5.5 ERMUSR 03-17-2015 2015 FEDERAL POSITION STATEMENTS
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Table of Contents
The EPA Clean Power Plan —
Minnesota Needs Major Changes in the Final Rule 3-6
Preserve and Protect Tax-Exempt Financing 7
Grid Security 8
Captive Rail Shippers Need Reform 9
Why Public Power? 10
Municipal Electric and Gas
Utilities of Minnesota 11
Photo/graphic credits:
All photos,graphics and tables by MMUA,except for:
Cover: U.S. Government Photo
Page 4, bottom photo, courtesy of MMPA
Page 6, National Renewable Energy Lab
Page 10,courtesy of Owatonna People's Press
Back cover,Architect of the Capitol, public images
larrigivie am:1 0
Position Statement
The EPA Clean Power Plan —
Minnesota Needs Major Changes in the Final Rule
The electric utility industry is suddenly facing more
/7--- -
than a dozen environmental regulations over the next
few years on a host of issues, including air pollutants,
greenhouse gases, water, and coal combustion residuals.
Several regulatory programs could transform the
entire electricity industry,causing major concerns over
reliability of the grid and possible significant increases
/
in consumer rates.The most problematic regulatory ii effort for Minnesota is EPA's Clean Power Plan, a
major undertaking that seeks significant nationwide /
reductions in carbon dioxide emissions from existing
power plants. r`
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On June 18, 2014, the U.S. Environmental Protection r '
Agency(EPA)published a proposed rule known as the
Clean Power Plan(CPP).The CPP would establish r
emission guidelines for existing electric generating units t
(EGUs)under section 111(d) of the Clean Air Act(CAA).
EPA is expected to issue the final version of the CPP
in mid-summer 2015.MMUA filed extensive comments
on the proposed rule.The final rule will likely contain '
significant changes and clarifications. a=/,
Legal Issues
The CPP is very different from clean air regulations
developed by EPA in the past. It is subject to numerous
legal challenges and is probably more susceptible to ,'
being overturned than most new regulations. A.
Section 111(d)of the CAA is intended to regulate f
stationary sources of air pollution,but the CPP doesn't
regulate individual sources, such as power plants. It
regulates states.The law intends that states develop ! /
plans which establish standards of performance for 1j,it
power plants. But the CPP turns this process on its head
and makes states the regulated entities rather than the The CapX2020 transmission lines will serve Minnesota's
regulators that the law intends them to be. expected growth and help begin to meet Minnesota's
Of the nearly 100 New Source Performance Standards Renewable Energy Standard (RES). The Brookings County
(NSPS) and emission guidelines EPA has developed Hampton 345 kV line (pictured) will expand access to
wind resources by adding about 700 MW of capacity to the
since 1970,every one has been based on a"system of transmission grid.This line,along with other projects recently
emission reduction"that is incorporated into the design completed or currently under construction or in the planning
or operation of individual sources.The CPP instead stages, has the potential to add nearly 2,000 MW of wind
uses a series of"building blocks"that go well beyond the capacity to the transmission grid. It's estimated Minnesota
operational characteristics of the power plant that is needs about 5,000 MW of renewable energy to meet the RES,
the source of the CO2 emissions that the EPA wants to one of the nation's most aggressive renewable energy laws.
reduce. Unfortunately, early actions to reduce greenhouse gases are
not recognized under the Clean Power Plan as proposed.
The EPA would replace the Federal Energy Regulatory
Commission and the states to become the primary
2015 Federal Position Statements/3
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regulator of electric power within the United States,
including regulating(i)the dispatch of electric
generation, (ii)the amount of renewable power to be
built, and(iii) the electricity consumption of customers.
This is an enormous and transformative expansion in
EPA's regulatory authority without clear congressional
authorization, which is precisely what the Supreme
Court recently invalidated in UARG v. EPA, 573 U.S. at
2431 (2014).
CPP treatment of early action
Under EPA's methodology, states are assumed to achieve
minimal reductions in CO2 emissions from the electric
utility industry during the 15-year period from 2005 to
2020. States are then required to achieve their entire
assigned reduction(41 percent for Minnesota)during
the 10-year period from 2020 to 2030. This construct not
only flies in the face of reality in early adopter states
such as Minnesota,it also ignores the incremental pace
of change that occurs in the highly regulated and capital-
intensive electric utility industry.
