0136 1 BEFORE THE WASHINGTON UTILITIES AND TRANSPORTATION 2 COMMISSION 3 WASHINGTON UTILITIES AND ) TRANSPORTATION COMMISSION ) 4 ) Complainant, ) 5 ) vs. ) DOCKET NO. PG-041624 6 ) Volume VIII PUGET SOUND ENERGY, INC., ) Pages 136 - 159 7 ) Respondent. ) 8 --------------------------------- 9 10 A settlement conference in the above matter 11 was held on June 5, 2007, at 9:30 a.m., at 1300 South 12 Evergreen Park Drive Southwest, Olympia, Washington, 13 before Administrative Law Judge ANN RENDAHL. 14 15 The parties were present as follows: 16 WASHINGTON UTILITIES AND TRANSPORTATION COMMISSION, by DONALD T. TROTTER, Assistant Attorney 17 General, 1400 South Evergreen Park Drive Southwest, Post Office Box 40128, Olympia, Washington 98504; 18 telephone, (360) 664-1189. 19 PUGET SOUND ENERGY, INC., by STEVEN R. SECRIST, Deputy General Counsel, 10885 Northeast Fourth 20 Street, Bellevue, Washington 98004; telephone, (425) 462-3178. 21 CITY OF BELLEVUE, by CHERYL A. ZAKRZEWSKI, 22 City Attorney, City Attorney's Office, Post Office Box 90012, Bellevue, Washington 98009; telephone, (425) 23 452-6829. 24 Kathryn T. Wilson, CCR 25 Court Reporter 0137 1 _____________________________________________________ 2 INDEX OF EXHIBITS 3 _____________________________________________________ 4 EXHIBIT: MARKED/OFFERED/ADMITTED 5 3 141 6 4 141 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 0138 1 P R O C E E D I N G S 2 JUDGE RENDAHL: Good morning. We are here 3 before the Washington Utilities and Transportation 4 Commission this morning, Tuesday, June 5th, 2007, at 5 the Commission's offices in the newly-named Richard 6 Hemstad building for a hearing on the second settlement 7 agreement in Docket PG-041624, which is a complaint by 8 the Commission against Puget Sound Energy, or PSE. The 9 time now is 9:31. We are pretty timely. I'm Ann 10 Rendahl, the administrative law judge presiding over 11 this hearing this morning. 12 This hearing was called following notice to 13 the parties issued on May 9th and pursuant to the 14 Commission's procedural rules governing consideration 15 of proposed settlements in WAC 480-07-740. This case 16 was initiated by the Commission to investigate a 17 natural gas explosion that occurred in the Spirit Ridge 18 neighborhood of the City of Bellevue on September 2nd, 19 2004. As a result of the explosion at the residence of 20 Mrs. Francis Shmitz, S-h-m-i-t-x, Mrs. Shmitz 21 subsequently died. 22 On October 7th, 2005, the Commission approved 23 the parties' revised settlement agreement that required 24 PSE to pay a penalty of $90,000, conduct an assessment 25 of its system to determine whether further cathodic, 0139 1 c-a-t-h-o-d-i-c, protection or system improvements were 2 necessary, and to change its operating manual and field 3 practices for detection of cathodic protection failure. 4 On May 4th of this year, the Company, 5 Commission staff, and the City of Bellevue filed the 6 second settlement agreement with the Commission to 7 resolve issues arising from Paragraph 14 and 15 of the 8 revised settlement agreement, which specifically 9 addressed efforts by PSE to gather data on certain 10 services in its pipeline system and to work with Staff 11 to evaluate the data. 12 So we are here this morning to consider that 13 second settlement agreement, and we will have a panel 14 of two witnesses, one from PSE, Duane Henderson, and 15 one from the staff, Alan Rathbun. I have a few 16 questions about issues raised in the settlement 17 agreement that I want to present to the Commission. 18 With that, let's have appearances from the parties, 19 first beginning with Staff 20 (Pause in the proceedings.) 21 MR. TROTTER: For the Commission staff, my 22 name is Donald T. Trotter, assistant attorney general. 23 JUDGE RENDAHL: For PSE? 24 MR. SECRIST: This is Steve Secrist, deputy 25 general counsel for Puget Sound Energy. The address is 0140 1 10885 Northeast Fourth Street in Bellevue, Washington, 2 appearing for Puget Sound Energy. 3 JUDGE RENDAHL: Your e-mail address? 4 MR. SECRIST: steve.secrist@pse.com. 5 JUDGE RENDAHL: Your telephone number? 6 MR. SECRIST: (425) 462-3178. 7 JUDGE RENDAHL: Your fax number? 8 MR. SECRIST: 456-2707. 9 JUDGE RENDAHL: And that's 425 area code as 10 well? 11 MR. SECRIST: Yes. 12 JUDGE RENDAHL: From the City of Bellevue? 13 MS. ZAKRZEWSKI: I'm Sheryl Zakrzewski, 14 assistant city attorney. 15 JUDGE RENDAHL: Is there anyone appearing on 16 the bridge line that wishes to state an appearance this 17 morning? Hearing nothing, let's go forward. 