BILL ANALYSIS                                                                                                                                                                                                    Ó



                                                                    SB 1233


                                                                    Page  1





          Date of Hearing:  June 29, 2016


                       ASSEMBLY COMMITTEE ON LOCAL GOVERNMENT


                           Susan Talamantes Eggman, Chair


          SB  
          1233 (McGuire) - As Amended June 20, 2016


          SENATE VOTE:  35-2


          SUBJECT:  Joint powers authorities:  Water Bill Savings Act.


          SUMMARY:  Establishes the Water Bill Savings Act, which  
          authorizes joint powers authorities (JPAs) to finance water  
          conservation improvements on private property for a customer of  
          a local agency or its publicly owned utility, to repay by  
          charges collected on a water bill.  Specifically, this bill:   


          1)Establishes the Water Bill Savings Act, which, notwithstanding  
            any other law, authorizes a JPA that meets specified  
            requirements to provide funding for a customer of a local  
            agency or its publicly owned utility to acquire, install, or  
            repair a water efficiency improvement on a customer's property  
            (residential, commercial, industrial, agricultural, or other  
            real property owned, leased or licensed for occupancy by the  
            customer) served by the local agency or its publicly owned  
            utility.  



          2)Requires a JPA to adopt a resolution to establish or extend a  








                                                                    SB 1233


                                                                    Page  2





            program to provide funding for a customer for a water  
            efficiency improvement.  Requires the resolution to do all of  
            the following:  



             a)   State the JPA's intent to operate the program;



             b)   Define the geographical scope of the operation of the  
               program as an area that is limited to only the territories  
               within which retail water service is provided by those  
               local agencies that have requested the JPA to provide  
               funding for the local agency's customers through the  
               program;  



             c)   Approve a standardized servicing agreement; and,



             d)   Authorize one or more designated officials of the JPA to  
               execute and deliver the servicing agreement on behalf of  
               the JPA.  



          3)Allows a JPA to make a final and conclusive determination that  
            its proceedings to establish or extend a program were valid  
            and in conformity with specified requirements enacted by the  
            bill.



          4)Authorizes the legislative body of a local agency to provide  
            funding for its customers through a program established by a  
            JPA by doing all of the following:








                                                                    SB 1233


                                                                    Page  3








             a)   Adopt a resolution of intention, as specified; 



             b)   Conduct a noticed public hearing, as specified; and,



             c)   Adopt a resolution to authorize the program that does  
               all of the following:



               i)     Authorize the JPA to establish or extend a program  
                 within the boundaries of the local agency;



               ii)    Declare that the operation of the program by the JPA  
                 in the local agency's geographic boundaries would provide  
                 significant public benefits in accordance with specified  
                 statutory criteria; 



               iii)   Approve the standardized servicing agreement and  
                 authorize one or more designated officials of the local  
                 agency to execute and deliver the servicing agreement  
                 with the JPA;



               iv)    Approve, if applicable, the pledge of water  
                 enterprise revenue as security for the payment of the  
                 principal of, and interest and redemption premium on,  
                 bonds issued by the JPA in the event that efficiency  








                                                                    SB 1233


                                                                    Page  4





                 charges are insufficient;



               v)     Authorize, if applicable, execution and delivery of  
                 one or more pledge agreements to evidence a pledge; and,



               vi)    Allow a local legislative body, in the resolution,  
                 to make a final and conclusive determination that its  
                 proceedings to establish or extend a program were valid  
                 and in conformity with specified requirements enacted by  
                 this bill.  



          5)Requires a customer to repay the JPA for the costs of water  
            efficiency improvements through an efficiency charge on the  
            customer's water bill that is established and collected by the  
            local agency or its publicly owned utility upon verification  
            that the efficiency improvement was installed.



          6)Specifies that the duty to pay the efficiency charge must  
            arise from and be evidenced by a written agreement executed at  
            the time of the efficiency improvement's installation among  
            the customer; the property owner of record, if different than  
            the customer; the JPA; and, the local agency or its publicly  
            owned utility.  