Although the goal of the CPP is to achieve a 30 percent
reduction in 2005 carbon dioxide emissions,the actual it
base year for the plan is 2012. Reductions in CO2 :<, t
emissions achieved during the seven-year period from 1/
2005 to 2012 are completely ignored by EPA's formula. ' ! rz "` $ ��
Further, any CO2 reductions during the eight-year
period from 2013 through 2020 beyond EPA's modest Minnesota utilities have been diligently adding renewable
assumptions should count toward achieving the state's resources for years.These two wind turbines south of Fairmont
goal. were dedicated in 2003.They are owned by SMMPA and feed
directly into the Fairmont Public Utilities distribution system.
Minnesota Greenhouse Gas Reduction Efforts
Minnesota has been a leader in the Upper Midwest in
developing state energy policy to reduce greenhouse
gas emissions. Minnesota has established a goal of
reducing greenhouse gas emissions from 2005 levels by
15 percent by 2015, 30 percent by 2025 and 80 percent
by 2050. Our RES requires power suppliers in the state
other than Xcel to achieve 25 percent renewable energy - "' �•• '" ""`
by 2025.Xcel, which accounts for about 46 percent of 4°'_ — - _ _
total sales,is required to achieve 30 percent renewable
energy by 2020. Minnesota has banned the construction The Hometown BioEnergy plant near LeSueur, owned by the
of or purchase from large new coal-fired power plants Minnesota Municipal Power Agency,produces fuel made from
and imposed one of the most stringent energy efficiency refined food and agricultural processing wastes. The eight-
requirements in the country. megawatt plant entered service in 2014.
The Sustainable Building 2030 program requires least 1.5 percent of retail electric sales made by investor-
performance standards for new and substantially owned utilities must come from solar energy.
reconstructed buildings to reduce their CO2 emissions
by 60 percent in 2010; 70 percent in 2015; 80 percent in Greenhouse Gas Reduction Program Results
2020; and 90 percent in 2025. It is an energy goal of the A review of Minnesota data clearly shows both how
state that by 2030, 10 percent of the retail electric sales effective Minnesota's efforts have been, and how severe
in Minnesota be generated by solar energy. By 2020, at the penalty can be for an early adopter state.
2015 Federal Position Statements/4
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Figure 1
Annual Minnesota Generation from Selected Sectors,Sales,and Electric Industry CO2 Emissions 2005-2012
Electricity Net Electricity Net Electric Power Total
Electricity Net Generation Generation Electricity Net Minnesota Industry Carbon
Generation From From Nuclear Generation Total Retail Carbon Dioxide Dioxide
From Coal Natural Gas Electric Power From Wind Sales Emissions Emission
1,000 Metric Rate
Year mWh mWh mWh mWh mWh Tons lbs/mWh
2005 32,949,845 2,707,267 12,835,219 1,582,477 66,019,053 39,516 1,640
2006 33,070,451 2,560,797 13,183,418 2,054,947 66,769,931 38,183 1,578
2007 32,190,373 3,842,477 13,103,000 2,638,812 68,231,182 38,321 1,548
2008 31,755,253 2,865,846 12,996,838 4,354,620 68,791,615 36,821 1,479
2009 29,327,226 2,846,483 12,393,425 5,053,022 64,004,463 33,689 1,412
2010 28,082,550 4,340,847 13,478,046 4,791,723 67,799,706 32,946 1,350
2011 28,258,626 3,350,773 11,958,525 6,725,695 68,532,708 32,618 1,351
2012 22,722.774 7,088,205 11,943,790 7,615,408 67,988,535 28,494 1,201
Change -31% 162% -7% 381% 3% -28% -27%
Source: EM Minnesota Electricity Profile, Tables 5, 7,and 8
2005—2012 Unfair treatment of early adopter states
Figure 1 shows a 27 percent reduction in Minnesota's Minnesota is on track to achieve reductions in CO2
annual power sector CO2 emissions from 2005 to 2012. emissions from electric generation of perhaps 30 percent
As we point out below, Minnesota's newest'and most during the fifteen year period from 2005 to 2020. These
efficient coal plant was off line during all of 2012, reductions need to count toward achieving our goal
which makes Minnesota's CO2 emissions for that year under the CPP. The EPA plan disregards substantial
abnormally low. If we assume that half of the reduction reductions in CO2 that are being achieved in Minnesota
from 2011 to 2012 is due to the Sherco 3 outage and and other early adopter states. Minnesota would be
half due to the impact of Minnesota energy policy, the forced to achieve a 41 percent reduction in CO2 emissions
reduction is still 21 percent. The Great Recession had by 2030 after reducing emissions by perhaps 30 percent
an impact on electricity sales, but total retail sales in the years leading up to 2020.