18 While were off the record, we talked about 19 exhibits that might need to be added to the exhibit 20 list in this case, and the parties have agreed that the 21 second settlement agreement, which was filed with the 22 Commission on May 4th, and the narrative supporting the 23 second settlement agreement are the only two exhibits 24 that we need to address here on the record this 25 morning. 0141 1 I'll note that the Company filed something 2 titled "The Puget Sound Energy Wrapped Steel Service 3 Assessment Program Report," filed with the Commission 4 on March 16th, and the settlement agreement and the 5 narrative might refer to that report, but that report 6 is not going to be marked as an exhibit in this 7 proceeding, but it is available on the Commission's Web 8 site and in the records center for consideration if 9 anyone wishes to see it. So the second settlement 10 agreement would be marked as Exhibit 3 and the 11 narrative would be marked as Exhibit 4. Is that 12 acceptable? 13 MR. TROTTER: Yes. 14 MS. ZAKRZEWSKI: Yes. 15 MR. SECRIST: Yes. 16 JUDGE RENDAHL: Are there any objections to 17 admitting those exhibits into the record? 18 MR. TROTTER: No. 19 MS. ZAKRZEWSKI: No. 20 MR. SECRIST: No. 21 JUDGE RENDAHL: Hearing no objection, the 22 second settlement agreement will be admitted as 23 Exhibit 3 and the narrative supporting the second 24 settlement agreement will be admitted as Exhibit 4. 25 We also discussed off the record that 0142 1 although the City does not have a witness to answer 2 questions this morning, if the City wishes to address 3 any of my questions or make a statement, Ms. Zakrzewski 4 can do so herself. So with that, is there anything 5 further we need to address before hearing from the 6 witnesses? Mr. Rathbun and Mr. Henderson, would you 7 please state your full name and your address for the 8 record starting with you, Mr. Rathbun? 9 MR. RATHBUN: My name is Alan Rathbun. I'm 10 pipeline safety director for the Washington Utilities 11 and Transportation Commission. My address is 1300 12 South Evergreen Park Drive Southwest, Olympia, 13 Washington, and my telephone number is (360) 664-1254. 14 JUDGE RENDAHL: Thank you, and Mr. Henderson? 15 MR. HENDERSON: I'm Duane Henderson, director 16 of engineering and operations services at Puget Sound 17 Energy. Address is 10885 Northeast Fourth Street in 18 Bellevue, 98004. Phone number is (425) 462-3974. 19 JUDGE RENDAHL: Would the two of you raise 20 your right hand please? 21 22 Whereupon, 23 THE WITNESSES, 24 having been first duly sworn, were called as witnesses 25 herein and examined and testified as follows: 0143 1 JUDGE RENDAHL: So with that, do either of 2 you wish to make a statement of any kind about the 3 second settlement agreement? 4 MR. RATHBUN: Staff has a few opening remarks 5 if you would like. 6 JUDGE RENDAHL: I will entertain them. You 7 might want to slow down for the court reporter. 8 MR. RATHBUN: Again, good morning, Judge 9 Rendahl. Your original comments basically touched very 10 concisely on the reason we are here today and made any 11 necessary comments I have even shorter, so thank you. 12 Pipeline safety staff joins with Puget Sound 13 Energy and the City of Bellevue in support of the 14 second settlement agreement before you today. Over the 15 past two years, we've worked in collaboration with 16 Puget Sound Energy in preparation and review of the 17 Company's wrapped steel service assessment plan, 18 something that we may refer to as WSSAP, and that's the 19 basis of this agreement. 20 We feel this agreement is in the public 21 interest, and Staff recommends the Commission approve 22 it. The judge has presented the background and why we 23 are here today so I won't repeat that. Puget Sound 24 Energy performed an assessment of approximately 100,000 25 services using this WSSAP model. The model classified 0144 1 those services into four categories reflecting the 2 various degrees of risk of failure due to corrosion. 3 They have agreed to take responsive action based on the 4 degree of failure risk in replacing service lines in 5 the highest risk category to increase leak surveys to 6 no additional action, and the table on Page 3 of the 7 settlement agreement shows the classification of these 8 services as it's reported. 9 We wanted to make sure the judge understands 10 that service lines can migrate between classifications 11 as PSE gathers further information and as these lines 12 age. Staff has a relatively high confidence level in 13 PSE's classification of services in the priority 14 placement and scheduled replacement categories. 