          7)Requires the written agreement to include all of the  
            following:











                                                                    SB 1233


                                                                    Page  5





             a)   An agreement by the customer to pay an efficiency charge  
               for the period and in the amount specified in the  
               agreement, unless the efficiency charge is prepaid in the  
               manner set forth in the agreement.  Prohibits the period  
               designated for repayment from exceeding the estimated  
               useful life of the funded efficiency improvements;



             b)   A description of the financial calculation, formula, or  
               other method that the authority used to determine the  
               efficiency charge.  Allows the efficiency charge to include  
               a component for reasonable administrative expenses incurred  
               by the local agency or its publicly owned utility and the  
               authority in connection with the program and the funding;  



             c)   A description of the efficiency improvement funded with  
               the efficiency charge.  Requires a determination in the  
               agreement that an improvement is an efficiency improvement  
               to be final and conclusive;  
             d)   A representation by the customer that the customer  
               intends to acquire, install, or repair and use the  
               efficiency improvement on the customer's property for the  
               useful life of the efficiency improvement.  Prohibits any  
               failure of the efficiency improvement by damage, removal,  
               or other fault of the customer during the useful life of  
               the efficiency improvement from affecting the customer's  
               obligation to pay the efficiency charge, 


             as set forth in the agreement; and,



             e)   A requirement that any failure of the efficiency  
               improvement not involving damage, removal, or other fault  
               of the customer must result in the efficiency charge being  








                                                                    SB 1233


                                                                    Page  6





               suspended until the efficiency improvement is repaired and  
               returned to service.  Requires the JPA's decision on the  
               reasons for failure of the efficiency improvement and its  
               repair and return to service to be final and conclusive.  



          8)Provides that the timely and complete payment of an efficiency  
            charge by a customer that has agreed to pay an efficiency  
            charge may be a condition of receiving water service from the  
            local agency or its publicly owned utility.  



          9)Authorizes a local agency and its publicly owned utility to  
            use their established collection policies and all rights and  
            remedies provided by law to enforce payment and collection of  
            the efficiency charge.  
             


          10)       Prohibits a person liable for an efficiency charge  
            from withholding payment, in whole or in part, of the  
            efficiency charge for any reason.



          11)       Requires a customer's obligation to pay the efficiency  
            charge to remain until the efficiency charge related to the  
            efficiency improvement has been repaid in full or the  
            efficiency charge has been transferred to a subsequent  
            customer who receives water service at a property with  
            installed efficiency measures for the remainder of the  
            obligation.  Prohibits the efficiency charge from transferring  
            to a subsequent customer and requires the charge to remain an  
            obligation of the previous customer if the efficiency  
            improvements were removed or damaged, and not restored to  
            service, by the previous customer.









                                                                    SB 1233


                                                                    Page  7







          12)       Requires a local agency or its publicly owned utility  
            to record, no later than 10 days after funding an efficiency  
            improvement, a notice of the efficiency charge in the records  
            of the county recorder, pursuant to specified requirements  
            regarding the form and content of the notice.



          13)       Requires the entity responsible for collecting and  
            servicing the efficiency charge to record, within 10 days of  
            full repayment of the outstanding charges, a notice of the  
            full repayment and removal of the efficiency charge in the  
            records of the county recorder, as specified.  



          14)       Requires, within 10 days of the JPA's decision not to  
            repair or return to service a failed efficiency improvement,  
            when the failure did not involve damage, removal, or other  
            fault of the customer, the entity responsible for the  
            collection and servicing of the charge to record a notice of  
            removal of the efficiency charge in the record of the county  
            recorder, as specified.  Requires the notice of the removal of  
            the efficiency charge to include a reference to the recorded  
            notice of the efficiency charge.  



          15)       Requires the JPA and a local agency or its publicly  
            owned utility to enter into a servicing agreement for the  
            collection of one or more efficiency charges and requires the  
            local agency or its publicly owned utility to act as a  
            servicing agent for purposes of collecting the efficiency  
            charge.  











                                                                    SB 1233


                                                                    Page  8





          16)       Requires the JPA, local agency, or utility responsible  
            for the collection of the efficiency charges to ensure that  
            the contact information in the notice of efficiency charge  
            recorded in the records of the county recorder, pursuant to  
            this bill, is accurate so that interested parties may request  
            and promptly receive a written and accurate payoff amount or  
            verification of the outstanding charges associated with the  
            recorded notice of efficiency charge.



          17)       Requires, in the event that the servicing agent or  
            entity responsible for the collection of the efficiency charge  
            changes, a new notice of efficiency charge to be recorded  
            within 10 days.



