
water/wastewater companies, but the impacts for most companies will be a
minimal reduction or no impact to costs. Thus, for each rule amendment, it is
unlikely that the amendment, if approved, will increase regulatory costs,
including any transactional costs, in excess of $1 million in the aggregate
within 5 years after the implementation of the rule amendment.
Estimated Number of Entities
Required to Comply and General Description of Individuals Affected
Subparagraph 120.541.(2)(b),
F.S., requires a good faith estimate of the number of individuals and entities
likely to be required to comply with the rule, together with a general
description of the types of individuals anticipated to be affected by the
rule. The number of companies affected by the rule amendments include 5
electric IOUs, 7 gas IOUs, and 147 water/wastewater companies.
Rule Implementation and
Enforcement Costs and Impact on Revenues For The Agency and Other State and
Local Government Entities
Subparagraph
120.541(2)(c), F.S., requires a good faith estimate of the cost to the agency,
and to any other state and local government entities, of implementing and
enforcing the proposed rule, and any anticipated effect on state or local
revenues. The FPSC is the agency with the jurisdiction to implement and
enforce amendment to the rules, and the draft changes to the rules are not
expected to impose any additional costs on the FPSC. The rule amendments, if
approved, would not impact the costs of other state or local government
entities. The rule amendments would have no impact on FPSC revenues or
revenues of other state and local government entities.
Estimated Transactional Costs
to Individual and Entities
Subparagraph
120.541(2)(d), F.S., requires a good faith estimate of the transactional costs
likely to be incurred by individuals and entities, including local government
entities, required to comply with the requirements of the rule. The
transactional costs for electric and gas utilities are expected to decrease
slightly under the rule amendments, based upon expected reductions in the cost
of capital. For most water and wastewater utilities, the transactional costs
associated with the rule amendment are expected to be unchanged compared to the
current level of compliance costs, but some utilities may see a slight
reduction in the cost of capital.
Impact On Small Businesses, Small Cities, Or Small Counties
Subparagraph
120.541.(2)(e), F.S., requires an analysis of the impact of the proposed
changes on small businesses as defined by Section 288.703, F.S., and an
analysis of the impact on small counties and small cities as defined in Section
120.52, F.S. The most direct impact of the rule amendments on small businesses
will be a reduction in bill credits associated with the reduction in the
deposit interest rates. Most electric IOUs expect their small business
customers will experience a reduction in bill credits. The first year impact
for the industry is at least $3.18 million for FPL and Gulf customers combined,
and an unquantified impact for TECO customers. Over the longer term,
reductions in the cost of capital may be reflected in customers’ base rates.
The rule amendments are expected to result in reductions in the amount of bill
credits issued to customers of gas IOUs and some water/wastewater companies,
occurring with a concomitant reduction in base rates over the longer term
associated with reductions in the cost of capital. The electric IOUs, the gas
IOUs, and the water/wastewater companies indicated that the rule amendments
would result in no impact to small cities or small counties.
Additional Information Deemed
Useful By The Agency
None.
cc: Braulio Baez
Marshall Willis
Cheryl Bulecza-Banks
Andrew Maurey