15 However, due to the lack of available data, 16 we do not have as much confidence in the ability of 17 WSSAP to differentiate the risks in the lower 18 categories labeled as increased leak survey and 19 standard mitigation categories. To address that, PSE 20 has agreed to conduct 1,000 electrical surveys and 21 associated assessments in these two categories. 22 Another important element of this agreement 23 is that PSE will regularly update the model as new 24 information about the condition of these services 25 becomes available. The goal of this enhanced data, 0145 1 including the thousand random surveys, is to improve 2 the model's reliability in placing services into the 3 two categories of something needed to be done and 4 something not needed to be done, something additional 5 to normal regulations. 6 Therefore, we believe this as a package 7 complies with Paragraph 14 and 15 of the settlement 8 agreement, and we stand ready to answer any questions 9 the judge may have. Thank you. 10 JUDGE RENDAHL: Okay. Mr. Henderson, do you 11 have any statement you wish to make? 12 MR. HENDERSON: I have nothing further to 13 add. 14 JUDGE RENDAHL: Very well. I have a few 15 questions, and some of them are just clarifying the 16 record and some of them are questions about the impact 17 and import of the work. 18 The report refers to "wrapped steel service" 19 and other references in the record refer to "bare steel 20 pipe" or "covered pipe." Is wrapped steel the same as 21 covered, or how would you describe wrapped steel? 22 MR. HENDERSON: I guess I need to understand 23 where the reference to "covered." It might be "coated 24 pipe." 25 JUDGE RENDAHL: Yes, excuse me. 0146 1 MR. HENDERSON: Wrapped pipe and coated pipe 2 are the same. 3 JUDGE RENDAHL: Also to clarify the record, 4 when you refer to a "service line," is that the line 5 between the main and a residence or a building? 6 MR. HENDERSON: That's correct. 7 JUDGE RENDAHL: In the settlement agreement 8 in Paragraph 21, which on my version is Page 6, on the 9 third line down, there is a reference to -- it says, 10 "If any annual status report provided pursuant to 11 Paragraph 23 of this agreement...," etcetera, and I'm 12 wondering whether that should say Paragraph 24 instead 13 of 23. In my reading, Paragraph 23 doesn't refer to 14 the report. 15 MR. RATHBUN: I would agree, Judge. 16 JUDGE RENDAHL: So we should correct that 17 reference to say Paragraph 24. 18 MR. TROTTER: Could PSE and the City confirm 19 that they agree with that? 20 MR. SECRIST: PSE concurs. 21 JUDGE RENDAHL: Ms. Zakrzewski? There are 22 two reports that are referenced. The first one refers 23 to identifying the number of leaks, and that's in 24 Paragraph 24, and in Paragraph 25, PSE should identify 25 the number of services replaced, and in Paragraph 21, 0147 1 it seems to refer to a report about the number of 2 leaks, so I'm wondering if that Paragraph 23 reference 3 needs to be changed to 24. 4 MS. ZAKRZEWSKI: I believe that is correct. 5 JUDGE RENDAHL: Thank you for that 6 clarification, and then also on Page 10 in Paragraph 34 7 in terms of procedure, the second sentence before the 8 end it refers to requesting a suspension of the 9 procedural schedule, and I'm not sure that there was 10 one, and this may have been a carryover from the former 11 settlement agreement. 12 MR. TROTTER: It was, Your Honor. 13 JUDGE RENDAHL: So we will not worry about 14 that sentence. Those are just the clarifying questions 15 I have about the settlement agreement. You might want 16 to file a revised settlement agreement at least 17 correcting Paragraph 21. 18 MR. TROTTER: Your Honor, we would be happy 19 to work with the other parties to file a second 20 settlement agreement with those edits. 21 JUDGE RENDAHL: Thank you. Just for the 22 record, is Exhibit A to the settlement agreement, are 23 those pages in Exhibit A that have the charts and 24 lists, are those included in the WSSAP report, or are 25 these sort of a summary of the WSSAP report or further 0148 1 actions to be taken? 2 MR. HENDERSON: This is included in the 3 report. 4 JUDGE RENDAHL: So these are excerpts from 5 the report and they are included as a part of the 6 settlement agreement, okay. Mr. Rathbun, you did talk 7 about the concerns about the lack of available, 8 reliable data to differentiate between the two sort of 9 lower risk categories, but you are satisfied that other 10 commitments that PSE is making will overcome that lack 11 of information? 