          18)       Allows any party requesting written payoff or amount  
            verification of outstanding charges from the JPA, local  
            agency, or utility identified as the contact on the recorded  
            notice to rely upon the written payoff amount or verification  
            as being accurate for 45 days from the receipt of this written  
            information.  Authorizes any party, if the JPA, local agency,  
            or utility provides a written amendment to the written payoff  
            amount or verification, to rely on the written amendment for  
            45 days from receipt of the written amendment.



          19)       Requires moneys collected as an efficiency charge to  
            be held in trust, as specified.  
            


          20)       Requires the local agency or its publicly owned  
            utility, in the service agreement, to contract with the JPA  
            that the local agency or its publicly owned utility will  
            continue to operate its utility system to provide service to  








                                                                    SB 1233


                                                                    Page  9





            customers, as specified.  
            


          21)       Requires the servicing agreement to provide that the  
            obligation to pay the efficiency charge shall remain  
            associated with the meter at the customer's property on which  
            the efficiency improvement is located, until the JPA is fully  
            repaid.  



          22)       Authorizes the local agency or its publicly owned  
            utility, in the servicing agreement, to agree that the timely  
            and complete payment of all efficiency charges by a customer  
            that has agreed to pay an efficiency charge shall be a  
            condition of receiving service from the publicly owned  
            utility, and that the local agency or its publicly owned  
            utility shall use their established collection policies, all  
            rights and remedies provided by law, to enforce payment and  
            the collection of the efficiency and charge.  
            


          23)       Requires the local agency or its publicly owned  
            utility, in its servicing agreement, to agree that in the  
            event of default by the local agency or its publicly owned  
            utility, in payment of revenues for the efficiency charge,  
            that the JPA will order the sequestration and payment to the  
            beneficiaries of revenue, as specified.   



          24)       Authorizes a JPA to issue bonds for the purpose of  
            providing funds for the acquisition, installation, and repair  
            of an efficiency improvement on customer property, pursuant to  
            the bill's provisions.  










                                                                    SB 1233


                                                                    Page  10






          25)       Specifies information that a JPA issuing a bond must  
            include in its preliminary notice and final report for the  
            bonds submitted to the California Debt and Investment Advisory  
            Commission (CDIAC).



          26)       Authorizes a JPA to pledge one or more efficiency  
            charges as security for the bonds.  



          27)       Authorizes a local agency to pledge water enterprise  
            revenue as security for the payment of the principal of, and  
            interest and redemption premium on, bonds issued by the JPA if  
            the efficiency charges are insufficient for that purpose.   
            Allows a local agency to execute one or more pledge  
            agreements, pursuant to state law, for the benefit of the JPA  
            or for the exclusive benefit of the persons entitled to the  
            financing costs to be paid from the efficiency charges.



          28)       Requires a local agency that pledges water enterprise  
            revenues to establish a debt service reserve fund for the  
            bond, as required by the purchaser of the bond.  



          29)       Requires a JPA and a local agency or its publicly  
            owned utility to enter into a servicing agreement for the  
            collection of one or more efficiency charges and requires the  
            local agency or its publicly owned utility to act as a  
            servicing agent for purposes of collecting the efficiency  
            charge.  
            










                                                                    SB 1233


                                                                    Page  11





          30)       Imposes requirements on the handling of funds  
            collected by a servicing agent and specifies provisions that  
            must be included in a servicing agreement to help ensure the  
            collection of efficiency charges and repayment of JPA debts.



          31)       Requires a JPA that issues bonds, pursuant to this  
            bill, to establish a debt service reserve fund for the bond to  
            the extent required by the purchaser of the bond.



          32)       Specifies the manner in which its provisions will  
            continue to be enforced if a local agency for which bonds have  
            been issued and remain outstanding ceases to operate a water  
            utility, either directly or through its publicly owned  
            utility.



          33)       Defines numerous terms that are used throughout the  
            bill.



          34)       Exempts a local agency, its publicly owned utility,  
            and the JPA, if they have complied with procedures specified  
            in the bill, from complying with existing statutes that would  
            otherwise prohibit a JPA from authorizing bonds to construct,  
            acquire, or finance a public capital improvement.  


