Ordinance No. 8,941Published in the Baytown Sun 20000713 -1
Tuesday, July i8,- 2000 and
Wednesday, July 19, 2000. ORDINANCE NO. 8941 J
AN ORDINANCE OF THE CITY COUNCIL OF THE CITY OF BAYTOWN,
TEXAS, ESTABLISHING THE MAXIMUM HOURLY SERVICE CHARGE TO
BE USED TO DEVELOP THE EQUIPMENT AND INSTALLATION RATES OF
TEXAS CABLE PARTNERS, L.P.; ESTABLISHING THE MAXIMUM
PERMITTED RATES FOR EQUIPMENT AND INSTALLATION CHARGES;
DISALLOWING THE INCLUSION OF CONVERTER RETRIEVAL COSTS
AND HOURS; SETTING FORTH OTHER PROVISIONS RELATED TO THE
SUBJECT; PRESCRIBING A MAXIMUM PENALTY OF FIVE HUNDRED
AND NO /100 DOLLARS ($500.00); PROVIDING A REPEALING CLAUSE;
CONTAINING A SAVINGS CLAUSE; AND PROVIDING- FOR THE
PUBLICATION AND THE EFFECTIVE DATE THEREOF.
WHEREAS, the City of Baytown, Texas (the "City "), is certified to regulate cable
equipment and installation rates pursuant to the 1992 Cable Act (the "Act ") and Federal
Communication Commission ( "FCC ") rules; and
WHEREAS, on or about February 29, 2000, Texas Cable Partners, L.P. ( "TCP ") submitted
to the City an FCC Form 1205 with a proposed schedule of equipment and installation rates
(hereafter "Form 1205 "); and
WHEREAS, the FCC rules allow the City ninety (90) days to review the proposed schedule
of equipment and installation rates after which time the operator may implement such rates, subject
to a prospective rate reduction and refund if the City subsequently issues a written decision
disapproving any portion of such rates; and
WHEREAS, at the City's request, C2 Consulting Services, Inc. ( "C2 "), has reviewed TCP's
proposed schedule of equipment and installation rates and submitted its report explaining its
analysis, findings, and conclusions, which is attached hereto as Exhibit "A" and incorporated herein
for all purposes; and
WHEREAS, a public hearing was held to hear public comments on the proposed schedule of
equipment and installation rates of TCP; and
WHEREAS, the City Council has now concluded its review of TCP's proposed schedule of
equipment and installation rates and made certain determinations; NOW, THEREFORE,
BE IT ORDAINED BY THE CITY COUNCIL OF THE CITY OF BAYTOWN, TEXAS:
Section 1: That the City Council hereby adopts and affirms the findings and recitals set
forth in the preamble to this Ordinance.
Section 2: That the City Council, having reviewed TCP's proposed schedule of
equipment and installation rates and the report submitted by C2, hereby finds and determines that
20000713 -1a
TCP's proposed equipment and installation rates, with the exception of the monthly equipment lease
rates for addressable and nonaddressable converters, are reasonable.
Section 3: That the City Council hereby finds and determines that, based on the report
from C2, the inclusion of converter retrieval costs and hours in the development of the Houston
Division's East Form 1205 is unreasonable and, therefore, disallowed.
Section 4: That TCP is hereby ordered to:
(a) reduce its Hourly Service Charge for installation, maintenance and repair of
equipment to an amount not to exceed TWENTY -NINE AND 78/100 DOLLARS
($29.78) per hour;
(b) reduce the monthly equipment lease rate for addressable converters to an amount not
to exceed THREE AND 39/100 DOLLARS ($3.39);
(c) reduce the monthly equipment lease rate for nonaddressable converters to an amount
not to exceed ZERO AND 62/100 DOLLARS ($0.62);
(d) reduce all other equipment and installation rates to an amount not to exceed the
amounts shown in Form 1205 submitted by TCP to the City; and
(e) refund to subscribers, within forty-five (45) days of the adoption of this Ordinance,
the difference between the maximum permitted rates established herein and the
actual charges to the extent that actual charges have exceeded such maximum
permitted rates, plus interest on such amounts calculated in accordance with FCC
rules.
The Hourly Service Charge rate, the service and installation rates, and the monthly
equipment lease rates were derived by using FCC rules, regulations, and instructions for calculating
same, as further explained in the report from C2 attached hereto as Exhibit "A," and which is
incorporated herein by reference for all intents and purposes.