12 MR. RATHBUN: Yes. Staff is satisfied with 13 the efforts being taken noting that this sort of model 14 is somewhat unique and something that we would probably 15 call "integrity management," and it will mature over 16 time as data is added. Like I said in my opening 17 remarks, Staff was comfortable in that the data that is 18 available is able to differentiate and show by leak 19 history and other events certain services which may 20 have been of higher risk. 21 As you went down in the model, they tended to 22 look more alike, and as such, this additional data, 23 this random sampling, these electrical surveys and 24 other assessment tools, as well as just as time goes on 25 PSE adding more, as they are doing more maintenance 0149 1 work, adding more to the record will enhance the 2 viability and credibility of the model just as a 3 reliable tool. 4 JUDGE RENDAHL: My understanding from 5 reviewing the settlement agreement and also the 6 transcript from the original settlement hearing that 7 this type of risk assessment analysis, it's not being 8 done by any other company. This is sort of new ground 9 that PSE is undergoing to make sure that the services 10 are not at risk. 11 MR. RATHBUN: PSE can speak to their 12 knowledge. As far as we are aware, this sort of model, 13 this sort of assessment is not done that we are aware 14 of across the country. There are replacement plans 15 that certain companies may have, but I think the 16 sophistication of and the type of review that is used 17 in this model is not done elsewhere, at least that I'm 18 aware. PSE may have different information. 19 JUDGE RENDAHL: Mr. Henderson, do you have 20 anything to add? 21 MR. HENDERSON: As Alan says, this is a new 22 area of expertise for the industry, and I would say 23 that in the last year and a half since our last hearing 24 that there are companies beginning to delve into this 25 area and develop similar type models, but as Alan says, 0150 1 I think we are ahead of the curve in the sense that 2 we've got a head start, and the timing of it, I think 3 the model that we've used, the consultant that's been 4 involved with this has established a benchmark for 5 other companies to follow. There are not, to our 6 knowledge, any other companies that are as far along in 7 the process as we are. 8 JUDGE RENDAHL: Okay. In terms of conducting 9 the random survey of a thousand additional services to 10 look at, so it's random. I was going to ask how they 11 are identified, but you said it's random. How would 12 you determine the randomness? 13 MR. RATHBUN: I will defer to PSE to give a 14 little bit more of the background. PSE has already 15 submitted a kind of preliminary set of their first look 16 at these services, and I know their desire is to look 17 at it over a broad geographical range, and I'm trying 18 to remember the other criteria you had, and I think 19 Mr. Henderson can deal with it, but it is a sense of 20 dealing from a standpoint of a geographical range. 21 And also you made reference to cathodic 22 protection in your comments, and the concept is to look 23 not only geographically but to make sure that you get a 24 representative sampling of these cathodic protection 25 regions or the ones that are protected by -- There are 0151 1 independent rectifiers that help protect these systems 2 and make sure that you are getting not too much 3 representation from any one given rectifier area, get 4 as broad and distributed effort as you can. 5 JUDGE RENDAHL: Mr. Henderson? 6 MR. HENDERSON: Alan characterizes it very 7 well. There is a number of variables that go into the 8 risk model, and what we are trying to do is get a good 9 sample of the variety of variables that went in, so 10 cathodic protection. The geographic areas will help to 11 assess kind of the impacts of what I would consider 12 environmental conditions on the pipeline, such as soil 13 condition, hard surface, soft surface kind of 14 insulation. 15 So to really characterize it, it's a sampling 16 of that population of services, not necessarily a pick 17 random numbers out of a hat approach. It's really a 18 focus trying to get a good representation of all the 19 variables that went into the model. 20 MR. RATHBUN: Judge, if I could add one 21 thing, Staff did have a consultant during our 22 assessment also, and I think we were satisfied with the 23 number as being a statistically valid number of 24 samples, which is one of the things we were concerned 25 with. I don't know of another word to use. It's 0152 1 really a broadly represented sample, and it might not 2 be the right word, but I think we were convinced that 3 the number of samples was enough to give us a 4 statistically valid number to represent the number of 5 services being looked at. 6 JUDGE RENDAHL: Mr. Henderson, how does PSE 7 plan to communicate to the public now if the Commission 8 were to approve the settlement agreement and this plan 9 goes forward? How does PSE plan to communicate to the 10 public its plan for replacing the pipes in the priority 11 replacement category or for mitigation plans under the 12 categories? Do you have a plan in place? Do you have 13 a public service announcement planned? 