have returned to pre-recession levels, so any recession
impact on CO2 reduction in the 2012 data is minimal. Minnesota's electric utilities are making substantial
To be conservative,we can state with confidence that investments to achieve today's greenhouse gas emissions
Minnesota achieved a genuine greenhouse gas reduction reductions.And the reductions achieved from 2005 to
of 15 percent to 20 percent from 2005 to 2012. 2020 will make further mandated reductions that much
more difficult and expensive to achieve. Our consumers
2013—2020 will have to bear the huge cost of reducing CO2 emissions
Minnesota will continue its aggressive greenhouse by as much as 70 percent by 2030. EPA must recognize
gas reduction policy during the eight-year period from the pre-2020 emission reductions achieved by Minnesota
2013 through 2020. In 2020 Xcel will be at 30 percent and other early adopter states in the final rule.
renewable and all other power suppliers will be at 20
percent renewable(on the way to 25 percent in 2025), Choice of baseline period
for a statewide renewable portfolio of 24.6 percent. Sherco 3,Minnesota's newest and most efficient coal
Minnesota's aggressive energy efficiency requirements plant(jointly owned by Xcel Energy and Southern
and energy efficiency performance standards for Minnesota Municipal Power Agency(SMMPA)) was
buildings will provide increasing levels of greenhouse off-line during all of 2012, the year used by EPA as the
gas reductions with each passing year. Minnesota energy baseline in the CPP.As a result, Minnesota's mandated
policy will provide additional greenhouse gas reductions CO2 reduction in the plan is substantially larger than it
from 2013 through 2020 of 10 percent to 15 percent. would be if EPA had used typical Minnesota annual coal
generation in the plan. EPA needs to allow Minnesota to
2015 Federal Position Statements/5
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select a baseline period that provides an accurate picture MMUA Position
of our coal generation in a typical year. As proposed, EPA's Clean Power Plan presents very
serious problems for Minnesota. In the final rule EPA
Cross-state ownership of renewables must recognize and take into account the very real
The CPP treats all renewables located in a state as greenhouse gas emission reductions that Minnesota
essentially"belonging"to that state. But ownership of and other early adopter states have achieved and will
renewable energy projects isn't that simple.Minnesota continue to achieve prior to 2020. Minnesota must be
power suppliers have developed or contracted with allowed to select a base period that provides an accurate
renewable projects in other states in order to meet picture of our coal generation in a typical year. EPA
the requirements of our renewable energy standard. must exercise great care in determining how renewable
Conversely, utilities from other states have developed energy projects are to be allocated among states that
renewable projects in Minnesota. EPA will have to have legitimate reasons to claim the output under the
clarify how renewable energy projects are to be allocated CPP.
among states that have legitimate reasons to claim the
output under the CPP.Any decision the EPA makes will We urge the members of Minnesota's Congressional
produce winners and losers, and will have a significant delegation to tell EPA that Minnesota needs relief in
impact on Minnesota's ultimate obligations under the the final rule from these troublesome and ill-designed
CPP. aspects of the proposed CPP.
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Recognizing the greater wind resource to the west,Minnesota utilities have built significant wind resources there.However,
the Clean Power Plan credits those resources to North and South Dakota,not Minnesota.
2015 Federal Position Statements/6
hiffiffA r ir 0
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Preserve and Protect Tax-Exempt Financing
Tax-exempt municipal bonds are critical financing tools 4'
___:2i
for all public power utilities, which are entities of state ��"
and local governments. These bonds help build utility �`
and community infrastructure;indeed, nearly three- "te
quarters of the infrastructure built in the U.S., including -t t
roads,bridges, schools,hospitals,water and wastewater .a;. = / � �,,, /,:�'
treatment plants, and publicly-owned electric utility r q' �"`k
facilities are financed with muni bonds. These bonds are - .- &l
desirable to investors because the earned interest is not ff7/ !''. X4 -----' r' r` ,n
subject to federal income tax. (cs �, _ ,..,,
The federal tax exemption on municipal bond interest '� '� r'
has been in place since enactment of the very first . •. . i r" ►
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federal tax code in 1913. It has allowed state and local ['.rs 1 q..-r. ' �.• +�AIII
governments to save,on average, an estimated two ' r. 1,,.......... _ .,. j
percentage points on their borrowing,which translates ,tip ' ' - :,.;
into a 25 percent savings in public infrastructure costs ' - r ""
over time. Over the past few decades,tax-exempt ' ' i
financing has generated trillions of dollars of investment !
in vital public infrastructure, saving state and local Ai -- , 00. ,
/ II governments hundreds of billions of dollars in interest , ` 1 , ii / _ . Ai
costs. ; '� � , ' ,:,
,....