Section 5: That the City Council hereby finds and determines that the rates established
hereby are reasonable.
Section 6: That in adopting this Ordinance the City Council of the City is not approving
or acquiescing in any way whatsoever to cost data and/or methodologies not specifically addressed
in this Ordinance. Furthermore, the City Council is not waiving any rights to which it is entitled.
Section 7: Pursuant to the authority granted to the City under Title 47 C.F.R.
§ 76.943(a) and Tex. Loc. Gov't Code § 54.001, should TCP fail to comply with any provision
of this Ordinance, it shall be deemed guilty of a misdemeanor and, upon conviction, shall be
punished by a fine in an amount not to exceed FIVE HUNDRED AND NO /100 DOLLARS
® ($500.00). Each day of each violation shall constitute a separate offense. In addition to the
penalty prescribed above, the city may pursue other remedies available.
2
20000713 -1b
Section 8: All ordinances or parts of ordinances inconsistent with the terms of this
Ordinance are hereby repealed; provided, however, that such repeal shall be only to the extent of
such inconsistency and in all other respects this Ordinance shall be cumulative of other
ordinances regulating and governing the subject matter covered by this ordinance.
Section 9: The City Council of the City of Baytown, Texas, does hereby declare that if
any section, subsection, paragraph, sentence, clause, phrase, word or portion of this Ordinance is
declared invalid or unconstitutional by a court of competent jurisdiction then, in such event, it would
have passed and ordained any and all remaining portions of this Ordinance without the inclusion of
that portion or portions which may be so found to be unconstitutional or invalid, and declares that its
intent is to make no portion of this Ordinance dependent upon the validity of any other portion
thereof, and all said remaining portions shall continue in full force and effect.
Section 10: That the City Clerk is hereby authorized and directed to mail a copy of this
Ordinance by first class mail to TCP.
Section 11: This ordinance shall take effect from and after ten (10) days from its
passage by the City Council. The City Clerk is hereby directed to give notice hereof by causing
the caption of this ordinance to be published in the official newspaper of the City of Baytown at
least twice within ten (10) days after passage of this ordinance.
INTRODUCED, READ, and PASSED by the affirmative vote of the City Council of the
City of Baytown, this the 13th day of July,. 2000.
ATTEST:
lX
64Y W. SMITH, City Clerk
APPROVED AS TO FORM:
ACIO RAMIREZ, SR.LfAty Attorney
c:k1h253\ Counci1\ 0rdinances 100- 1205BaytownRevised
3
PETE C. ALFARO, Mayor
. MONSULTING SERVICES, INC.
7801 Pencross Ln.
Dallas, Texas 75248
April 17, 2000
Ms. Eugenia Cano
Mr. Ron Cox
City Attorney
City Manager
City of Alvin
City of Friendswood
216 West Sealy Street
910 South Friendswood Drive
Alvin, Texas 77511
Friendswood, Texas 77546-4856
Mr. Tommy Cones
Ms. Donna Sams
Administrative Assistant
Controller
City of Nassau Bay
City of Baytown
1800 Nasa Road One
2401 Market Street
Nassau Bay, Texas 77058
Baytown, Texas 77522
Ms. Jean Raffetto
The Honorable Einar Goerland
City Secretary
Mayor
City of El Lago
City of Taylor Lake Village
98 Lakeshore Drive
500 Kirby
El Lago, Texas 77586 -6398
Taylor Lake Village, Texas 77586 -5298
Ms. Carol McLemore
Mr. Nick Finan
City Manager
City Manager
City of La Marque
City of League City
1111 Bayou
300 West Walker
La Marque, Texas 77568
League City, Texas 77573
Mr. Tom Pedersen
Mr. Ron Wicker
City Secretary
City Manager
City of Texas City
City of Seabrook
1801 9th Avenue North
1700 First Street
Texas City, Texas 77592
Seabrook, Texas 77586
Mr. Don Taylor
Ms. Cheryl Wilson
City Manager
Olson & Olson
City of Dickinson
3485 Three Allen Center
2716 Main Street
333 Clay Street
Dickinson, Texas 77539
Houston, Texas 77002
Mr. Joe Dickson
Mr. Roger Carlisle
City Manager
City Manager
City of Santa Fe
City of Webster
PO Box 950
311 Pennsylvania
Santa Fe, Texas 77510
Webster, Texas 77598
Dear City Representatives:
Tel. (972) 726 -7216
Fax (972) 726 -0212
C2 Consulting Services, Inc. ( "C2") has completed the evaluation of the FCC Form 1205 filed by
Texas Cable Partners, L-P. ( "TCP" or the "Company ") with the Cities on or about February 29,
41 2000. This is TCP's second year to file a Form 1205 with the Cities regarding its proposed
changes in equipment monthly lease rates and installation and maintenance charges. As you
City Representatives
April 17, 2000
Page 2
recall, the last filing was based on a fiscal year 1997 national filing by TCI /AT &T.' TCP
amended this filing and the Form 1205 rates ultimately adopted by the Cities were based on
TCl/AT &T system specific costs for the Houston and Houston Bay areas for the fiscal year 1998
period. The instant filing is based on the TCP/Time Warner operations within the State of Texas
for the period ended September, 1999.