14 MR. HENDERSON: Not so much focused around a 15 broad communication, but as with any of our replacement 16 programs, as we go into certain areas, we get ahead of 17 the actual construction practices and start 18 communicating individually with customers, usually via 19 door hangers or face-to-face meetings with the 20 customers as we schedule -- many of these replacements 21 will require an outage for the customer. We need to 22 make sure that we are mindful of the customer's 23 schedule, so it's really down to that individual basis 24 before we start talking to them. 25 Just for people's knowledge, the priority 0153 1 replacements have already begun. They were scheduled, 2 budgeted for in 2007, and at the beginning of the 3 calendar year, we started the planning and construction 4 of many of those replacements, and we are a good 5 portion through that priority replacement category. 6 JUDGE RENDAHL: Do you expect to be able to 7 meet the December deadline for finishing the priority 8 replacements? I understand the priority replacements 9 are intended to be completed by the end of December 10 2007. 11 MR. HENDERSON: That's correct, and as of 12 now, we don't anticipate any delays. 13 JUDGE RENDAHL: Mr. Rathbun, if the Company 14 can demonstrate some justifiable reason why they can't 15 complete by the end of 2007, how do you expect the 16 Company to bring that to the Commission's attention? 17 MR. RATHBUN: I think that we did have an 18 element in the agreement that, as we do with any 19 commitment that the Company makes to us under 20 regulation, we expect that communication to certainly 21 be as soon as they are aware that some delay is going 22 to cause them delay that they communicate with us with 23 some data that explains what the problem is, and if it 24 can't be done by then, when it is planned to be 25 accomplished. I think that's what we will expect from 0154 1 the Company. So I don't think that this will be any 2 different than any other circumstance under our 3 regulations in which a company finds circumstances 4 beyond their control that keep them from keeping a 5 commitment. 6 JUDGE RENDAHL: There is the December 31, 7 2007 deadline, and then for the next category of 8 mitigation scheduled replacements, I understand the 9 deadline for those is intended to be December of 2010; 10 is that correct? 11 MR. SECRIST: Yes. 12 JUDGE RENDAHL: Beyond that date, is the 13 intention of the parties that the Company will continue 14 to update and monitor the lower mitigation categories 15 and if there is any that rise above -- does the this 16 agreement extend beyond 2010? 17 MR. RATHBUN: I think that from Staff's 18 perspective, yes, and as Mr. Henderson related before, 19 there is current regulation pending at the federal 20 level, management for distribution systems, and we view 21 that this is, in fact, an element of this interior 22 management program, which requires operators to 23 understand their systems, identify risks, and mitigate 24 those risks before they constitute a risk of failure, 25 and we just few this as a tool that the Company will 0155 1 use, and like I said, I think Puget Sound Energy has 2 gotten a little bit of a head start because the 3 regulation hasn't even been released yet, but we view 4 that this is an ongoing program and not something that 5 will end. 6 JUDGE RENDAHL: Mr. Henderson? 7 MR. HENDERSON: I agree wholeheartedly with 8 what Alan has indicated. I think what we believe is 9 the attractiveness of this is that it is a continual 10 process. It's going to be updated not only with the 11 data inputs that we've collected over previous years, 12 but it will also allow us to further fine tune the 13 model as we become more familiar with its capabilities 14 and how it relates with what we are finding out in the 15 field, so it really is a new way of doing business. 16 JUDGE RENDAHL: Mr. Secrist? 17 MR. SECRIST: I think I would characterize 18 this as a bridging tool. As Mr. Rathbun was 19 characterizing, we expect regulations will be 20 forthcoming, and certainly, the regulations will govern 21 the way we are practicing in the future. We don't 22 expect any inconsistencies, but just procedurally, we 23 view the regulations as what we will be following in 24 the future. We expect that this will tie into them 25 nicely. We expect that this will bridge into that 0156 1 world, and then the regulatory model will be what PSE 2 follows in the future. 