But muni bonds are under assault from all quarters, 1 a„ , jLL� ° 4,ii
including recent White House budget proposals that ' r ��._ F ii
seek to cap the tax value of the exclusion on muni bonds; — { ` .v
this amounts to a surtax on the interest of those bonds =- `— :, -
--
and would increase borrowing costs by 32 to 35 percent. - - - -
Further,this proposal would apply retroactively to$3.7 ;., _ -- =
trillion of existing bonds, imposing a significant financial Nearly three-quarters of the infrastructure built In the U.S. is
burden on public power communities. financed with municipal bonds.
Proposals to tax municipal bonds would impose higher
borrowing costs on cities and other local governments and higher rates for municipal services such as electric,
and discourage investment in critical infrastructure. water, and wastewater service.
Increased borrowing costs would lead to higher taxes
It seems ironic that in this era of ever more costly
environmental regulations, Congress and the White
House are looking to limit the one tool that local
governments have to control costs as they make
- (! the investments necessary to comply with one new
ri 1)--,,, J,_ =- ' ,j 1 I regulation after another.
,,,,* _II' 1
! Y_ ' ...... MMUA Position
1"' -- We urge Congress to preserve the traditional tax
exempt financing tools used by local governments since
the development of the federal tax code more than a
hundred years ago, and to reject all proposals that would
'"` limit or eliminate the tax exempt status for municipal
Tax-exempt bonds were a vital financing vehicle for the U.S. bonds,including replacing muni bonds with tax credits
Highway 10 reconstruction project through Staples,including or"direct payment bonds."
the overpass visible in the background.
2015 Federal Position Statements/7
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11117110,11 Position Statement
Grid Security
Public power utilities, along with the rest
of the electric industry, take seriously
their responsibility to maintain the very __
high degree of electric grid security that r
is absolutely essential to the welfare and
security of the nation. That is why the
industry worked together to reach consensus
on a mandatory reliability plan in the Energy
Policy Act of 2005 (EPAct05). ^
The electric utility industry is the only
critical infrastructure sector, along with
nuclear power plants, that adheres to federal - -
mandatory and enforceable reliability and t
cyber security standards;this is known as
the FERC-NERC process (Federal Energy - I
Regulatory Commission and North American
Electric Reliability Corporation),which -
oversees the standards as prescribed in the The electric utility industry adheres to federal reliability and cyber security
EPAct 05.
standards.We take threats to the electric system very seriously.
We take threats to the electric system
very seriously.We know that we need to MMUA Position
be on constant guard against cyber-attacks.We also We recognize that grid security legislation is coming.
understand how critical it is to protect our physical We support enhanced information sharing between the
assets—our power plants, transmission lines, and federal government and electricity industry. We also
substations. support narrowly crafted and targeted legislation to
address grid security emergencies. We don't support
Electric utilities are working diligently with regulators legislation that would place an unnecessary burden
to develop the necessary standards and make sure that on Minnesota's relatively small public power systems,
they are upgraded to ensure that our defenses are up to duplicates existing systems, and would deliver little in
date. Critical Infrastructure Protection(CIP)Version the way of additional results.
3 cybersecurity standards are currently in effect and
enforceable.Version 5 has been approved by FERC and
will be enforceable on April 1, 2016. FERC has also
approved a new physical security standard to protect
our most critical substations which becomes enforceable
beginning on October 1, 2015. l -
4
The public power community supports NERC's Critical
Infrastructure Protection standards, as well as efforts "f.:4107‘ g,
by the Electricity Sub-sector Coordinating Council to " .
improve cyber standards throughout the industry. We '1'1,4+ 4,°
also encourage our local utilities to adopt the cyber g P Y l Ml �
security framework outlined in the White Houses 1 *
Executive Order in 2013, and support FERC's new "-` <
physical standards that go into effect later this year.
However, we do not support legislation that would place an
unnecesary burden on small public power systems and deliver
little In the way of additional results.
2015 Federal Position Statements/8
Position Statement
Captive Rail Shippers Need Reform
Nearly 40 percent of total US
electricity comes from coal.About
46%of the electricity generated
in Minnesota came from coal-fired Prpt
electric power plants in 2013. That _
coal is typically shipped by rail,
often by a single railroad,with „,.. '
no transportation alternatives,
making the utility coal customer
"captive"to the railroad.