          35)       Makes findings and declarations, including that  
            efficiency charges levied under the bills provisions are not  
            taxes, assessments, fees, or charges for the purposes of  
            Articles XIII                                                  
            C and XIII                                                     
            D of the California Constitution and therefore the provisions  








                                                                    SB 1233


                                                                    Page  12





            of Articles XIII                                               
            C and XIII                                                     
            D and Article 4.6 (commencing with Section 53750) of Chapter 4  
            of Part 1 of Division 2 of Title 5 are not applicable to those  
            efficiency charges.  





          36)States that it is the intent of the Legislature to make water  
            efficiency improvements more affordable and promote the  
            acquisition, installation, and repair of those improvements by  
            allowing local agencies to establish a mechanism by which they  
            may help their water customers acquire install, and repair  
            water efficiency improvements on privately owned customer  
            properties.  
          FISCAL EFFECT:  None


          COMMENTS:  


          1)Marks-Roos.  The Marks-Roos Local Bond Pooling Act of 1985  
            authorizes two or more public agencies to exercise their  
            common powers by signing joint powers agreements.  This  
            agreement can create a JPA which allows local agencies to use  
            JPAs to finance infrastructure.  The Marks-Roos Act authorizes  
            JPAs to issue bonds and loan the capital to local agencies to  
            finance public capital improvements, working capital,  
            liability, insurance needs, or other projects.  Bonds issued  
            under Marks-Roos are secured by a variety of repayment  
            sources.  


          2)Bill Summary.  This bill establishes the Water Bill Savings  
            Act which authorizes JPAs to provide funding to customers of a  
            local agency or its publicly owned utility for water  
            efficiency improvements on the customer's private property.   








                                                                    SB 1233


                                                                    Page  13





            This bill creates the process for establishing a financing  
            program; specifies the information that must be included in  
            the written agreement between a customer, a local agency or  
            its locally owned utility, and a JPA; provides reporting  
            requirements for outstanding efficiency charges; requires a  
            local agency or its publicly owned utility to enter into a  
            servicing agreement with a JPA; and, provides for the bond  
            issuance.  Under this bill, following the establishment of a  
            financing program, a JPA would provide the customer of a local  
            agency or its publicly owned utility up front financing for a  
            water efficiency improvement that the customer would then  
            repay by an efficiency charge on the water bill.  JPAs would  
            be authorized to pool revenues generated by water efficiency  
            charges paid by participating customers to issue bonds,  
            pursuant to the Marks-Roos Act.  This bill is  
            author-sponsored.  


          3)Author's Statement.  According to the author, "This bill will  
            create a broad scale regional response to California's water  
            supply issues by adding Section 6588 of the California  
            Government Code to extend existing Marks Roos Local Bond  
            Pooling Act authority used by JPAs to fund utility projects to  
            voluntary customer water efficiency projects installed on  
            private property and paid for by participants. 





            "The legislation will enable JPAs to fund project installation  
            with pooled revenue bonds, with debt service provided through  
            meter charges aggregated from participating properties rather  
            than all ratepayers.  Just like a charge for water service,  
            individual meter charges are tied to the specific efficiency  
            services delivered at the meter location.  Meter charges  
            designed to be less than the estimated utility bill savings  
            delivered by the associated project create immediate net cost  
            savings at a participating property. 








                                                                    SB 1233


                                                                    Page  14










            "Pay As You Save (PAYS) pilots established by the Bay Area  
            Regional Energy Network (BayREN) have already demonstrated the  
            potential for this water efficiency model, saving 20-33% of  
            participating customers' water use.  Building upon these  
            successes, SB 1233 seeks to allow Local Governments the option  
            to: 1) Pool JPA Member Utilities into a single entity able to  
            raise capital; 2) Deliver centralized administration and  
            operation services to Member Utilities and their customers,  
            and; 3) Allow Member Utilities to aggregate customer on-bill  
            surcharges to repay the program for services received."  


          4)Financing Programs for Water Efficiencies.  Under existing  
            law, local governments have several options to respond to  
            concerns about the barriers to the upfront costs of water  
            efficiency improvements on private property.  