This study does not constitute an examination of the financial condition of TCP or its parent
company. As such, C2 cannot and does not express any position with regard to the accuracy or
validity of the financial information provided by TCP during the course of the analyses_
BACKGROUND
In its 2000 Form 1205 filing, TCP proposes to increase its hourly service charge (and many
resulting installation rates) and decrease all of its monthly equipment lease rates. The following
table provides a comparison of TCP's 1999 rates and TCP's proposed 2000 Form 1205 rates:
COMPARISON OF EQUIPMENT AND INSTALLATION RATES
1999 MPR'
2000 MPR`
Difference
Hourly Service Charge
$26.49
$29.78
$3.29
Service
Install - Unwired home
$39.50
$29.78
$(9:72)
Install - Prewired home
$21.00
$17.27
$(3.73)
Install - Additional connect initial
$12.00
$13.40
$1.40
Install - Additional connect separate
$18.75
$27.40
$8.65
Relocate Outlet
$18.75
$17.27
$(1.48)
Upgrade (non - addressable)
$12.95
$29.78
$16.83
Downgrade (non - addressable
$6.95
$29.78
$22.83
Montihly Lease Rates
Remotes
$0.30
$0.29
$(0.01)
Non addressable converters
$1.55
$0.64
$(0.91)
Addressable converters
$3.49
$3.44
$(.05)
'Maximum Permitted Rate
TCP's proposed 2000 rates are based on a single Form 1205 calculation that was provided to each
of the franchising authorities impacted. However, each of the components of the aggregated
filing is a sum of that same component on Form 1205 filings developed for the following five
Time Warner divisions operating in Texas:
® Based on the information provided to C2, TCP bean operating the systems on or about December 1,
1998.
l
I
City Representatives
April 17, 2000
Page 3
• Austin Division
• Houston Division (East and West, with East being previously operated by TCI)
• San Antonio Division
• Southwest Division
• Waco Division
Therefore, each individual Form 1205 must be reviewed for accuracy and the appropriateness of
any computations.
ANALYSES OF THE FILINGS
Project Objectives and Activities
The project objectives are three fold:
1. Assessment of the completeness of the filings with regard to the information and
documentation that must be filed with the Cities.
2. Assessment of the reasonableness of the proposed computations in light of FCC
regulation, recent FCC rulings and prior ownership and operations of the system
included in the calculations.
3. Assessment of the reasonableness of the proposed computations in light of TCP's
proposed method of aggregation.
Given these objectives, C2 conducted the following project activities:
• Review of the filings to assess the completeness based on the FCC Form 1205
instructions.
• Review of the filings to identify any issues with respect to the data and/or
methodologies employed by TCP.
• Submission of follow -up data requests and subsequent review of TCP's responses.
• Review of recent FCC decisions that may have an impact on TCP's proposed
methodologies or the Cities' alternative actions.
• Development of potential alternatives available to the Cities in establishing
maximum permitted equipment and installation rates.
Summary of Findings
C2 identified two main issues with respect to TCP's proposed computations of maximum
permitted equipment and installation rates. The issues are:
1. The computation of the Hourly Service Charge ( "HSC ") and the monthly lease rates
inappropriately include both the costs and hours related to converter retrieval in the
previously owned TCI systems.
2. It does not appear that Time Warner has instituted adequate quality control measures
to assure that the five Texas divisions follow standard methods by which the data are
derived, accumulated and/or allocated to the Form 1205 computations.