Over the past year electric utility
captive shippers have experienced ¢.
unprecedented delays in delivery •
of coal. Coal stocks at many power
plants have often dwindled to 4
dangerously low levels, potentially
threatening the reliability of the I
electric system.And despite the
poor service, costs remain very = .
high. The rail transport costs
are often far higher than the cost The Willmar Municipal Utilities combined heat and power plant is adjacent to railroad
of the delivered product itself. tracks,and relies on the railroad for fuel deliveries.The utility is among those who have
This also occurs in other key had frustrations with what appears to be a straightforward issue: delivering fuel to
sectors of the economy, including power plants.Pictured is Wes Hompe,now the utility's general manager.
agriculture, chemicals, pa er
,
steel, and many more.
customers to enhance rail competition and improve
Two public power communities, Hibbing and Virginia, customer protection provisions.We also support
are trucking coal from Superior, Wisc., because they removing exemptions from antitrust law long enjoyed by
can't arrange for rail delivery of coal to their power the rail industry.
plants at a reasonable cost.As a result,Virginia pays
$58.77 per ton for delivered coal, and only $13.30, or 23
percent,is for the coal itself.
The Surface Transportation Board has shown an
increasing level of interest in the concerns of shippers in
recent years,but overall it has had little or no effect on
the dominance of the railroad industry.We appreciate
the fact that the STB recently required BNSF to submit "*,,
plans to deal with dwindling coal supplies at utilities.
But the STB lacks both the authority and the will to try
take the steps necessary to force railroads to provide _ --,
adequate service at fair prices.
MMUA Position
Legislation is necessary. Lack of competition in the rail -, ; _ ts,
industry,coupled with the lack of access to regulatory
relief, threatens electric reliability in Minnesota and Agricultural interests are also keenly aware of the need for rail
throughout the coal-dependent Midwest.We support reform.Agriculture is important economically to many MMUA
the STB reform initiatives endorsed by freight rail member communities,including Warren(pictured here).
2015 Federal Position Statements/9
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FAs,, Position Statement
Why Public Power?
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photo courtesy of the Owatonna People's Press
One hundred twenty-five Minnesota cities benefit from • We're owned by our customers.There is no tension
having a locally owned and locally operated municipal between the interests of customers and the interests of
electric utility. Thirty-one cities have a municipal stockholders. Our focus is Main Street, not Wall Street.
natural gas system. Fifty of our eighty-seven county We work for you.
seats are served by a municipal electric or gas system.
A not-for-profit municipal electric or gas utility is a • We're not in it for the money.Municipal utilities
tremendous asset in these uncertain times. Here are are not-for-profit and operated in the public interest.
some of the reasons why: Our goal is long-term community benefit, not short-term
gain. We work hard to save you money.
• We have great service.We're part of the community
and our policy makers, managers and workers are part • We're the yardstick for the industry. For
of the community. Our crews are always on hand in generations, public power systems have set standards
the event of emergency.You don't need to call an 800 for rates and service that other utilities have had to
number to talk to us. meet.
• We're locally regulated.Members of the community • We'll be there.Most Minnesota's municipal electric
who live in the community set rates and service utilities have served their communities for more than
practices. If you have a problem,you know who to talk a hundred years. In an era when new competitors come
to. and go faster than we can learn their names, you can
count on us. We will be there when you need us.
• We're Public Power.
We're here for you!
2015 Federal Position Statements/10
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Alexandria- Mora.
Electric Sauk Centre &
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Princeton Norlh Bianchi Natural Gas
,0rtonville Poison Elk River
Buffalo Anoka Utilities of
Kandiy i crave City • .Circe Pines
Madison Willmar Litchfield Delan Nort
St.Paul Minnesota
Hutchinson
Granite Fa s
Glencoe Chaska,Shakopee
Olivia' Brownian
Vlrinihrop ArI ton
Marshall. Redwood Falls Le Sueur•New Prague Lake City
Mairiax Goodhue
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Westbrook Springfield Lake Crystal Janesvige Owatonna a
Mountain Lake •Madera Yrasera Rochester
Qundet+ 'Saint James Kassnn •Saint Charles
*Windom Tnanran •Blooming Prairie Peterson Rushtord
Brewster, Lakefield 4USpring Valley ••" alan
Luveme, Adrian Worthington .Alpha .Fairmont •Blue Earth J+usrn Preston Lanesbora Caledonia
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IIIElectric ■ Electric and natural gas II Natural gas only
Note:Many of these utilities also provide water service, and may provide other services as well.
2015 Federal Position Statements/11
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Minnesota Municipal Utilities Association
3025 Harbor Lane N., Suite 400, Plymouth, MN 55447
www.mmua.org