            Modeled after a financing program in the City of Berkeley, in  
            2008, the Legislature granted the statutory authority to  
            cities and counties to provide up-front financing to property  
            owners to install renewable energy sources or energy  
            efficiency improvements that are permanently fixed to their  
            properties, which is repaid through the property tax bill.   
            The Legislature has expanded PACE (Property Assessed Clean  
            Energy) for residential and commercial property owners as an  
            option to pay for renewable energy upgrades, energy and water  
            efficiency retrofits, water efficiency improvements, and other  
            specified improvements for their homes or buildings.  Local  
            agencies create PACE assessment districts or establish a  
            Community Facilities District (CFD), allowing the local agency  
            to issue bonds to finance the up-front costs of improvements.   
            In turn, property owners enter into a voluntary contractual  








                                                                    SB 1233


                                                                    Page  15





            assessment agreement with the local agency or agree to annex  
            their property into a CFD to re-pay the bonds via an  
            assessment or special tax, secured by a priority lien, on  
                                                                their property tax bill.  The intent of the program is that  
            the assessment or parcel tax remains with the property, even  
            if it is sold or transferred, and the improvements must be  
            permanently fixed to the property.  





            In California, there are several models available to local  
            governments in administering a PACE program.  Only the  
            counties of Sonoma and Placer administer their own PACE  
            programs.  The majority of local governments contract with a  
            private third-party or join a JPA, which contracts with a  
            private third-party to carry out their PACE programs.  





            Additionally, AB 2636 (Gatto), Chapter 825, Statutes of 2014,  
            created the CalConserve Water Use Efficiency Revolving Fund,  
            administered by the Department of Water Resources, to be a  
            sustainable funding source for water use efficiency projects.   
            The Legislature allocated $10 million to provide loans to  
            local agencies to provide water efficiency updates to eligible  
            residents at no upfront costs, and to local agencies to  
            implement water use efficiency loan programs through on-bill  
            financing.  


          5)Policy Considerations:  The Committee may wish to consider the  
            following:  


             a)   Existing Programs.  When faced with the barriers of  








                                                                    SB 1233


                                                                    Page  16





               up-front costs for water efficiency improvements, local  
               agencies and homeowners have options to offer PACE or apply  
               to participate in the CalConserve Water Use Efficiency  
               Revolving Fund.  Additionally, local agencies, like Windsor  
               or East Bay Municipal Utility District, may provide their  
               own on-bill financing programs or rebate programs.  The  
               Committee may wish to ask the author to explain why these  
               existing programs are not sufficient.


             b)   Water Efficiency Improvements.  This bill defines an  
               efficiency improvement to mean a water efficiency  
               improvement, as defined by the JPA.  The only prohibition  
               is that an efficiency improvement cannot include living  
               vegetation.  The Committee may wish to consider if  
               parameters should be established around what types of water  
               efficiency improvements that may be financed by this  
               program, especially in absence of any cost limitations or  
               requirements around a customer's ability to repay.  The  
               Committee may 




             wish to consider if DWR should play a role in determining the  
               types of improvements eligible for the program, similar to  
               those available in the CalConserve Water Use Efficiency  
               Revolving Fund.  
             c)   Consumer Protections.  This bill does not include any  
               requirements that ensure a customer's ability to repay nor  
               any assurances that the savings realized on a customer's  
               utility bill, as a result of the improvement, will be equal  
               to or greater than the amount necessary to repay the loan.   
               The Committee may wish to consider if this should be a  
               requirement for participation in the financing program.  


             d)   Written Agreement.  This bill requires a written  
               agreement with the customer to include a description of the  








                                                                    SB 1233


                                                                    Page  17





               financial calculation used to determine the efficiency  
               charge, which may include a component of reasonable  
               administrative expenses incurred by the local agency or the  
               JPA.  The Committee may wish to consider if the  
               administrative expense should be explicitly disclosed to  
               the consumer. 


             e)   Oversight and Reporting.  This bill requires a JPA to  
               report to CDIAC on debt issuance.  Absent any additional  
               reporting requirements, the Committee may wish to consider  
               a requirement for participating JPAs to produce an annual  
               report, and to consider if additional oversight and  
               reporting requirements should be included in this financing  
               program.  


             f)   Complaint Process.  Under this bill, if a customer does  
               not pay an efficiency charge, the local agency or its  
               publicly owned utility are authorized to use their  
               established collection policies, including turning off  
               water service.  This bill also authorizes the suspension of  
               payment, in the case of any failure of the improvement that  
               is not the fault of the customer, until an efficiency  
               improvement is repaired and returned to service.  This bill  
               requires the JPA's decision on the reasons for failure of  
               the improvement to be final and conclusive.  The Committee  
               may wish to consider if it should be the determination of  
               the local agency or, instead, its publicly owned utility  
               and if some type of process should be established by the  
               local agency or its publicly owned utility to consider  
               complaints.  