City Representatives
April 17, 2000
Page 4
1. Converter Retrieval Costs/Hours in HSC and Converter Lease Rates
Within several of the Time Warner divisions are a number of previously owned and operated TCI
systems that were transferred to the control of Time Warner in November 1998. Prior to that
rime, TCI had filed aggregated Form 1205s that included all its owned and/or managed systems
on a national basis.
C2 reviewed the TCI Form 1205s for many of these Texas systems for the period 1996 through
1998. In 1999, Time Warner presented the Form 1205 filing based on information that was
provided by TCI.2 In the 1996 -1998 filings, C2 determined costs and hours concerning converter
retrieval had inappropriately been included in the development of the HSC and the monthly
equipment lease rates. C2's argument was premised on (1) these costs (and hours) were not
related to "new activities," but in fact, were related to activities conducted during the period of
"unbundling" in the Form 1200/1205 process; and (2) TCI had not unbundled the costs related to
these activities into the equipment basket (thereby continuing to recover them from the monthly
programming services rates). C2 concluded that allowance of these costs in the equipment basket
would provide for a double recovery from the subscribers served by these systems.
In the 1999 Time Warner Form 1205 filing related to the systems that had been transferred from
TCI, TCI provided Time Warner with computations that did not include converter retrieval costs
or hours_ These 1999 filed rates are the rates that were adopted by the franchising, authorities.
However, in the instant filing, TCP has included converter retrieval costs and hours again for
these prior TCI systems. Not only is the Company collecting from the basic service rates in these
systems, but it is also attempting to collect these same costs from all other subscribers through
equipment and installation rates.
The FCC recently ruled on this issue in DA 99 -2227:
MACC disallowed TCI's recovery of costs associated with disconnects and converter
retrievals based on the consultant's finding that these costs were not unbundled from the
operator's programming charge. TCI appealed this action but does not dispute the
unbundling finding. Because an operator cannot include in the equipment basket costs
that were left in the base programming service rates. .. TCI's appeal on this point is
denied.'
Therefore, the inclusion of the converter retrieval costs and hours by TCP in the previously
managed TCI systems should be disallowed in determining the combined divisions' HSC. In
addition, the labor costs assigned to the repair and maintenance of converters should not include
the hours related to the retrieval of converters from the subscribers' premises for these systems.
Based on the information provided, the only converter retrieval costs and associated hours that
can be specifically identified relate to the Houston systems. The impact of deducting the
converter retrieval costs and associated hours from the Houston Division East's Form 1205, and
z Time Warner's amended 1999 Form 1205 filing in the Houston East systems was based on a fiscal year
end December 31, 1998.
' Nlemnrandl M Opinion and Order, DA 99 -2227. released October 21; 1999, paragraph 18.
City Representatives
April 17, 2000
Page 5
thereby reducing the combined Form 1205 computations, results in no change to the HSC, but
reduces the monthly equipment lease rates as follows: 4
• Non addressable converters - $0.64 to $0.62
o Addressable converters - $3.44 to $3.39
Additional adjustment should be made upon receipt of converter retrieval information for the
other TCI /AT &T systems transferred to Time Warner operations.
2. Apparent Lack of Standard Quality Controls
During the review of the five Texas divisions' Form 1205 computations, C2 noted that the
development of certain data and/or methodologies varied among divisions. For example, some
systems used the actual contract labor costs and others developed an average annual cost based on
average annual jobs times average costs per job. The supporting documentation provided by each
division also varied significantly.
For purposes of the instant filing, it does not appear that the lack of standardization has resulted in
any significant impact to rates (outside of the above issue, and in light of the fact that most of the
rates have been reduced for the 2000 rate year). However, for future filings, TCP should be
required to demonstrate that a standard methodology is being used, that the divisions are
following such standards, and that the Company has instituted quality control measure to test the
reliability of each division's computations.
SUMMARY OF RECOMMENDATIONS
Based on the above findings and conclusions, the Cities should consider taking the following
actions:
1. The City should consider disallowing the converter retrieval costs and hours used in the
development of the Houston Division's East Form 1205.
2. The City should consider adopting a maximum permitted non - addressable converter rate
of $0.62 per month.
3. The City should consider adopting a maximum perntted addressable converter rate of
$3.39 per month.