3 JUDGE RENDAHL: Mr. Trotter? 4 MR. TROTTER: I think I agree with 5 Mr. Secrist, and I think at some point if and when 6 regulations supplant this agreement, then we may just 7 file something with the Commission or ask for some 8 indication for a person to acknowledge that, because 9 there is always the problem of several years down the 10 line an agreement popping up and no one knows what 11 happened to it, so we would try to bring this agreement 12 to a close if and when integrity management programs 13 that are codified in the rule become obsolete. 14 JUDGE RENDAHL: That ties into my next and 15 maybe last question, which is about the reports to the 16 Commission and the City of Bellevue, which there is 17 really no end date to the reports, so my question which 18 ties into what you just said, Mr. Trotter, at some 19 point would the parties be coming to the Commission to 20 say because of this new regulation that we don't need 21 to provide these reports any longer or this settlement 22 agreement has served the immediate purpose and the 23 reports will be available in some other format, so I 24 don't know who wishes to answer that first. 25 MR. TROTTER: I think the idea was in the 0157 1 early years of this, the reports are going to be very 2 important. I think over time, they may diminish in 3 importance, and at that point, the parties would just 4 come back and ask the Commission to terminate the 5 agreement or agree that the agreement had been 6 completed, but it is an ongoing process, and it may be 7 a few years before that happens, or the advent of new 8 regulations affecting the agreement, or just that 9 enough work is done that the reports have diminished 10 usage. We would come to the Commission to address that 11 issue. 12 JUDGE RENDAHL: Ms. Zakrzewski? 13 MS. ZAKRZEWSKI: That's what we had 14 anticipated as well. 15 JUDGE RENDAHL: Mr. Secrist. 16 MR. SECRIST: PSE agrees. 17 JUDGE RENDAHL: Any comments from the 18 witnesses on this issue? 19 MR. RATHBUN: Nothing further, Judge. 20 MR. HENDERSON: None from me. 21 JUDGE RENDAHL: With that, I think you have 22 answered my questions about the settlement and how it 23 will work and the import of it, and I appreciate the 24 time you all have devoted to what looks to be a really 25 groundbreaking method of integrity management and 0158 1 applaud all of you for working together on making this 2 happen. 3 The process now is I will be entering an 4 initial order on the settlement agreement, and you all 5 then will have the opportunity to, if you choose to, 6 seek a review of the Commission if you disagree with 7 any portion of my decision. If you don't and you wish 8 it to be expedited for finality or for final Commission 9 order, then you can let the Commission know after my 10 initial order has been entered. 11 I understand that priority replacement is 12 already occurring, so in that sense, there is no need 13 for an order for this to go forward, but is there any 14 timing needs you all have for this matter? 15 Mr. Rathbun? 16 MR. RATHBUN: Judge, I think the Staff is 17 satisfied that things are progressing, so we don't have 18 any timing issues at this time. 19 JUDGE RENDAHL: For PSE? 20 MR. HENDERSON: None for PSE, no. 21 JUDGE RENDAHL: None for the City? 22 MS. ZAKRZEWSKI: No. 23 JUDGE RENDAHL: Just a few last items, does 24 anyone wish to order a transcript of this morning's 25 proceeding? If you wish to do so, then contact the 0159 1 court reporter after the hearing. With that, is there 2 anything else we need to discuss? Mr. Trotter? 3 MR. TROTTER: There were two edits that 4 needed to be made, the Paragraph 24 reference and then 5 deleting a sentence on the procedural schedule. I 6 think we can handle that very efficiently, but should 7 we call the agreement something else? I think the 8 parties should be able to agree the signature pages 9 could stay the same. 10 JUDGE RENDAHL: That's fine, and if you just 11 simply want to file under a cover letter that states 12 pursuant to discussion at the hearing, this is the 13 substitute version and the signature pages remain the 14 same, that's fine with me. 15 MR. TROTTER: We will get that done. 16 JUDGE RENDAHL: With that, is there anything 17 further? Hearing nothing, this hearing is adjourned. 18 Thank you very much. 19 (Settlement conference adjourned at 10:05 a.m.) 20 21 22 23 24 25