          6)Committee Amendments.  Due to the policy considerations raised  
            above, the Committee may wish to ask the author to accept the  
            following Committee amendments to ensure consumer protections:










                                                                    SB 1233


                                                                    Page  18





             a)   DWR.  The Committee may wish to consider lessons learned  
               from PACE, another voluntary financing program, which  
               authorizes local agencies to opt into a financing program  
               administered by a JPA.  To provide additional oversight,  
               the Committee may wish to ask the author to accept an  
               amendment to place oversight of this financing program with  
               DWR.  Additionally, Committee amendments would direct DWR  
               to utilize the work performed for the CalConserve program  
               to establish a list of eligible water efficiency  
               improvements, and to provide ongoing oversight and  
               monitoring of JPAs administering a financing program,  
               pursuant to this bill.  The Committee may wish to ask the  
               author to accept amendments that would require JPAs to  
               report the creation of a financing program and direct DWR  
               to compile annual reporting requirements for the JPAs,  
               which would include, but not be limited to, the  
               participating local agencies, 



             number of written agreements entered into, water savings  
               achieved, the amount of up front financing provided, the  
               amount of revenues collected, water efficiency savings 
             achieved, and a copy of the CDIAC report, the complaint  
               process for customers and local agencies or publically  
               owned utilities, and the oversight mechanism for  
               contractors and marketing.  

             b)   Resolution.  For transparency purposes, the Committee  
               may wish to require both the legislative body and the JPA  
               in their resolutions to establish the program to identify  
               the types of water efficiency improvements offered.  





             c)   Bill Neutrality.  The Committee may wish to consider an  
               amendment to require the local agency or its publicly owned  








                                                                    SB 1233


                                                                    Page  19





               utility to exemplify to the customer, based on recent  
               billing history, that the savings achieved will be equal to  
               or greater than the cost of the loan repayment.  This  
               requirement does not need to ensure future neutrality, as  
               conditions like usage by the customer may change, but  
               should be a requirement at the point the local agency or  
               its publicly owned utility enter into the written  
               agreement.  



             d)   Disclosures.  The Committee may wish to consider adding  
               explicit language to require that any administrative  
               expenses must be listed separately on the written agreement  
               to provide transparency.  Additionally, the Committee may  
               wish to require that the written agreement include the  
               authorization granted to the local agency or its publicly  
               owned utility to use collection policies and all rights and  
               remedies, under existing law, which includes discontinuing  
               water service.  



             e)   Determining Fault for an Improvement.  The Committee may  
               ask the author to accept an amendment to provide the local  
               agency or its publicly owned utility, instead of the JPA,  
               the right to determine failure of a water efficiency  
               improvement.  
          7)Arguments in Support.  Supporters argue that this bill is a  
            voluntary program and will create another tool for local  
            governments to respond to drought that is regionally  
            efficient, financially sustainable, and available to all  
            municipal utilities, large and small.  Additionally, this bill  
            will help people save money on water, while reducing wasted  
            water, and provide a voluntary tool to meet state conservation  
            mandate.  


          8)Arguments in Opposition.  None on file.  








                                                                    SB 1233


                                                                    Page  20







          












































                                                                    SB 1233


                                                                    Page  21







          REGISTERED SUPPORT / OPPOSITION:




          Support


          Association of Bay Area Governments 


          Bay Area Regional Energy Network


          California Apartment Association


          California Association of Realtors 


          California Building Industry Association


          California Business Properties Association


          California Chamber of Commerce


          Mayors and Councilmembers' Association of Sonoma County


          Nexus eWater, Inc.


          School Project for Utility Rate Reduction  









                                                                    SB 1233


                                                                    Page  22






          Sierra Club California 


          Sonoma County Board of Supervisors


          Sonoma County Regional Climate Protection Authority


          Sonoma County Water Agency


          StopWaste


          Town of Windsor




          Opposition


          None on file




          Analysis Prepared by:Misa Lennox / L. GOV. / (916)  
          319-3958
















                                                                    SB 1233


                                                                    Page  23