4. The City should order TCP to issue refunds to subscribers within ninety (90) days of a
rate order based on the difference between the ordered rate and the implemented rate if
such order is passed subsequent to June 1, 2000. Interest on the refund amount should
accrue to the time the refund is issued.
5. The Company should be required to institute quality controls for consistency in the
reporting of data by Time Warner divisions should the Company continue to employ this
aggregated methodology.
There are also systems that were previously owned by TC1/AT &T in at least one of the other divisions.
C2 notes that the Harlingen system is part of the Southwest Division computations. Although requested,
Time Warner has not provided the amount of converter retrieval costs for the other systems previously
operated by TCL
City Representatives
April 17, 2000
Page 6
C2 appreciates having this opportunity to work again with the Cities in review of the Form 1205
rates. If you have any questions regarding this report or need clarifications as to the
recommendations, please contact Ms. Connie Cannady at (972) 726 -7216.
Very truly yours,
C2 Consulting Services, Inc.
FaomW Comm.mvlYws Ca and �
WrbY fw D.C. 2DS54
NiN- T'liR�1 /`MT <I.PCRNf`L'.YIT�I�. � •o. .u�
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IMuYwYYa
P- obt:..
OIMsr 1.
(S it belarl
lllisf 2.
4spify b.".1
C.— Bode Vales
$11.VW.W1U. 14
$7.574.421 07
132,064 U)
S224779 71
$6.%407
A--l—/ ec.a,a.,
S7,742,975:99
S5,143,793.6U
S27,24u (.1
$0,990.59
fl,,5,w(17
Def—d T—
5231,113.19
S477,734.8U
S1.326.UU
161r K,
156.47'_541
N. faouk V.)- B4C *D,
S3,924911AW
$1,952,90.3.47
$3,49400
$160.1 UI U8
$6.47157
Mrs 4 k.0 ,
U 1125
Cak.blwa G Raw
FWd W I.— T- ku
0.35
Sus I--- TaY R"
0.
Na ToW k. Ta Rue 4O1 x020-(01 s 02)
0.35
Ad W P.G d ba—w Ded, ",
Amin Io9asu AYwu1Y
S2U,382,QW.0D
Taut tin Ass.
SIU,412,25S.URiAU
Bss Rmin m 1-.= g AmwYY 104b . Fj
Sl 179 129 687.50
I k-- D.d.. b1 F.m 104.,(Vl
0.2449
Edoans T.a Rre 63911 -04d1 C wG7
0.2643
fv NonC
Ba.e Remo m lore.lmau Ammo 1134c 1
$1,179,139,697.50
Dumb.'—
$1,046.971,000.00
Cu,ub4rr. (—y ow sacseJ 066)
SU. W
I R.a— S..b w Iaoom. Tu (G&.061,.C,6.1
5131.1 S7,610.50
k— Pa amww Sub2m w k— Tae (GWIG&I
0.1113
Cn Up RYts JC l 4 1 q5 Qhr.l /(I4GS YG6c I)l
1.0303
Q ..e& ; Rue d Rs F . 071
0.1159
lk . oo In..wn.,d 01—d-Up fu T . H
$45S,171.73.41
5224362.7673
S4i/5.4563
$19,557 3419
$7u12116
linos 17w..ra fa. scow,
$4,967,925.98
15(0),779 UI
V.4 4 W
5:1.,11,9 9'
Sues
MYwel C.Pasl Coo j l•J1
1 52,323,097.6141 1
$736,141.7773
SI.979. 4.5d.3
544,7261619
S7502378
GkAND TOTAL J— d Lie C .Ywxs1
I 53,l(A sp&u72
Spm* cgbw I. -
Spmly: lahw 2.
IffDU1.E 9: ANNUAL OPL72ATLNG EXPENSES FOR SERVICE INSTALLATION AND MAINTENANCE OF FOUIPAIENT' I
p F+W.n fu S— U-11. uw M.in, 0f
TOTAL 1.— d lir A —6..1
Sp-,fy. fAGs 2.
5892,317.95 1 $317.521151
xlwr'1'.,..ea �5,n,� below, 1 ,Sl,ee,ry lwlawi
5629.`14�7.2�1 57.670,95050 51.968.921 48
A4W, -.d by. 1Il13 ]JW V71U
Fes\ F,ew I2JS
Yag, 2 llxvl 4 U fur W uWluw. lux I9A
F.Or.L Cat®m.atlom Commrt4m
W&uh.Vws4 D.C. 24354
Ayl.a.d by. AlB 3LMW W
HED' -ff.- COSTS Of 1 AS D CUSTOb" EQUEPNENT
Aw Haw p. LL+.r<rd 11® k.W1.0m im.eh
R.Ma1. 1
K.•..,.. 2
Ke wt. 3
C.—I- I
G.1verla 2
C: w na 3
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Tool ►'-- •- -^^"SrM�'me H -1An -h Ir>rt..0
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1.7314
16760 .
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T.W . of Lkou m Servmc
691439.
tu%2
976606.
cxo baai V-J—
57,540,103.75
$4,'177 °127 56
5190,439,961.47
Aocu L-1 run
14,91 IAW.22
$4,779,( wi3 4M
$77,741.015 15
Wf-d T—
15296,751.91)
(553,131 -171
$4,4MOM•l 20
1r Hoot V.9- IL)4E,Fll
$3,234,025.44
w.w
w.W
5251,40145
SI0tl211,759.12
ww
suW
C—.d-C k. alHaan JFlom Srhd. A, L.te H
0.11S9
Ri m L—mmml OrooW- for T— 10 M H
5374 535.7471
$.00
w. W
S' -9,140 -1643
$12.542.92416419
$0.00
$0.00
C1.rsm hovrm for mrl.n
$1,495.731.4,
$175.53. U.
522.205,079 .32
Aaa.rl CpAW Cm. (If 11
51.560.5901471
SU.0)
3.011
5:0.690.5243
$34.745.799.%19
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"&%u TOTAL I"—.i Sir Jc nr—I
f3fi114.W15."u
Ar J.
ILLDUU D: AVEAAGE HOURS PER ViSTALSATiON
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A.cr How Rswirad Home Illilwll.tmll l.u.ch m w lance )
t 1
A Hoes A4dmurl Cmwwan 6wall—at Tmr oflni W hrl.ILMmn(Mt+h m 1.n.lion)
n
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Yom) 6-1 4 u Li. W..W- Imr 1996
FaimW C40mun a(m Cammr.m
Wo"War, D.C. 20551
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XKMWY" CALCULATING TOTAL CQlWhWrT AND UaTAUATION Com
TOW Cmpaa Cm of hWgUl m nd ldamat.me &h.& - A. El- I I
I S3.10tO952472
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S27.StNA+u ea
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S.W.610,635i "72
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336,nI J,UW.6333
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S36.%11,u11u 6373
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PAW 6 L:—1 4 .0 tm Wuukw l�r I9%
Finaa1 Qmmw d m Crw.t..m
W—M.40uftD.0 20554
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b Are La.aYe m
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529.7Y
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$17.27
1. kw dlr of Additrmal C— . L— r Tmr of buL.1 h.tdlr.at I SgT B, Late 90
$13.40
4. ImW lreao of Adda"W C� 1-WI I Sup f1, L— 9O7 1
$27.39
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Cannata Baa Typt 1:
w.62
Caaata B,._ T 2:
$3.39
Coorata Lk- T 3:
M.aN far La.e of Cd— E. Lm 33
ahra 1 1
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CF far T.sa f J I I!iLp F. I.— 34.35 u 36c
52979
OR COAT AND POLWY CHANGLb "
ar ya tar..a a The Uloo'ni lama "mum by fang an -x' m On i pWvplc bat
M ya aoludnd tho lebw Com maom.ad Wah.rhaat m aWa drop m yow �Kgw for al d imWlaTOn?
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NO
LTWWATIO+t STATEMENT
WD.L.FIA. FALSE SfATEM3MS MADE ON TM FORM ARE Pt NWIAB n BY FBIH AND/OR WRL%obaw'1'
W-1 OODE TrMH 14 SE MN 1001 x AND/OR FORFEFiURE (U.& OWIf TM2 47. SEf nON 503).
I WUJY Ih. ths.iamsda made a th. farm M Uw and oo.a. w The he. of my Iao kdp and bd oC sod we ae.de m goad &A L
N— Cale Oparae Sgglrt..s
Dw TAW
Ll
Apprord by LWIB 3u0ld7W
FCV Farm t _l15
P%. I L� l 4 ri 1w W u..l i— 19Y6